[House Hearing, 117 Congress]
[From the U.S. Government Publishing Office]
HOW INVIDIOUS DISCRIMINATION
WORKS AND HURTS: AN EXAMINATION
OF LENDING DISCRIMINATION AND
ITS LONG-TERM ECONOMIC IMPACTS
ON BORROWERS OF COLOR
=======================================================================
VIRTUAL HEARING
BEFORE THE
SUBCOMMITTEE ON OVERSIGHT
AND INVESTIGATIONS
OF THE
COMMITTEE ON FINANCIAL SERVICES
U.S. HOUSE OF REPRESENTATIVES
ONE HUNDRED SEVENTEENTH CONGRESS
FIRST SESSION
__________
FEBRUARY 24, 2021
__________
Printed for the use of the Committee on Financial Services
Serial No. 117-5
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
U.S. GOVERNMENT PUBLISHING OFFICE
43-992 PDF WASHINGTON : 2021
HOUSE COMMITTEE ON FINANCIAL SERVICES
MAXINE WATERS, California, Chairwoman
CAROLYN B. MALONEY, New York PATRICK McHENRY, North Carolina,
NYDIA M. VELAZQUEZ, New York Ranking Member
BRAD SHERMAN, California FRANK D. LUCAS, Oklahoma
GREGORY W. MEEKS, New York BILL POSEY, Florida
DAVID SCOTT, Georgia BLAINE LUETKEMEYER, Missouri
AL GREEN, Texas BILL HUIZENGA, Michigan
EMANUEL CLEAVER, Missouri STEVE STIVERS, Ohio
ED PERLMUTTER, Colorado ANN WAGNER, Missouri
JIM A. HIMES, Connecticut ANDY BARR, Kentucky
BILL FOSTER, Illinois ROGER WILLIAMS, Texas
JOYCE BEATTY, Ohio FRENCH HILL, Arkansas
JUAN VARGAS, California TOM EMMER, Minnesota
JOSH GOTTHEIMER, New Jersey LEE M. ZELDIN, New York
VICENTE GONZALEZ, Texas BARRY LOUDERMILK, Georgia
AL LAWSON, Florida ALEXANDER X. MOONEY, West Virginia
MICHAEL SAN NICOLAS, Guam WARREN DAVIDSON, Ohio
CINDY AXNE, Iowa TED BUDD, North Carolina
SEAN CASTEN, Illinois DAVID KUSTOFF, Tennessee
AYANNA PRESSLEY, Massachusetts TREY HOLLINGSWORTH, Indiana
RITCHIE TORRES, New York ANTHONY GONZALEZ, Ohio
STEPHEN F. LYNCH, Massachusetts JOHN ROSE, Tennessee
ALMA ADAMS, North Carolina BRYAN STEIL, Wisconsin
RASHIDA TLAIB, Michigan LANCE GOODEN, Texas
MADELEINE DEAN, Pennsylvania WILLIAM TIMMONS, South Carolina
ALEXANDRIA OCASIO-CORTEZ, New York VAN TAYLOR, Texas
JESUS ``CHUY'' GARCIA, Illinois
SYLVIA GARCIA, Texas
NIKEMA WILLIAMS, Georgia
JAKE AUCHINCLOSS, Massachusetts
Charla Ouertatani, Staff Director
Subcommittee on Oversight and Investigations
AL GREEN, Texas Chairman
EMANUEL CLEAVER, Missouri ANDY BARR, Kentucky, Ranking
ALMA ADAMS, North Carolina Member
RASHIDA TLAIB, Michigan BARRY LOUDERMILK, Georgia
JESUS ``CHUY'' GARCIA, Illinois ALEXANDER X. MOONEY, West Virginia
SYLVIA GARCIA, Texas DAVID KUSTOFF, Tennessee
NIKEMA WILLIAMS, Georgia WILLIAM TIMMONS, South Carolina,
Vice Ranking Member
C O N T E N T S
----------
Page
Hearing held on:
February 24, 2021............................................ 1
Appendix:
February 24, 2021............................................ 31
WITNESSES
Wednesday, February 24, 2021
Cooper, Cheryl R., Analyst, Financial Economics Division,
Congressional Research Service................................. 12
Darity, William, Jr., Professor of Public Policy, African and
African-American Studies, and Economics, Duke University; and
Director, Samuel DuBois Cook Center on Social Equity........... 5
Espinoza, Frances, Executive Director, North Texas Fair Housing
Center......................................................... 10
Perry, Andre M., Senior Fellow, Metropolitan Policy Program, the
Brookings Institution.......................................... 9
Rice, Lisa, President and CEO, National Fair Housing Alliance
(NFHA)......................................................... 7
APPENDIX
Prepared statements:
Cooper, Cheryl R............................................. 32
Darity, William, Jr.......................................... 44
Espinoza, Frances............................................ 50
Perry, Andre M............................................... 52
Rice, Lisa................................................... 60
Additional Material Submitted for the Record
Green, Hon. Al:
Written statement of the Appraisal Institute................. 77
Written statement of Engine.................................. 79
``Financial Resilience Challenges During the Pandemic,''
Federal Reserve Bank of Atlanta............................ 112
``Mortgage Prepayment, Race, and Monetary Policy,'' Federal
Reserve Bank of Boston..................................... 115
GAO study, ``Fair Lending, Access, and Retirement Security... 196
HOW INVIDIOUS DISCRIMINATION
WORKS AND HURTS: AN EXAMINATION
OF LENDING DISCRIMINATION AND
ITS LONG-TERM ECONOMIC IMPACTS
ON BORROWERS OF COLOR
----------
Wednesday, February 24, 2021
U.S. House of Representatives,
Subcommittee on Oversight
and Investigations,
Committee on Financial Services,
Washington, D.C.
The subcommittee met, pursuant to notice, at 3:05 p.m., via
Webex, Hon. Al Green [chairman of the subcommittee] presiding.
Members present: Representatives Green, Cleaver, Adams,
Tlaib, Garcia of Illinois, Williams of Georgia; Barr,
Loudermilk, Mooney, and Taylor.
Ex officio present: Representative Waters.
Chairman Green. The Oversight and Investigations
Subcommittee will come to order.
Without objection, the Chair is authorized to declare a
recess of the subcommittee at any time. Also, without
objection, members of the full Financial Services Committee who
are not members of this subcommittee are authorized to
participate in today's hearing.
As a reminder, I ask all Members to keep themselves muted
when they are not being recognized by the Chair to minimize
disturbances while Members are asking questions of our
witnesses. The staff has been instructed not to mute Members,
except when a Member is not being recognized by the Chair and
there is inadvertent background noise.
Members are also reminded that all House rules relating to
order and decorum apply to this remote hearing. And Members may
only participate in only one remote proceeding at a time. If
you are participating today, please keep your camera on, and if
you choose to attend a different remote proceeding, please turn
your camera off.
If Members wish to be recognized during the hearing, please
identify yourself by name to facilitate recognition by the
Chair.
The title of today's hearing is, ``How Invidious
Discrimination Works and Hurts: An Examination of Lending
Discrimination and Its Long-Term Economic Impacts on Borrowers
of Color.''
We will now move to opening statements, and, in so doing, I
will recognize myself for 4 minutes for an opening statement,
with the understanding that the Chair of the Full Committee,
Chairwoman Waters, will be present at some point, and will
receive 1 minute of the additional time that we have for
opening statements.
Friends, lie on a mortgage application to secure a loan,
and you are likely to get caught and criminally prosecuted for
mortgage fraud, with jail time as a consequence. Lie as a loan
originator to deny a loan to a person of color, and you are not
likely to get caught, and if you do get caught, a civil
monetary fine is likely the consequence, and little more than
the cost of doing business.
H.R. 166, the Fair Lending for All Act, provides the best
tool available--testing--to catch, prosecute, and deter these
predatory criminal lenders.
First, H.R. 166 would provide critical tools for detecting,
ending, and sanctioning discrimination that would otherwise go
undetected. It would deter the predatory lending that
perpetuates race-based differences in wealth, asset
accumulations, income, and financial security.
There is no enforcement tool--some things bear repeating--
there is no enforcement tool with the utility of matched-pair
testing. This is why H.R. 166 creates a dedicated Federal
office within the Consumer Financial Protection Bureau (CFPB),
which would be charged with conducting such testing.
Second, H.R. 166 would expand the Equal Credit Opportunity
Act's (ECOA's) terms to expressly prohibit lending
discrimination against LGBTQ+ persons.
Finally, H.R. 166 would establish criminal penalties for
lenders and lending officials who engage in knowing and willful
discrimination in violation of ECOA.
This concludes my opening statement.
At this time, without objection, I would like to place in
the record the following documents: a GAO report dated February
24, 2021; a document styled, ``Financial Resilience Challenges
During the Pandemic,'' which is an article from the Atlanta
Federal Reserve Bank examining the history of discriminatory
policies that leave many Black and Hispanic households less
resilient in the face of economic shock caused by the pandemic;
and a document styled, ``Mortgage Prepayment, Race, and
Monetary Policy,'' a working paper from the Boston Federal
Reserve Bank which finds that Black and Hispanic borrowers pay
more than 50-basis-points-higher interest rates than White
borrowers in a large representative sample of loans insured by
Fannie Mae and Freddie Mac.
Without objection, it is so ordered.
Having made my opening statement, it is now my honor to
yield to the ranking member of the subcommittee, Mr. Barr, for
5 minutes for his opening statement.
Mr. Barr. Thank you, Mr. Chairman. I appreciate you
yielding, and I appreciate you holding today's hearing.
