• CRA mandated loans would have defaulted at higher rates;

• Foreclosures in these distressed urban CRA neighborhoods should have far outpaced those in the suburbs; Local lenders making these mortgages should have failed at much higher rates;

• Portfolios of banks participating in the Troubled Asset Relief Program should have been filled with securities made up of toxic CRA loans;

• Investors looking to profit should have been buying up properties financed with defaulted CRA loans;

• and Congressional testimony of financial industry executives after the crisis should have spelled out how the CRA was a direct cause, with compelling evidence backing their claims.


Yet none of these things happened. And they should have, if the CRA was at fault. It’s no surprise that in congressional testimony, various experts were asked about the CRA -- from former Federal Deposit Insurance Corp. Chairman Sheila Bair to the Federal Reserve’s director of Consumer and Community Affairs -- and none blamed the crisis on the CRA.

If that isn’t enough to dismiss the claim, consider this: Where did mortgages, especially subprime mortgages, default in large numbers?

It wasn’t Harlem, Philadelphia, Baltimore, Chicago, Detroit or any other poor, largely minority urban area covered by the CRA. No, the crisis was worst in Florida, Arizona, Nevada and California. Indeed, the vast majority of the housing collapse took place in the suburbs and exurbs, not the inner cities.

Now consider that much of the rest of the developed world also had a boom and bust in residential real estate that was worse than in the U.S. Oh, right -- those countries didn’t have the CRA.

What's more, many of the lenders that made the subprime loans that contributed so much to the collapse were private non-bank lenders that weren’t covered by the CRA. Almost 400 of these went bankrupt soon after housing began to wobble.