HOEPA was enacted in 1994 in response to Congressional concerns over “reverse redlining.” [PDF] According to the Senate Banking Committee report accompanying the legislation, “reverse redlining” is the practice of targeting residents of specific disadvantaged communities for credit on unfair terms, and in particular by second mortgage lenders, home improvement contractors, and finance companies. These lenders were felt to “peddle high-rate, high-fee home equity loans to cash-poor homeowners.” … [1] American Bar Association analysis, vintage August 2007 I’m working through the Q&A session of AEI’s October 11, 2007 Subprime II seminar, and around 1:34:00 on the tape there’s a fascinating…
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