Thank you also to our witnesses for appearing today.
Discrimination in lending and other financial services is
wrong, it is illegal, and it should not be tolerated. There is
no room for compromise on that point.
While discrimination is illegal, that does not mean that
there are not large pockets of the population who continue to
be left behind by our banking system. It is important that we
review and address those problems holistically. Our discussion
on the economic impacts of inequities in the financial system
should extend to all unbanked and underbanked groups.
Economic recovery is well under way in the wake of the
COVID pandemic. Unfortunately, many Americans continue to
struggle financially. The pandemic has exposed and exacerbated
certain weaknesses in our financial system, highlighting how
large portions of the population still have trouble accessing
credit. Every American should have equal access to our
financial system regardless of their race or gender, whether
they live in urban or in rural America, or any other factor.
One area of particular concern to me is the access to
capital and other financial services in rural areas. According
to a recent FDIC study, people in rural areas are more likely
than their urban and suburban counterparts to visit a bank
branch in person to do their banking. Unfortunately, the number
of bank branches across the country continues to decrease, and
the pace of de novo bank formation has slowed significantly
compared to pre-financial crisis levels.
As there has been a movement towards online banking, we
know the challenges that rural Americans face with respect to
rural broadband, and that is another impediment.
There were 181 de novo charters granted in 2007, but
between 2010 and 2019, an average of fewer than 10 new banks
opened per year. A recent Federal Reserve study shows that 51
percent of the 3,114 counties in the United States saw net
declines in the number of bank branches between 2012 and 2017.
These declines in bank branches disproportionately hit rural
communities. A total of 794 rural counties lost a combined
1,553 bank branches over the 5-year period, a 14-percent
decline.
The negative financial impacts on rural counties of branch
closures are perpetuated by the continuing difficulties due to
burdensome regulations and other roadblocks of de novo
community bank formation.
The Federal Reserve report identified 44 counties
considered deeply affected by trends in bank closures and
consolidation, which it defines as counties that had 10 or
fewer branches in 2012, and lost at least 50 percent of those
branches by 2017. Eighty-nine percent of the deeply affected
counties are rural counties, including Nicholas County in my
district, and counties in the districts of several of my
colleagues.
The current framework of Federal, State, and local laws
prohibits discrimination of any kind in lending. Financial
regulators have developed robust tools to ensure that regulated
firms play by those rules. To the extent that firms are failing
to comply with those rules, or that additional statutory
authority is needed to combat discrimination, we must act.
However, we must also be cautious about imposing additional
restrictions and regulations on lenders that do not accomplish
a specific goal, and monitor potential impacts of our actions
on the widespread availability of financing to creditworthy
borrowers.
Emerging technology has allowed people previously outside
the banking system to access financial services and has
enhanced lenders' ability to tailor their products to the
specific characteristics of the borrower based on race-blind
metrics. Meaningful restrictions on risk-based pricing will do
more harm than good, as creditworthy borrowers pay more for the
capital they need.
Promoting across-the-board financial inclusion should be a
top bipartisan priority for this subcommittee. I appreciate the
opportunity to discuss ways to ensure that more people,
including those currently underserved in the market, have easy,
fair, and safe access to financial services.
I look forward to working with Chairman Green to ensure
that discrimination does not occur in lending, and to promote
policies that expand access to credit and lead to long-term
economic growth. And, again, the warning is to not do away with
risk-based pricing, which I think would curtail and restrict
access to credit for creditworthy borrowers.
I look forward to hearing from our witnesses today, and I
yield back the balance of my time.
Chairman Green. Thank you, Mr. Ranking Member. I appreciate
your commentary, and I look forward to working with you.
I am told that the Chair of the Full Committee, Chairwoman
Waters, has arrived, so I will now yield to Chairwoman Maxine
Waters for 1 minute.
Chairwoman Waters. Thank you so very much. Good afternoon,
Chairman Green.
The discriminatory lending practices of the 20th Century
continue to affect minority communities long after they are
repealed. The effects of decades of government-sanctioned
discrimination continue to plague our housing and lending
markets today, ultimately hindering the ability of households
of color to build equity and accumulate wealth through
homeownership relative to White households.
Since home equity is the primary source of wealth for most
families, disparities in homeownership and home equity are key
drivers of the racial wealth gap. So, I look forward to hearing
from our witnesses today about what we can do to remedy the
continuing economic effects of discrimination.
Thank you, and I yield back the balance of my time.
Chairman Green. Thank you, Madam Chairwoman.
Let me make an announcement, if I may. We will have
additional votes, and the staff has indicated that we will make
a great attempt to wait until the first vote has expired, or
nearly expired. This way, we will be able to cast two votes and
then come back to the hearing. My hope is that we will get this
done as expeditiously as possible.
Today, I would like to welcome each of our witnesses. And I
am pleased to introduce this panel: William Darity, Jr.,
professor of public policy, African and African-American
studies, and economics at Duke University, as well as the
director of the Samuel DuBois Cook Center on Social Equity;
Lisa Rice, president and CEO of the National Fair Housing
Alliance; Andre Perry, senior fellow at the Metropolitan Policy
Program at the Brookings Institution; Frances Espinoza,
executive director of the North Texas Fair Housing Center; and
Cheryl Cooper, an analyst for the Financial Economics Division
at the Congressional Research Service.
Witnesses are reminded that your oral testimony will be
limited to 5 minutes. You should be able to see a timer--and
this timer should be on your screen--that will indicate how
much time you have left, and a chime will go off at the end of
your time. I would ask that you be mindful of the timer, and
quickly wrap up your testimony if you hear the chime, so that
we can be respectful of both the witnesses' and the committee
members' time. And without objection, your written statements
will be made a part of the record.
Once the witnesses finish their testimony, each Member will
have 5 minutes to ask questions. And may I remind Members to
please get your questions and answers in within that 5-minute
time period. Let me restate this differently; you should not,
at the end of your 5 minutes, have multiple questions to be
answered. Please be mindful of the time of other Members in
trying to get your time in within the 5 minutes.
Professor Darity, you are now recognized for 5 minutes to
give an oral presentation of your testimony.
STATEMENT OF WILLIAM DARITY, JR., PROFESSOR OF PUBLIC POLICY,
AFRICAN AND AFRICAN-AMERICAN STUDIES, AND ECONOMICS, DUKE
UNIVERSITY; AND DIRECTOR, SAMUEL DUBOIS COOK CENTER ON SOCIAL
EQUITY
Mr. Darity. Thank you, Chairman Green, Ranking Member Barr,
and members of the subcommittee.
Discrimination in access to credit and the terms of credit
is an important barrier to Black wealth accumulation.
Elimination of this barrier, albeit wholly desirable, will not
eliminate the gaping chasm in wealth between Black and White
Americans.
The fundamental reason for Black-White differences in
wealth is not high Black indebtedness. The fundamental reason
is low Black asset holdings.
A Prosperity Now study in 2019 reported that median Black
household liabilities were $30,800, while the median White
household liabilities were more than twice as large, at
$73,800. However, White households had a median level of assets
valued in excess of $260,000, in contrast with the median Black
households' assets, valued at $55,900.
The median Black household had 40 percent of the debt of
the median White household but only 20 percent of the assets.
Correspondingly, the ratio of assets to debts for Black
households was 1.6, versus 2.8 for White households, both
measured at the median.
The magnitude of the racial wealth gap, driven
predominantly by a racial difference in asset ownership, is
staggering. The 2019 Survey of Consumer Finances indicates that
the Black-White wealth gap at the median was $164,000, and at
the mean, it was substantially larger, at $840,900.
Assuming an average household size of 3 persons, the median
gap per person was $52,500 and the mean gap was $280,000. These
are conservative estimates of per-capita differentials because
the average White household size is actually less than 3
people.
Many observers treat the median gap as the target for
closing the racial wealth gap in the United States. In this
context, it may be more appropriate to set the more demanding
target at the mean.
Wealth is so densely concentrated in the United States that
90 percent of the wealth held by White Americans is in the
possession of White households with a net worth above the White
median. Close to 99 percent of White household wealth is held
by those with a net worth above the national median,
approximately $100,000. Twenty-five percent of White households
have a net worth in excessive of $1 million, in contrast with
only 4 percent of Black households.
The limitations of an exclusive focus on debt reduction
rather than asset building comes into stark relief when
considering a policy of student loan relief. Whether one
eliminates student debt by trying to erase the difference at
the median or the mean, there will be at best an incremental
effect on the racial wealth differential.
The net reduction in the gap will be $1,856 after we adjust
for the enrollment rates that are different between the two
communities. And, therefore, the reduction amounts to only 3
percent of the total median gap of $52,500. It amounts to less
than 1 percent at the mean gap of $280,000.
Indeed, the key to understanding the sources of the racial
wealth gap is government policy that supported the
underdevelopment of asset accumulation in the Black community.
In January 1865, General William T. Sherman, after
Secretary of War Edwin Stanton and he held a consultation with
a group of Black leaders in Savannah, Georgia, issued Special
Order No. 15. His directive assigned 5.3 million acres of land,
stretching from the Sea Islands of South Carolina to the
portion of northern Florida bordered by the St. Johns River, as
a site for settlement and property for the newly emancipated.
Here was an intended preliminary phase of a substantial
land reform on behalf of the formerly enslaved that would have
amounted to at least 40 million acres of land for the 4 million
persons released from bondage.
Ultimately, only 40,000 persons settled on 400,000 acres,
but even that small allotment was lost by the end of the year.
