Public Comment, Subprime Mortgage Lending, George Mason University

Public Interest Comment onProposed Statement on Subprime Mortgage LendingOffice of the Comptroller of the Currency, Treasury (OCC); Board of Governors of the FederalReserve System (Board); Federal Deposit Insurance Corporation (FDIC); Office of ThriftSupervision, Treasury (OTS); and the National Credit Union Administration (NCUA)May 7, 2007 [OCC Docket No. 2007-3005; Board Docket No. OP-1278; OST Docket No. 2007-09] The Regulatory Studies Program (RSP) of the Mercatus Center at George Mason University is dedicated to advancing knowledge of the impact of regulation on society. As part of its mission, RSP conducts careful and independent analyses employing contemporary economic scholarship to assess rulemaking proposals from the perspective of the public interest. Thus, this comment in response to the proposed Interagency Statement (the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the National Credit Union Administration) on Subprime Mortgage Lending does not represent the views of any particular affected party or special interest group, but is designed to help the agencies make the greatest possible contribution to consumer welfare. I. Introduction In 2006, foreclosure rates on subprime mortgages more than doubled over the previous year, and a number of firms that specialize in such loans—primarily in the mortgage ...