Public Comment, Samuel D. Bornstein

June 1, 2007 Robert E. Feldman, Executive Secretary Attention: Comments, Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 Topic: The Proposed Statement on Subprime Mortgage Lending Dear Mr. Feldman: My comments apply to the basic concerns that need to be addressed as described in your proposed Statement on Subprime Mortgage Lending. We must develop new and innovative approaches using the latest state of the art technological tools in order to seek solutions to these pressing issues. 1) Subprime borrowers may not fully understand the risks and consequences of obtaining these products. 2) An institution’s analysis of a borrower’s repayment capacity should include an evaluation of the borrower’s ability to repay the debt. 3) The statement also underscores that communications with consumers should provide clear and balanced information about the relative benefits and risks of the products. The basis for my comments were derived from my unique perspective gained from 30 years as an educator, Professor of Accounting and Taxation, at Kean University School of Business, as well as 30 years professional experience gained as a practicing CPA and Consultant. I have recently concluded 5 years of research on the topic of Small Business Failure. As a by-product of my research findings, I have also developed an understanding of how to address the mortgage foreclosure phenomenon. A slogan that I recently encountered ...