Andrew Johnson, Lincoln's successor, ended the land allocation
program and restored the properties to the former slaveholders.
The promise of 40-acre land grants remained unfulfilled.
Simultaneously, the Federal Government, under the auspices
of the Homestead Act of 1862, was distributing 160-acre tracts
of lands to upwards of 1.5 million White families in the
western territories. This huge asset-building policy resulted
in benefits carrying over to a conservative estimate of 45
million White living descendants of Homestead Act patents.
The racial wealth gap in the United States originates with
the failure to give the formerly enslaved 40 acres, while White
Americans, including new immigrants, were given 160 acres of
land.
Conditions worsened with wave upon wave of White massacres
that took place between the end of the Civil War and World War
II. In the Red Summer of 1919, upwards of 35 White terrorist
actions took place across the country in locations ranging from
Chicago, Illinois; to Omaha, Nebraska; to Washington, D.C.; to
Elaine, Arkansas.
The most famous of these--
Chairman Green. Professor, I am going to have to ask that
you summarize quickly, please.
Mr. Darity. Okay--took place in Tulsa, Oklahoma, in 1921.
I would add that the destruction of Black property and the
appropriation of Black property that was lost in that period of
time was compounded by the policies in the 20th Century that
discriminatorily provided support for asset building in the
form of homeownership.
Indeed, the effects of these disparities transmitted across
generations resulted in the contemporary Black-White wealth
gap. And the disproportionate growth in Black debt matters in
explaining America's racial wealth gap, but the
disproportionate deprivation of Black assets matters far more.
By all means, we should take steps to make the credit
market more racially equitable, but if our goal is to eliminate
the Black-White difference in wealth, the focus must be placed
on building Black assets to a level consistent with White asset
ownership.
[The prepared statement of Mr. Darity can be found on page
44 of the appendix.]
Chairman Green. Thank you, Professor.
Ms. Rice, you are now recognized for 5 minutes to give your
oral presentation.
STATEMENT OF LISA RICE, PRESIDENT AND CEO, NATIONAL FAIR
HOUSING ALLIANCE (NFHA)
Ms. Rice. Chairwoman Waters, Subcommittee Chair Green,
Subcommittee Ranking Member Barr, and other members of the
subcommittee, I want to first thank you for inviting me to talk
about this really important issue.
Housing and lending discrimination have been a part of the
United States since its inception, and have helped create the
racial wealth and homeownership gaps that Professor Darity has
just spoken about.
Due to government-sanctioned discriminatory policies as
well as private-market practices, underserved groups have been
systemically excluded from wealth-building opportunities such
as homeownership.
These groups still experience high levels of
discrimination. There are over 4 million instances of housing
discrimination each year. Redlining, which persists in various
forms today, real estate sales discrimination, appraisal bias,
lending discrimination, and tech bias are significant barriers
that keep the dream of homeownership from becoming a reality
for many people, and contribute to the racial wealth gap.
Moreover, structural barriers, such as the dual credit
market, segregation, and restrictive zoning ordinances, create
systemic impediments which significantly prohibit the ability
of people of color to access fair housing and fair lending
opportunities and perpetuates the racial wealth and
homeownership gaps.
The segregation of people based on race, coupled with the
segregation of resources, drives many of the disparities in
health, education, wealth, and many other areas. And these
structural barriers, these structural inequities are a reason
that Blacks, Latinos, and Native Americans are contracting and
dying from the COVID virus at disproportionately higher rates
than their White counterparts.
Segregation is also a driver of the racial homeownership
gaps. The homeownership rate for Black Americans, for example,
is where it was when the Fair Housing Act was passed in 1968.
And the homeownership gap between Blacks and Whites is as wide
today as it was in 1890.
There are many ways that invidious discrimination harms
communities. For example, many of the technologies used in the
housing and financial services space are biased, and
discriminate against consumers of color. Tenant screening
selection tools, automated underwriting systems, credit scoring
models, risk-based pricing systems, and digital marketing
platforms all have discriminatory outcomes and lock people out
of housing opportunities.
Too many people experience discrimination when they seek to
access housing and housing-related opportunities. Newsday
recently completed an in-depth testing project on Long Island,
New York, in which they found that 49 percent of African
Americans, 39 percent of Hispanics, and 19 percent of Asian
Americans experienced discrimination, including racial
steering.
Real estate discrimination can take on myriad forms, and
our recent lawsuit against Redfin illustrates that: NFHA and
nine of our member organizations conducted a comprehensive
investigation of Redfin, one of the nation's largest real
estate companies. The investigation uncovered disturbing
practices that suggested really wide-scale discrimination and
modern-day technology-based real estate redlining. The groups
found that Redfin offered its best available service at
significantly higher rates in extremely White communities, and
offered no service for homes in communities of color at much
greater rates than in predominantly White areas.
Appraisal bias and lending discrimination are also still
too common. Analysis of Home Mortgage Disclosure Act (HMDA)
data revealed that communities of color are still being
redlined by mainstream financial institutions.
One way to overcome discrimination is to increase funds for
testing programs. And the Supreme Court has stated that testing
is one of the best mechanisms for ferreting out discrimination.
This is why the National Fair Housing Alliance supports the
Fair Lending for All Act, which would help address longstanding
barriers to fair and equal credit by adding sexual orientation
and gender identity protections to the Equal Credit Opportunity
Act, but would also make it illegal to discriminate against
people based on geographical location, and re-empower the
Consumer Financial Protection Bureau (CFPB) to address fair-
lending issues and to test for fair-lending violations.
And I thank you.
[The prepared statement of Ms. Rice can be found on page 60
of the appendix.]
Chairman Green. Thank you very much, Ms. Rice, for your
testimony.
Mr. Perry, you are now recognized for 5 minutes to give an
oral presentation of your testimony.
STATEMENT OF ANDRE M. PERRY, SENIOR FELLOW, METROPOLITAN POLICY
PROGRAM, THE BROOKINGS INSTITUTION
Mr. Perry. Chairwoman Waters, Chairman Green, Ranking
Member Barr, Vice Ranking Member Timmons, thank you for
inviting me to testify today on this extremely important issue
that affects millions of people across the country.
``We are here today because we are tired. We are tired of
paying more for less.''
Dr. Martin Luther King, Jr., said those words in 1966, to
35,000 people in Chicago's Soldier Field, as part of the
Chicago Freedom Movement, also known as the Chicago Open
Housing Movement. Dr. King went on to relay housing price
differences that resulted in Black people paying higher rents
in Black-majority communities for worse housing than their
White counterparts.
``Now is the time to make real the promises of democracy,''
Dr. King declared. ``Now is the time to open the doors of
opportunity to all of God's children.''
More than half a century later, now is still the time.
According to the most recent Census figures, the Black
homeownership rate in America is 46 percent, almost the exact
same level that it was when Dr. King spoke in 1966. This is
compared to the White homeownership rate, which is roughly 74
percent.
Even as overall U.S. homeownership has grown over the last
2 decades, there has been a catastrophic loss of homeownership
in key cities that have large shares of Black residents.
When people in Black neighborhoods do own homes, we accrue
less wealth. Homeowners in disproportionately Black and Latino
neighborhoods are gaining wealth at about half the speed of
homeowners in predominantly White neighborhoods.
One of the reasons is that these homes are devalued. In the
2018 Brookings report, ``The Devaluation of Assets in Black
Neighborhoods,'' Jonathan Rothwell, David Harshbarger, and I
found that, even after accounting for structural
characteristics such as square footage, age, and number of
bedrooms, as well as neighborhood characteristics such as crime
and school quality, homes in Black neighborhoods were valued,
on average, $48,000 less than they would have been if the
residents of the neighborhood were mostly White. That is a
cumulative loss of $156 billion nationwide.
And we witness viral news stories revealing how appraisers
value Black and White homeowners differently. In Jacksonville,
Florida, a mixed-race family looking to sell their home in a
predominantly White neighborhood received an original appraisal
of $330,000. After presenting a White owner, a second appraisal
came in $135,000 higher.
A similar incident occurred in Denver. Again, after the
family removed indicators of Blackness, the home increased in
value by $145,000. In San Francisco, a second appraisal
increased its value by $500,000.
``We are here today because we are tired. We are tired of
paying more for less.''
These seemingly individual acts of racism are part and
parcel of a structural problem. The housing market is
structured to disproportionately exclude Black and Brown
households.
For instance, our zoning codes and building practices are
streamlined to deliver large, single-family homes. My
colleague, Tracy Loh, and I showed in a recent study that, for
decades, the very largest houses--four or more bedrooms--have
grown as a share of all housing inventory, while smaller homes,
which are more affordable for low-wealth families, have
stagnated or declined.
Over 6 million Black and Brown millennials would be
considered mortgage-ready if there were any attainable homes
for sale in prime locations.
Black buyers are subjected to racist steering practices
when looking for a home. When applying for a loan, Black buyers
are perceived as higher-risk, leading to more denials and
higher interest rates.
Devaluation limits the amount of gain from refinancing. As
we have heard, bad appraisals also rob families of wealth.
And all of these housing industry actors blame each other
for the problem.
``We are here today because we are tired. We are tired of
paying more for less.''
We made individual racism in the housing market illegal,
and when it finds its way back in, we make a headline. But
structural racism rigs the game from the start. The root cause
for these negative trends is structural racism, which is
systemic. To unlock the potential of Black neighborhoods and
their residents, systemic racism must be pulled at its roots,
rather than trimmed neatly, only to grow again.
Thank you for my time.
[The prepared statement of Mr. Perry can be found on page
52 of the appendix.]
Chairman Green. Thank you, Mr. Perry.
Ms. Espinoza, you are now recognized for 5 minutes to give
an oral presentation of your testimony.
STATEMENT OF FRANCES ESPINOZA, EXECUTIVE DIRECTOR, NORTH TEXAS
FAIR HOUSING CENTER
Ms. Espinoza. Thank you, Chairman Green, Ranking Member
Barr, and subcommittee members.
The North Texas Fair Housing Center is a nonprofit
organization that provides fair-housing services to residents
of north Texas. Our services consist of fair-housing
counseling, intake, and investigation of housing discrimination
complaints, and fair-housing education.
It has been 50 years since the Federal Fair Housing Act
banned racial discrimination in lending, yet African-American
and Latino applicants continue to be routinely denied
conventional mortgage loans at rates far higher than their
White counterparts.
In 2011, the North Texas Fair Housing Center did an
analysis of Home Mortgage Disclosure Act data and found that
African-American and Latino mortgage applicants were denied
conventional mortgages at much higher rates than Whites in the
Dallas-Fort Worth market.
For example, African-American mortgage applicants to Wells
Fargo Bank were 57 percent less likely to get a home purchase
loan when compared to White applicants. Latino mortgage
applicants to Chase Bank were 64 percent less likely to get a
loan than were White applicants. Home Mortgage Disclosure Act
data from 2015 and 2016 confirmed the same pattern.
One of the most valuable tools we use to investigate
housing discrimination is testing. Testing allows us to compare
how applicants of color are treated as compared to their White
counterparts.
As part of our enforcement program, we use the results of
testing as evidence in housing discrimination complaints. We
file both administrative complaints with the U.S. Department of
Housing and Urban Development and lawsuits in Federal court.
The most common form of testing we do is rental testing. In
2011, we conducted rental testing which showed that African
Americans who were otherwise qualified encountered
discrimination in 37 percent of their housing searches. This
means that African Americans face discrimination in two out of
every five housing searches.
The testing also showed that Latinos experienced
discrimination in 33 percent of their housing searches, or at
least once in every three housing searches.
In our most recent enforcement initiative in 2019, we
conducted tests to measure how veterans with Housing Choice
Vouchers were treated in the housing market in Dallas, Texas.
We conducted a total of 35 tests, and the results of 32 of them
showed evidence of discrimination. We filed housing
discrimination administrative complaints for all 32 tests.
The next most common form of testing that we do is sales
testing. These tests measure how real estate agents treat
buyers of color as compared to their White counterparts. In
2018, we conducted sales tests which showed that African-
American testers are still being steered, based on their race,
to neighborhoods that are predominantly African-American and
steered away from neighborhoods that are majority-White.
Unlike rental and sales testing, mortgage lending testing
is very resource-intensive. One of the challenges is the
significant amount of time that testers must devote to each
test. Unlike rental tests, which can be completed rather
quickly, lending interviews involve several complex financial
components, even at the pre-application stage. Testers must
also be knowledgeable about the entire lending process.
Rental, sales, and lending testing can all be used to
uncover practices that lead to segregation of neighborhoods.
However, there is a particular need to devote resources to
lending testing because it is so resource-intensive.
There is also a need for enforcement of complaints based on
lending testing evidence. Because lending testing cases are
more complex, they sometimes languish in the administrative
process. There is a need for a strong entity with an expertise
in lending discrimination that can take the testing evidence
generated by local fair-housing organizations and move forward
with enforcement that will thwart illegal practices.
Thank you for inviting me. My statement is complete.
[The prepared statement of Ms. Espinoza can be found on
page 50 of the appendix.]
Chairman Green. Thank you very much, Ms. Espinoza.
Ms. Cooper, you are now recognized for 5 minutes to give an
oral presentation of your testimony.
STATEMENT OF CHERYL R. COOPER, ANALYST, FINANCIAL ECONOMICS
DIVISION, CONGRESSIONAL RESEARCH SERVICE
Ms. Cooper. Chairman Green, Ranking Member Barr, and
members of the subcommittee, thank you for the opportunity to
testify today.
My name is Cheryl Cooper, and I am an analyst in financial
economics at the Congressional Research Service (CRS), focusing
on consumer finance markets and policy issues. For those who
might be unfamiliar with CRS, our role is to provide objective,
nonpartisan research and analysis to Congress.
Any arguments presented in my testimony are for the
purposes of informing Congress and not to advocate for a
particular policy outcome.
My testimony today will focus on disparities in access to
financial products and services, including racial, ethnic,
income, age, and geographic disparities. In particular, I will
focus on discussing disparities in access to banking services
and disparities in inclusion in the credit reporting system.
These areas are generally considered foundational for
households to successfully manage their financial affairs and
to graduate to wealth-building activities in the future, like
homeownership.
Consumers often rely on family or community connections to
get their first bank account, establish a credit history, and
gain access to affordable credit. However, research suggests
that disparities in family wealth or in community relationships
with financial institutions can potentially persist across
generations.
A factor that may be influencing racial disparities is the
intergenerational effects of discrimination--for example,
historical mortgage lending practices, redlining practices.
Moreover, violations in fair-lending laws can cause harm to
consumers who do not get access to financial services. This is
important because safe and affordable financial services are an
important tool for most American households to help them avoid
financial hardship and build assets over the course of their
lives.
According to the FDIC's 2019 survey, over 5 percent of
households in the United States were unbanked, meaning that
these households did not have a bank account. In addition, over
17 percent of households used a nonbank financial transaction
service, like a money order, a check-cashing, or a bill payment
service.
These households are disproportionately of a racial or
ethnic minority and tend to be lower-income, younger, and have
less formal education. Urban and rural households are more
likely to be unbanked, compared to suburban households.
Unbanked households report that they do not have a bank
account because they do not have enough money, they don't trust
banks, they have privacy concerns, and they want to avoid high
and unpredictable bank fees.
These disparities in access are significant because some
research suggests the importance of emergency savings and
affordable payment transactions. Also, developing a
relationship with a bank can sometimes lead to access to other
financial products, helping young consumers develop a credit
history.
A limited credit history may serve as a barrier to
achieving affordable credit, yet consumers also can't develop a
credit history without access to credit products. This chicken-
and-egg situation can make it difficult for some people to
enter the credit reporting system.
According to the CFPB, credit scores can't be generated for
approximately 20 percent of the U.S. population due to their
limited credit histories. Limited credit history is correlated
with age, income, race, and ethnicity. Many of these consumers
are young. For example, 40 percent of credit invisibles are
under 25-years-old. These consumers are disproportionately
Black or Latino and live in lower-income or rural
neighborhoods.
Most young adults transition into the credit reporting
system in their early twenties. Young adults in lower-income
and rural neighborhoods tend to make the transition to credit
visibility at older ages than young adults in higher-income
areas. And, notably, in lower-income communities, it is less
common to enter the credit reporting system through what is
called, ``piggybacking,'' or becoming a joint account holder or
authorized user on another person's account, such as a parent's
account.
The disparities in inclusion to the credit reporting system
are significant because it is generally a precursor to gain
access to affordable credit and eventually to homeownership.
Thank you for your time, and I am happy to answer any
questions that you have.
[The prepared statement of Ms. Cooper can be found on page
32 of the appendix.]
Chairman Green. Thank you very much, Ms. Cooper.
The Chair will now recognize Members for questions.
The gentleman from Missouri, Mr. Cleaver, who is also the
Chair of our Subcommittee on Housing, Community Development,
and Insurance, is now recognized for 5 minutes.
Mr. Cleaver. Thank you, Mr. Chairman. I appreciate this
opportunity. And I think this is exactly the kind of hearing
that we need, so thank you.
Where I would like to center my discussion, my questions,
is on the fact that the current Federal public policies operate
to perpetuate or expand the racial wealth gap.
So, I would like to ask any of the panelists, are there
Federal public policies that actually contribute to the
exclusion of African Americans, Brown people, people of color?
And what impact does it have on the wealth gap? I am talking
about Federal policies.
Mr. Perry. I will take a stab at that.
One of the things I am noticing is that current legislation
does not address wealth in this country. We measure almost
everything by income. And by doing so, you essentially abdicate
responsibilities of dealing with the structures that created
the gaps in the first place. In many different systems--
housing, education, and other areas--if you don't address the
wealth gap, you essentially gloss over the problem.
In addition, we also have a race and space problem. Because
racist policies have followed Black people, we see
discrimination in rural communities, in urban communities, in
suburbs. And, for my take, it is hard to not have a race and
place approach to change.
And so, for me, it is not necessarily what the Federal
Government is doing; it is what the Federal Government is not
doing, not measuring, not testing. Because we have ample data
that shows the impact of our policies, but what we have not
done is really get at the reasons, the causes for these
disparities.
Mr. Cleaver. Yes. I think you are making a case for the
increase of the minimum wage, and I think that is going to--
that is a debate we are having right now.
Ms. Rice. Congressman, if I can add to that, too, there are
a lot of policies that perpetuate racial disparity. So, in
terms of Federal policies: the recently promulgated cap rule
that was promulgated by the Federal Housing Finance Agency; the
GSE LLPA structure, the loan-level pricing adjustment
structure, discriminates against communities of color; the
current Affirmatively Furthering Fair Housing rule that was
promulgated several months ago by the Department of Housing and
Urban Development, which really eviscerates our civil rights
rules; and the current Disparate Impact rule that was
promulgated by the Department of Housing and Urban Development
several months ago, which also eviscerates a major civil rights
tool that we have for addressing discriminatory policies.
So, there are many, many Federal policies that right now,
work to perpetuate discriminatory outcomes.
Mr. Cleaver. Thank you.
I think my time is running down, so I appreciate both you
and Mr. Perry for your comments. Thank you.
Chairman Green. The gentleman yields back.
The Chair now recognizes the ranking member of the
subcommittee, Mr. Barr, for 5 minutes.
Mr. Barr. Thank you, Mr. Chairman.
Last year, I introduced H.R. 8410, the Promoting Access to
Capital in Underbanked Communities Act, which is designed to
spur de novo bank formation and promote banking services in
underserved areas.
The bill would ease the up-front burden of opening a bank,
and provide incentives for banks to open and operate in rural
areas. The bill is intended to address the problem of deeply
affected counties that I referenced in my opening statement,
which have lost a large portion of their bank branches.
Ms. Cooper, how have bank closures in rural communities
impacted customers living in those areas? What long-term issues
will arise if rural communities continue to face an
unprecedented number of bank closures? And we anticipate that,
given the trend of bank consolidation. Could a bill like the
one I just referenced, designed to promote more banking
activity in rural and otherwise underserved areas, help with
those problems?
Ms. Cooper. Thank you so much for your question,
Congressman.
As I mentioned in my oral statement, there are geographic
disparities that exist in terms of access to financial
products. And as you mentioned and I mentioned, research
suggests that, for consumers living in rural areas, these
consumers may be living farther from bank branches or also may
be less likely to have access to high-speed internet, and both
of these factors could possibly make it more difficult for
consumers to access quality banking services.
We at CRS don't advocate for a particular policy outcome,
but I would be happy, after this hearing, to look at the bill
with some of my CRS colleagues.
Also, in general, around trends in terms of consolidation
in the banking industry, this has been happening for decades.
We have seen a reduction in community banks for the past few
decades, particularly a reduction in bank branch openings in
the past decade.
And there are a lot of different factors that are leading
to this trend. In general, economists would say that you are
starting to see economies of scale, which basically means that
big banks are becoming more profitable than smaller banks to
operate. And that is probably part of the reason why we are
seeing this consolidation in the banking industry.
Mr. Barr. Ms. Cooper, I did see, though--and I respect that
CRS doesn't make policy endorsements, but I did see in your
testimony, in the, ``Possible Policy Responses'' section,
``Bank Regulation Changes,'' that you mentioned the Community
Reinvestment Act (CRA). And I think, for our friends and
neighbors in underserved parts of our country in both urban and
rural areas, this is something that I think would be welcome,
to give banks more credit for bank account outreach activities
in those underserved areas.
Do you have any specifics on that? We saw an effort by the
OCC, and Lael Brainard at the Federal Reserve, to update the
CRA, but how can we give incumbent banks and new banks in these
underserved areas credit for originating loans under the CRA?
Ms. Cooper. Yes. Thank you so much for that question.
You are right, one of the things that I mentioned in terms
of possible policy options for expanding access to credit was
possible proposed changes to bank regulation. So, this is one
of the areas where we see proposals on this.
For example, I know the bank regulators have stated that
they were considering changes to the Community Reinvestment Act
to give banks more credit for bank account outreach activities
in underserved communities. But I think there are trade-offs to
these type of policies.
The positive, as you were saying, is that it can encourage
bank outreach and connect more consumers to banks. But I think
the flip side to it is, also, it could give credit for what
some may consider effectively marketing, rather than the
intention of the law, which was to encourage lending in
underserved communities.
Mr. Barr. Thank you.
Ms. Cooper. This is an area where there--
Mr. Barr. Thank you.
And just reclaiming my time, in the final time I have, how
is compliance under the Equal Credit Opportunity Act currently
tested? And is there any indication that the testing regime
needs to be strengthened? Or do regulators currently have
enough authority to enforce that law?
And that is again to you, Ms. Cooper.
Ms. Cooper. Yes. Thank you so much for that question. And
we are running out of time, so let me get back to you with
that. I am happy to answer that question with one of my CRS
colleagues.
Mr. Barr. Mr. Chairman, my time has expired, and I know
that is a subject or a topic that is part of your legislation,
so I invite any or all of the witnesses to comment on that and
how we can make sure the ECOA is tested.
With that, I yield back.
Chairman Green. The gentleman's time has expired. And the
witness may respond in writing to the gentleman's question.
The Chair will now recognize Ms. Adams, the gentlelady from
North Carolina.
Ms. Adams. Thank you, Mr. Chairman.
And thank you to our witnesses for your testimony today.
Mr. Darity and Mr. Perry, you have both have done extensive
research and writing on economic and racial inequity in the
United States. In today's hearing, we focus primarily on how
lending discrimination harms individual borrowers of color, but
I am curious to hear your thoughts on how the same dynamics,
primarily racism, also impact institutions of color, such as
Historically Black Colleges and Universities (HBCUs).
In December of 2019, a study in the Journal of Financial
Economics found that HBCUs pay higher underwriting fees to
issue tax-exempt bonds compared with similar non-HBCUs,
apparently reflecting higher costs of finding willing buyers.
The effect is 3 times larger in the Deep South, where racial
animus remains the most severe.
For example, identical fee differences are observed between
HBCUs and non-HBCUs with triple-A ratings or when insured by
the same company, even before the 2007-2009 financial crisis.
HBCU-issued bonds are also more expensive to trade in secondary
markets and, when they do, sit in inventory longer.
So are you familiar with this type of institutional lending
discrimination? And what policy steps can we take to collect
more data on the prevalence of this issue and ultimately to
eradicate this type of harmful discrimination in lending for
institutions that have been historically underserved and
undervalued?
Mr. Darity. It is my impression that this is a serious
problem, but I think it is compounded or generated by the fact
that Historically Black Colleges and Universities have such low
endowment levels that they are then pressured to go into the
credit market, a discriminatory credit market, to gain
resources.
Another way to think about improving their circumstances is
something that I think is applicable to individual households
as well, which is, we need to build the wealth position of
those institutions in such a way that they don't have the same
type of pressure to seek predatory lending options to try to
maintain their operations.
And we should think about how we could go about building
the endowments of Historically Black Colleges and Universities
so that they are comparable to the endowment levels that exist
for White institutions in the United States. That is where we
have a very glaring and dramatic difference.
In addition, of course, I think that we do have to confront
these kinds of discriminatory practices. And it may be
necessary for the Federal Government to take the step of
providing public banking services in competition with the
private sector to offset the types of behavior that we are
observing that the private sector is undertaking.
And one final comment in this context. I said that this
parallels the conditions that we observe for households,
because the reason why households are pushed into trying to
seek high levels of credit under very, very difficult
circumstances, discriminatory circumstances, is, again, because
their initial levels of wealth are so low. So, again, I would
say, we have to think about asset building in addition to
trying to improve credit market conditions.
Ms. Adams. Thank you, sir.
Mr. Perry, did you want to comment?
Mr. Perry. I think Mr. Darity said everything I was going
to say. In a nutshell, I think Black institutions are treated
like Black people. And you have school boards and universities
that, because of their wealth position, have to take
essentially subprime market products, for all of the reasons
that Mr. Darity indicated.
But I will just leave it there.
Ms. Adams. Okay. Thank you, sir.
Let me move on quickly. Ms. Rice, Ms. Espinoza, just how
pervasive is lending discrimination in the United States? Is it
widescale, or is it just a small problem?
Ms. Rice?
Ms. Rice. Sure. I am happy to answer that.
Yes, it is very widescale, especially when you consider,
Congresswoman Adams, that almost all of the technologies that
we use in the lending space--automated underwriting systems,
risk-based pricing systems and credit scoring systems--
discriminate against consumers of color and other underserved
groups.
So the discrimination is very prevalent, which is why we
have to really work to de-bias all of these technologies that
we are using in the housing and financial services space.
Ms. Adams. Okay. Is the answer--
Chairman Green. The gentlelady's time has expired.
Ms. Adams. Okay. Thank you very much, and, Mr. Chairman, I
yield back.
Chairman Green. The gentlelady's question can be answered
in writing.
Ms. Adams. Great. Thank you.
Chairman Green. The gentleman from Georgia, Mr. Loudermilk,
is now recognized for 5 minutes.
Mr. Loudermilk. Thank you, Mr. Chairman.
As I was preparing for this hearing, I was trying to think
of ways that we as policymakers can help the minority
communities have more access to financial services and wealth
building. One thing that immediately came to mind, which is
something that I have been working on for a long time, is
fintech.
In recent years, developments in the financial technology
arena have made enormous strides toward giving minority
consumers access to the banking system. Let me just go through
a few of these.
The first is mobile banking. It makes it easier than ever
to open a checking account without having to go into a bank
branch.
The second is online lending. It uses fintech platforms and
even incorporates artificial intelligence in underwriting and
has expanded access to credit to millions of consumers who were
credit-invisible and didn't qualify for a traditional bank
loan.
Prepaid cards are another. They have enabled consumers who
do not have credit or debit cards to access e-commerce.
And the list goes on and on.
And it is not just in consumer finance. A recent study by
New York University showed that fintech companies are by far
the number-one source of Paycheck Protection Program (PPP)
loans for Black-owned small businesses, exceeding Minority
Depository Institutions (MDIs) and Community Development
Financial Institutions (CDFIs). Fintechs have also been the
number-one source of PPP lending to Hispanic-owned businesses.
As a result of this, I offered an amendment at this
committee's markup of the stimulus bill that would allow
fintech companies to participate in the State Small Business
Credit Initiative (SSBCI). Unfortunately, it was rejected by
the Majority. I would just say, if my colleagues are interested
in improving access to financial services for minority
consumers, I would suggest embracing fintech instead of
opposing it.
Ms. Cooper, in your testimony, you said that new technology
can provide more affordable financial products to consumers.
Can you discuss how fintech has expanded access to credit for
minority consumers?
Ms. Cooper. Thank you so much for that question,
Congressman.
So, yes, as you just stated, I think new technology could
potentially provide more affordable financial products to
underserved communities, but it also could introduce consumer
protection risks as well.
And this is similar to what you were saying. One example of
this, for example, would be internet-based or mobile financial
products, which, for example, could lower the cost to provide
payment services or other types of products, but these types of
products could have, for example, cybersecurity or privacy
risks as well.
So, I think there is always a trade-off there when you are
thinking about this stuff.
Mr. Loudermilk. Thank you for that, and I appreciate it.
On another note, because of these developments and what you
have laid out, data security and data privacy laws, I think,
need to be updated, and we need a uniform national standard. Do
you have any thoughts on that?
Ms. Cooper. No. In general, I would say that CRS does not
advocate for any particular policy outcome. And I personally am
not the one at CRS who covers those issues, but I would be
happy to put you in touch with the CRS analyst who does, to
work with you and your staffers.
Mr. Loudermilk. I appreciate that.
And as we continue to hopefully promote fintech, since it
is very beneficial in underserved areas of our nation and
underserved demographics, we do have to address some
limitations, which could be the data security, because we are
looking at more than 50 different standards with which we have
to deal.
So, I appreciate the time here, Mr. Chairman, and I yield
back.
Chairman Green. The gentleman yields back.
The Chair now recognizes the gentlelady from Michigan, Ms.
Tlaib, for 5 minutes.
Ms. Tlaib. Thank you, Mr. Chairman.
And thank you all so much for being with us.
As we all know, despite decades of civil rights laws on the
books, Black homeownership is plunging across the nation, with
the worst losses happening right here in Michigan. Detroit has
seen a dramatic shift from a city of homeowners where Black
family members could build intergenerational wealth to, now, a
city of renters. And the predatory lenders on Wall Street who
crashed the economy in 2007-2008, as we know, got bailed out,
while many of my residents got foreclosed on by the thousands.
Redlining never ended in Detroit. In 2019, in a city of
more than 650,000 people, there were only 1,535 mortgages
issued. And that is up from 2012, when we only had 244
mortgages that were reported. When mortgages are issued in
Detroit, they go towards those who are White borrowers, who are
a small minority of the population.
And so, unwillingness of banks to lend in Detroit and other
majority-Black communities pushes our residents into riskier
arrangements, like land contracts, which offer opportunities
but also fewer protections and have been abused by predatory
sellers.
Ms. Rice, we know banks aren't drawing red lines on a map
anymore but that discrimination still persists. Can you
describe some of the tactics and technology that lenders use
now to perpetuate racial redlining?
Ms. Rice. Sure. Thank you so much for that question, and it
is a critically important issue.
I am from Toledo, Ohio, and so I am very familiar with the
Detroit market and other markets like it. One major problem
that we have in cities like Detroit is that a lot of the
housing stock is very affordable and is priced under $100,000.
And, for a variety of reasons, it is extremely difficult in
today's marketplace for consumers to access mortgage credit in
the financial mainstream when you are trying to get what we
call a smaller-dollar loan.
The qualified mortgage rule, coupled with the LLPAs from
the GSEs, coupled with other Federal policies, really restrict
credit access for more affordable loans. So, that is a major
problem.
The other problem is the industry's overreliance on credit
scores. Back when I was underwriting mortgages years ago, two
of the key things that I relied on to determine a borrower's
creditworthiness were: What are your current housing payments?
Have you been paying your rent on time? And if you have been
paying your current housing bill on time, you are a very good
candidate. And, also, what is your housing payment shock? So,
is the new mortgage that you are going to be paying appreciably
different from the housing payment that you have been used to
making? And if you have been paying your rent on time, and if
there is really no housing payment shock, you are a very good
candidate for getting credit.
But we don't use those two indicators anymore. Today, we
overrely on algorithmic-based systems, like credit scores,
automated underwriting systems, that don't include those kind
of indicators.
And you heard one of the other panelists already testify
that consumers of color are disproportionately credit
invisible. So, just the systems that we have in place in order
to give people an entrance into the financial mainstream are
blocking folks out because those systems do not work for
underserved communities.
Ms. Tlaib. Thank you, Ms. Rice.
I am not sure how much time I have, but I just want folks
on the panel and just the public to notice that none of this
discrimination that we are talking about today is explicitly
spelled out in some sort of company handbook, but it is all
implicit and cloaked in, like, proxies and codewords and
misguided assumptions. And its effect, regardless of the
intent, is to disproportionately deny homeownership
opportunities to Black and Brown folks.
We have the tools to fight it. Just last year, though,
unfortunately, President Trump struck a huge blow to fair-
housing protection with this disparate impact final rule which
failed to comply with the Supreme Court's Inclusive Communities
decision. And we need to address that, Mr. Chairman.
We also know that, as recently as 2015, the Supreme Court
recognized the continuing availability of disparate impact
litigation on the Fair Housing Act. We need to restore these
protections. They are getting watered down by conservative
courts and decisions. And so, I just hope our subcommittee can
proceed and be very intentional about addressing this
discrimination that leaves a lot of my residents out of
opportunities for economic stability.
Thank you, and I yield back.
Chairman Green. The gentlelady's time has expired.
We will now hear from Mr. Mooney from West Virginia for 5
minutes, and then, we will take our break. So if you are after
Mr. Mooney, you might want to go cast your vote now. And we
will cast our second vote as well. That is two votes before we
return.
So, please, now, Mr. Mooney, you are now recognized for 5
minutes.
Mr. Mooney. Thank you, Mr. Chairman.
My concerns are going to address access to rural banking,
generally speaking. And I am going to direct a question to Ms.
Cooper. But I want to highlight some of the concerns related to
getting my constituents in rural West Virginia, and others,
access to loans, credit, and banking, any and all banking
services in general.
According to a survey by the FDIC, 7.8 percent of West
Virginia households are unbanked. This puts West Virginia in
the bottom 10 in the nation in terms of unbanked households.
Ms. Cooper, what can we do to help rural Americans get
access to credit and basic financial services?
And just as a quick follow-up to that, after you answer
that one, how do you feel the COVID-19 pandemic has affected
efforts to reach the unbanked?
Ms. Cooper. Thank you so much for your questions,
Congressman.
So, yes, in general, I know we have already spoken about
this, and in my oral and written statements I have mentioned,
kind of, the geographic disparity, the fact that research
suggests consumers living in rural areas may be living farther
from bank branches, and are less likely to have access to high-
speed internet, and these reasons might make it more difficult
for them to access quality banking services.
In general, in my written testimony, I talk about some
policy options that are often discussed in this space just
generally to increase access to credit to consumers.
And there are five broad types of policy approaches in this
space: first, possible changes to bank regulation to further
encourage banks to serve underserved communities; second,
payment system improvements that may make bank products more
attractive; third, financial technologies to potentially
increase access to consumers; fourth, the government directly
providing certain financial products directly to consumers; and
fifth, financial education programs.
And I would say, in terms of all of these policy options,
they all have costs and benefits and potential unintended
impacts and risks, but they are all things that could be
potential places to explore in this space if you are interested
in expanding access to credit.
Thank you so much. And then your second question was around
the COVID-19 pandemic? Is that correct?
Mr. Mooney. That is correct, how you feel that affects
efforts to reach the unbanked?
Ms. Cooper. Yes. Thank you so much for that question.
I am actually not aware of that much data, since the COVID-
19 pandemic is something that has happened in this past year,
and the FDIC's survey that they do regularly was most recently
done in 2019.
But, yes, I think at least at the beginning of the
pandemic, there were a lot of reports of more people accessing
banking services online, given the pandemic. That pattern makes
sense. So, I do think that is an interesting trend in this
space.
Mr. Mooney. Okay.
Thank you, Mr. Chairman. I yield back.
Chairman Green. The gentleman yields back.
At this time, we will stand in recess for the Members to
cast two votes and then return.
[brief recess]
Chairman Green. Thank you, everyone, for your patience,
especially our witnesses. Thank you so much. It is not unusual
for Members to have to rush out and vote, and we try to do it
as expeditiously as possible, because we know that your time is
very valuable
Let me just see if Mr. Garcia of Illinois is present.
Mr. Garcia, are you with us? If so, I will yield 5 minutes
to you for your questions.
We will stand in recess for a bit longer. We are awaiting
the arrival of our ranking member and additional members, so
please be a little bit patient with us. Thank you so much.
[brief recess]
Chairman Green. Friends, just to give you a quick update,
we are not waiting on Mr. Garcia, so that you won't think that
we are. We are waiting on our ranking member, Mr. Barr. I
assume that he will be arriving shortly, so please continue to
be patient with us while we await his arrival.
Mr. Garcia of Illinois. And Mr. Garcia is on standby, Mr.
Chairman.
Chairman Green. Yes, sir. I have noted that you are here.
As soon as Mr. Barr arrives, we will come right to you. Thank
you so much, Mr. Garcia.
Friends, if I may have your attention, please, the hearing
will now return to order.
We will continue with questions. And next in order for
questions will be Mr. Garcia of Illinois. Mr. Garcia, you are
recognized for 5 minutes to ask your questions.
Mr. Garcia of Illinois. Thank you so much, Mr. Chairman,
for convening this important meeting.
When we talk about wealth in this country and opportunities
to build wealth, we have to talk about housing. So when I think
about the wealth gap, I think about neighborhoods like mine. I
represent a working class, mostly Latino community in Chicago.
I have lived here for more than 50 years. Most of my
constituents are renters, and the housing crisis they are
facing now under COVID-19 isn't new.
My neighbors are squeezed. On the one hand, our community
can't get the investment they need. On the other hand, working-
class Latino and Black people are being pushed out of their own
neighborhoods by wealthier White residents who do have access
to capital. So, I am glad to talk with you today to learn more
about what is driving that and what we can do to support
working-class communities and communities of color especially.
I thank all of the witnesses for being here.
I would like to ask Ms. Espinoza a question on bank
mergers. This country had 12,000 banks in 1990, and now it has
fewer than 5,000. The Fed and the Department of Justice rubber-
stamped bank merger applications without a second thought, even
though mergers can often close down local bank branches and
leave communities underserved.
Do you find that consolidation in the banking industry has
a negative impact on marginalized communities, and does it hurt
access to credit in communities like mine?
Ms. Espinoza. It does hurt access to credit, and one of the
things that we have seen here with the bank mergers is that the
Community Reinvestment Act (CRA) requirements don't change when
banks merge. Instead of them having to do twice the amount, for
example, by merging, they are actually having to do less under
the CRA. So, it is definitely hurting people, and it hurts
people of color because as they merge, they seem to close down
branches in minority neighborhoods that are predominantly
African American and Latino.
Mr. Garcia of Illinois. Okay. Thank you.
Mr. Perry, in your testimony, you mentioned recent high-
profile instances of the appraisal gap, that is, when a
family's home is appraised at a low value because of racial
discrimination. This is a huge problem in my City of Chicago.
Could you talk a little bit more about how the appraisal
gap hurts communities that have always had a hard time getting
loans, and what can Congress and housing advocates do to get
help?
Mr. Perry. Yes, that is a difficult one, because Congress
does not authorize appraisals. However, there are some key
areas that we know are at fault. We know that the price
comparison model in which homes are compared to other homes in
similar neighborhoods essentially recycles racism, because if
you are essentially measuring homes against other homes that
have been impacted by discrimination, you really never get a
sense of values.
The other area that is clear that home improvements are not
treated the same in Black and Brown communities as they are in
White communities, and we see that time and time again.
And there is one other area, and this is the area--the
Dodd-Frank Act created an arm's-length relationship between
appraisers and lenders, and it seems that in some communities,
it is very strict, where lenders and appraisers don't talk at
all, and it results in loans falling through, where in White
communities, there seems to be enough communication to come to
an agreed-upon price. And so those are the three areas where I
see of some of the biggest problems.
Mr. Garcia of Illinois. Thank you very much.
Mr. Chairman, I don't have any more questions at this time.
I have to go vote.
Chairman Green. The gentleman yields back. Thank you, Mr.
Garcia.
The Chair now recognizes the vice ranking member, Mr.
Timmons from South Carolina, for 5 minutes.
Mr. Timmons. Thank you, Mr. Chairman.
Ms. Cooper, since the 1990s, the median wealth among
minority families has plateaued, while it has increased roughly
50 percent for White families. This is a huge problem, as White
families on average now have 41 times the wealth of Black
families and 22 times the wealth of Latino families. I think we
can all agree that that is a major problem.
A friend of mine, who is Black, explained it to me in a way
that really stuck with me. He said, imagine a game of monopoly.
Certain families have been playing for generations. They have
been passing go, collecting $200. They have been purchasing
property, building houses, building hotels, buying the
railroads, and certain families have started much later. And it
is challenging to play the game, it is challenging to compete,
it is challenging to have a chance when you are faced with
those kind of odds.
So, a racial wealth gap has always been an issue. But why
has it gotten worse over the last few decades, and does it have
anything to do with lending practices of financial
institutions?
Ms. Cooper. Thanks for that question. As I was saying in my
oral testimony, as you were describing, research suggests that
disparities in family wealth or in community relationships with
financial institutions can potentially persist across
generations. For example, from parents to children, influencing
children's financial outcomes, so, for example, children's
credit history or homeownership status. And in this way, past
discrimination can cause intergenerational effects, and as I
described, these disparities exist in terms of access to
financial products.
I will say in general, I am not aware of research around
increases or decreases in some of these disparities. Over time,
a lot of this research, particularly around intergenerational
effects, is relatively new. But I would be happy to do some
more research on that question and get back to you.
Mr. Timmons. Thank you.
Mr. Darity. I would like to comment on this, if I may, to
say that the widening gap that we have observed is in part
attributable to the adverse effects of the Great Recession, but
more significantly is due to the cumulative nature of wealth
accumulation and decumulation across generations. That is to
say, wealth begets wealth and lack of wealth begets lack of
wealth.
And so communities that have been subjected to denial and
deprivation have less of an opportunity to transfer resources
across generations and, therefore, we observe a widening gap
over the course of time. It is a fact that is associated with
the very way in which people acquire additional assets.
Mr. Timmons. Sure. And, Mr. Darity, let me follow up on
that. I appreciate you jumping in.
Mr. Darity. Yes.
Mr. Timmons. Would you agree that it is a worthy endeavor
to try to find ways to give people opportunities, who have not
had opportunities in the past, without necessarily putting
people who do not fall into that category at a disadvantage?
I am in the military. I am in the South Carolina Air
National Guard, and we talk a lot about these issues, and the
question becomes, not everyone is in the same box, and if you
are going to try to give people opportunities who have not had
opportunities in the past, that is a worthy endeavor, and I
actually support that. My concern is that there are people who
would be lumped in with the people who theoretically have had
opportunities, who really haven't had opportunities.
So while we look at these statistics, and I agree they are
actually quite terrible and we need to take steps, the question
is, if someone is not necessarily in the bucket of, wealth
begets wealth, they are struggling just like anyone else, how
do we not disadvantage that person? Does that question make
sense to you, sir?
Mr. Darity. It makes sense to me, but I think that we have
to recognize that those differences in opportunity historically
have been racialized to the point that Whites who are in the
bottom 20 percent of the income distribution have a higher
median level of wealth than all Black Americans taken together.
And so, I would argue that there is a racial differential that
needs to be addressed.
Mr. Timmons. And I will do everything I can to help address
that, because I do agree with you, in large part.
And I guess my next question is, would you segment out--
Chairman Green. The gentleman's time has expired. Excuse
me. I'm sorry.
Mr. Timmons. Oh, I will yield back, Mr. Chairman. Thank
you.
Chairman Green. Okay. Because we are trying to end before
this next vote. The gentleman's time has expired.
And we will move on now to Ms. Garcia of Texas. You are now
recognized for 5 minutes.
Ms. Garcia of Texas. Thank you, Mr. Chairman, and thank you
so much for hosting this hearing.
And thank you to all of the witnesses. And most of all,
thank you for your patience as we struggle through these votes.
I want to start with Ms. Rice. Ms. Rice, the Center for
Investigative Reporting report revealed that out of 31 million
Home Mortgage Disclosure Act records, that modern-day redlining
still exists in 61 metro areas in our country. As compared to
White borrowers, lenders denied African-American borrowers in
significantly higher rates in 48 cities, Latinos in 25 cities,
Asian Americans in 9 cities, and Native Americans in 3 cities.
Still, 98 percent of the banks nationally received a
passing grade in the Community Reinvestment Act examination.
What is wrong here? Do you think that we need to redo how we
grade for the Community Reinvestment Act, and would moving from
a pass/fail system to a more transparent letter grade be
better?
Ms. Rice. Thank you so much, Congresswoman Garcia, for that
question. One of the challenges that we face with the Community
Reinvestment Act and the CRA examinations is that it is not
automatically a given that if there are fair-lending violations
at a financial institution, that it will translate into a lower
score for the financial institution.
And so, oftentimes, fair-lending violations are not even
considered in terms of being reflected in the ultimate score
for the financial institution. And that is why you have seen,
since 1977, when the Community Reinvestment Act was enacted,
multiple examples over and over again of financial institutions
who have been found to violate the Fair Housing Act, they have
been found to have engaged in discrimination, and received an
outstanding CRA grade.
Part of that is because CRA is tied to income. The
Community Reinvestment Act says that lenders are supposed to be
meeting the credit needs of their entire delineated community,
including low-income areas. And it just depends on the guidance
at the regulatory agencies at the particular time, but for some
reason, the part that says that the banks are supposed to meet
the credit needs of their entire community--somehow,
communities of color don't get picked up in that definition.
Ms. Garcia of Texas. Should we look at other punishment, if
you will? Should we look at criminal sanctions for intentional
discrimination by the landlords, the builders, the mortgage
companies?
Ms. Rice. We can certainly look at that, whether or not
there should be criminal violations. But I think one of the
first steps that should be taken is we should add race as a
consideration explicitly in the Community Reinvestment Act, so
it makes it clear that lenders cannot redline communities of
color, they cannot avoid serving communities of color in order
to get the higher grades in the CRA designations.
And also, lenders should be required to include communities
of color in their service area. In other words, you shouldn't
be able to carve out neighborhoods of color when you are
designating what is your service area.
Ms. Garcia of Texas. Okay. But as my colleague, Ms. Tlaib,
mentioned, nobody goes around and says, ``Okay neighborhood A,
you are being redlined.'' It is a lot more subtle. And with
algorithms and the technology that is being used now, it is
hard to find, and it is hard to find the appropriate
enforcement tool. But thank you for that.
And I wanted to ask quickly, Ms. Espinoza, because I know I
am running out of time, you mentioned the three different kinds
of testing that you all do and look at. I think you said there
was rental testing, self testing, and mortgage testing. How
complicated is that, and about how much money do you all need
for more testing so that we can more easily prove some of these
cases?
Ms. Espinoza. Well--
Chairman Green. If I may, Ms. Espinoza, the gentlelady's
time has expired, and we are trying to get back for the next
vote.
Ms. Espinoza. Oh, okay. I can address that in writing.
Ms. Garcia of Texas. Thank you, Ms. Espinoza.
I yield back, Mr. Chairman. I apologize.
Chairman Green. That is quite all right. We are trying to
get to everybody.
We will now go to Ms. Williams from Georgia for 5 minutes.
And my apologies to everyone, but we do want to finish before
the next vote.
Ms. Williams of Georgia. Thank you, Chairman Green, and
thank you for convening this hearing today.
In my district and across the country, we see racial wealth
disparities brought on by barriers like invidious
discrimination. In 2019, the median wealth in Black households
was about $24,000, compared to $188,000 for White households,
with the gaps sure to continue to widen because of the
disproportionate impact of COVID-19.
I have an obligation in Congress to work to break down
these barriers and ensure communities of color have a fair
chance to buy homes, start their own businesses, and even send
their kids to college without taking on the massive debt that I
have had to incur. When fewer of us face barriers to building
wealth and long-term prosperity, the better off our economy,
our communities, and our people will be.
Professor Darity, student debt certainly stands in the way
of closing the racial wealth gap, but in your testimony, you
mention that there are some limitations to focusing exclusively
on debt reduction. What are some next steps that we should
consider from an asset-building perspective to lessen the
financial burden of things like going to college for
communities of color?
Mr. Darity. Historically, the United States has practiced
asset-building policies. Representative of these are the 19th
Century policies that involved land allocation. In the 20th
Century, the policies were focused primarily on supporting
homeownership.
I would argue, though, that since the 1960s, the entire
emphasis of Federal policy has been on income supports rather
than wealth building or asset building. And so, if we are
really concerned about improving opportunities for all
Americans to engage in the widest range of opportunities, there
needs to be a shift back towards asset-building opportunities.
And I would think that if we are thinking about individuals
having an opportunity to go to college and to leave college on
a debt-free basis, either we have to eliminate the expense of
attending college altogether, as some people have advocated
zero tuition for attending State universities. I think that is
an idea that should be explored.
But on the other hand, I think that we tend to think about
education as driving wealth, but we really should think about
wealth as driving educational achievement. So, if we could
alter the foundation for assets that are held by a large number
of wealth-poor families in the United States, we would create
greater opportunities for their kids to go further in school
and not have to do so on the basis of the acquisition of
extraordinary levels of indebtedness.
Mr. Perry. And, Representative Williams, I just wanted to
add that there are a number of innovative products going on
right now which are enabling people to get a mortgage and
cancel a student loan debt at the same time, and I think those
are the kind of products we need to see in communities.
Ms. Williams of Georgia. Thank you so much.
And, Professor Darity, I appreciate that.
Ms. Rice, I do have a quick question for you. As we have
heard today, we must break down the discriminatory barriers to
things like owning a home if we really want to close the racial
wealth gap. In your testimony, you offered some suggestions to
increase diversity in the real estate industry. Do you have any
additional recommendations for increasing diversity in other
parts of the financial services industry that impact how
communities of color access housing?
Ms. Rice. Yes, absolutely. One of the first things we have
to do is break down barriers to credit access and the
overreliance on things like credit scores. Credit scores are a
major factor that preclude people of color from being able to
access financial services. People of color disproportionately
live in credit deserts. They also disproportionately live in
communities where there is a hyper concentration of
nontraditional financial services providers who do not report
positive behavior to the credit repositories.
So, that is a huge thing that we need to break down, and we
can actually use new artificially intelligent tools in order to
do that. But we do need more support from regulators and
Congress in order to onboard those new debiasing, tech
debiasing methodologies so that we can expand opportunities for
people.
Ms. Williams of Georgia. Thank you.
Ms. Cooper. And I will just--
Ms. Williams of Georgia. We are out of time, because we
only get 5 minutes, but I appreciate everyone being here today.
And I look forward to working with everyone on the subcommittee
as we continue to address these disparities.
Thank you, Mr. Chairman. I yield back the balance of my
time.
Chairman Green. And thank you very much for being a little
bit conscious of the time. I greatly appreciate it.
Let me move expeditiously and yield myself 5 minutes, so
that we may quickly get to the next vote.
I was here in 2008 when we had the downturn in the economy,
and one of the questions that we asked quite consistently was,
would anyone go to jail for the predatory lending that took
place? The answer to the question is, yes, someone did: one
person. One person went to jail for that long line of predatory
lending that took place. In fact, we had one CEO of a major
bank who settled out of court with the Justice Department, and
the bank's board of directors gave this CEO a 74 percent raise
in salary, amounting to about $20 million.
So, the question becomes this: Do we want to continue to
allow persons who make loan applications to be punished
criminally for falsifying information on a loan application
while the loan originator does not face any charges if the loan
originator denies a person credit? That is predatory lending,
by the way. If you intentionally deny a person credit who is
qualified for that credit, you are engaging in predatory
lending, which is a crime.
But the question becomes, how do we deal with it? And
testing is the means by which we can acquire the empirical
evidence necessary to prosecute these crimes.
Let me start with you, Ms. Rice. Would you give me some
indication as to how efficacious testing is, in your opinion,
with reference to bringing forth the empirical evidence
necessary to prosecute?
Ms. Rice. Testing is extremely efficacious for that
purpose. And thank you so much, Congressman Green, for that
question. The Supreme Court actually has stated that testing is
one of the most verifiable and efficient ways of ferreting out
discrimination.
Part of the challenge though, is that we don't have
sufficient funding to support testing in the United States, and
it is private fair housing organizations who engage in testing
in a consistent fashion, as you have heard Frances Espinoza
already testify to. But the challenge is that, some years we
have very, very little funding to support testing and in some
years we have more funding, but we never have sufficient
funding.
The other thing that--
Chairman Green. Let me intercede for just a quick second. I
am familiar with the Fair Housing Initiatives Program (FHIP)
and the Fair Housing Assistance Program (FHAP). Here is
something that is important. In H.R. 166, we provide for, in
the Consumer Financial Protection Bureau (CFPB), an entity to
conduct these tests. We want to formalize it to a greater
degree.
I still support FHIP and FHAP. That is a great program, so
I am going to support it. But what I would like to know is, if
we put this together with the CFPB, does that give you some
greater degree of belief that we can police and deter those who
would intentionally deny people loans? Ms. Rice?
Ms. Rice. Yes, I do. And we vehemently support the bill
that you referenced, the Fair Lending for All Act. It
definitely will, and it is important for Congress to include
protections, guardrails, so that the testing program can be
ongoing no matter who is in control or who is at the helm of
the organization.
Chairman Green. Let me move quickly to Ms. Espinoza. Ms.
Espinoza, would you agree that testing is an efficacious
methodology, and would you support H.R. 166 as we propose
having testing take place through the CFPB?
Ms. Espinoza. Yes. Testing is the best way to uncover these
predatory practices in fair housing investigations, so I do
support--
Chairman Green. Okay. And let me ask Mr. Perry, would you
agree as well?
Mr. Perry. Yes. And, in fact, journalists and individuals
are doing it.
Chairman Green. I hate to do this to you, but I am going to
have to accept your yes, because I am running out of time.
Mr. Perry. Yes.
Chairman Green. And I can't be unfair to others by giving
myself more time.
Just let me say, Professor, I am very much familiar with
Andrew Johnson and what happened, especially as it relates to
him in 1868 when there was an effort to impeach him. I would
add that he was the bigot of his time, and he denied the newly
free persons the opportunity to start to amass wealth with the
land that would have been accorded them. I can only say this, I
don't pretend to say that this is the silver bullet, but this
will at least help us with some of the credit issues. I do
agree with you that the wealth issue is something that is
paramount for us.
With that said, my time has expired, friends. I do
appreciate all of the witnesses for being here today. Your
being here and being patient with us has meant a lot to us. I
regret that we had to intercede with votes, but these things
happen, and we now have another vote that we have to deal with.
So thank you, all of you.
The hearing is now adjourned, after I read a statement,
excuse me. There is a statement that I have to read before we
can adjourn this hearing, so please be patient as I move to the
statement.
I thank the witnesses for their testimony and for devoting
their time and resources to share their expertise with this
subcommittee. Their testimony today will help to advance the
important work of this subcommittee and of Congress in
addressing lending discrimination and systemic racial
inequality.
The Chair notes that some Members may have additional
questions for this panel, which they may wish to submit in
writing. Without objection, the hearing record will remain open
for 5 legislative days for Members to submit written questions
to these witnesses and to place their responses in the record.
Also, without objection, Members will have 5 legislative days
to submit extraneous materials to the Chair for inclusion in
the record.
This hearing is now adjourned. Thank you so much.
[Whereupon, at 5:23 p.m., the hearing was adjourned.]
A P P E N D I X
February 24, 2021
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