evaluating the dodd frank act

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DODD FRANK Housing and the Economy APRIL 24, 2017

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Page 1: Evaluating the Dodd Frank Act

DODD FRANK Housing and the Economy

APRIL 24, 2017

Page 2: Evaluating the Dodd Frank Act

Repealing Dodd Frank

1

Repealing the Dodd Frank Act

Pub.L. 111–203, H.R. 4173, 2010.

The Law of Diminished Returns

The Dodd Frank legislation is damaging to the housing market, mortgage industry and

the U.S. economy. Prior to the Great Recession of 2008, home ownership peaked between (2003

and 2005) and has declined at rapid pace since. 1 Comparatively speaking, data from the U.S.

Censuses bureau also showed significant decreases in the levels of home ownership and

increased rental housing costs.2 At the time, despite the modest two percent increases in Gross

Domestic Product (GDP), economic growth did not sustain itself, growth was a result of the

financial stabilization package (TARP). 3 The economy grew at lackluster pace ever since.

Historically, it is noted as one of the worst economic recoveries since the great depression. 4

In 2006, subprime mortgage lending accounted for 23 percent of all mortgages. 5 Credit

industry data show that beginning year 2015 credit applications denials where worse than 2008

recessionary periods. 6 The National Association of Credit Managers reported (NACM) reported

the biggest spike in credit application denials ever recorded post-recession. 7

1 “US Middle Class Stays Dead: Homeownership Drops to 48 Year Low; Median Asking Rent Soars to All Time

High,” July 28, 2015, accessed February 25, 2017, http://www.zerohedge.com/news/2015-07-28/us-

homeownership-drops-48-year-low-median-asking-rent-rises-new-record-high. 2 SEE: https://www.census.gov/housing/hvs/files/qtr215/currenthvspress.pdf

3 Bureau of Labor Statistics, Center on Labor and Policy Priorities 4 Peter, J, Wallison. “Is the Dodd-Frank Act Responsible for the Economy’s Slow Recovery from the Financial

Crisis and the Ensuing Recession?” 2015. Retrieved from: https://www.hillsdale.edu/wp-

content/uploads/2016/02/FMF-2015-Dodd-Frank.pdf

5 Financial Crisis Inquiry Commission Report 2011. Retrieved from https://www.gpo.gov/fdsys/pkg/GPO-

FCIC/pdf/GPO-FCIC.pdf (70). 6 Aexander, Giyravets. “Recessionary Levels in Credit Conditions,” 2015. Retrieved from:

http://www.zerohedge.com/sites/default/files/images/user5/imageroot/2015/04/DynamikaCommentary20150331.pdf

7 “There are big, big problems’ - the Shocker Crushing the Economy Revealed,” April 13, 2015, accessed February

25, 2017, http://www.zerohedge.com/news/2015-04-13/unseen-recession-shocker-crushing-economy-revealed-

credit-rejections-soar-most-ever.

Page 3: Evaluating the Dodd Frank Act

Repealing Dodd Frank

2

The Center for American Progress (CAP) cited,

“Data from the Federal Reserve shows that loan officers

have become stricter in their mortgage lending standards

than at any point since 1991.” Further, “minorities, and low-income families have

disproportionately felt the effects of the credit crunch.” 8 Disparities in mortgage lending are more

most common among low income and minority groups, data shows they are “not mortgage ready

and have high debt to income levels.” 9 Loan denial rates stay high for low income and minor ity

families.10 Federal Reserve Chair Janet Yellen said, “Demand for housing is still being restrained

by limited availability of mortgage loans to many potential homebuyers.” 11 The Brookings

Institute conducted a comprehensive analysis on how the regulatory burden of the legislation is

hurting economic growth citing DF has “decreased economic stability without economic growth.”

12 Further, U.S homeownership rate fell to its lowest level since 1960 to sixty three percent. 13

Hester Peirce and James Broughel described the current regulatory system, “suppresses market

discipline in favor of regulatory expertise and broad regulatory authority.” 14

8 Christine Weller. “Access Denied.” September 2007. Accessed February 25, 2017.

https://www.americanprogress.org/wp-content/uploads/issues/2007/08/pdf/credit_access.pdf.

9 “Housing Advocacy Team,” What is Behind the Lending Disparities? February 24, 2015, accessed February 26,

2017, http://hatdc.org/?p=1920.

10 Weller, (4). 11 Diane Olick. “How Dodd-Frank Changed Housing, for Good and Bad,” Real Estate July 16, 2015,

http://www.cnbc.com/2015/07/16/how-dodd-frank-changed-housing-for-good-and-bad.html.

12 Bailey, Martin, and Aaron Klein. "The Impact of the Dodd-Frank Act on Financial Stability ..." October 2014.

Accessed April 3, 2017. Retrieved from: https://www.brookings.edu/wp-content/uploads/2016/06/Baily-Klein-

PPTF-1.pdf

13 Kathleen Howley. “U.S homeownership Falls to its Lowest Levels Since 1960”. July 28, 2015. Retrieved from

https://www.bloomberg.com/news/articles/2015-07-28/u-s-homeownership-rate-falls-to-lowest-since-the-1960s 14 Peirce, Hester, and James Broughel. Dodd-Frank: What It Does and Why Its Flawed . Arlington, VA: Mercatus

Center at George Mason University, 2012.

“U.S homeownership rate fell to

its lowest level since 1967 to sixty

three percent.” Kathleen Howley

Page 4: Evaluating the Dodd Frank Act

Repealing Dodd Frank

3

Dodd Frank resulted in “36 billion in final rule costs,” and “resulted in a 14.5 percent

decline in revolving consumer credit.” 15

Figure 1.1

Source: National Association of Credit Managers 2015 as cited in Zero Hedge.

Dodd Frank impacts to the economy are yet to be determined. In 2016-2017 “rejections of

credit application remained stable at 51.6 given fewer credit applications. 16 Members of Congress

discussed new DF mortgage lending rules imposed such as the “Qualifying Mortgage Rule,”

(QMR), its effects on people with student loans, low income households, and people with sub-

prime credit scores. 17 Since the passage of DF regulation in the mortgage industry requirements

for QM rules are more stringent than before DF rules, as a result mortgages are more difficult to

qualify for and require more documentation and paperwork.

15 Mathew, Sliver. “The Dodd-Frank Legacy: Billions Spent, More Designated, Questionable Gains .” July 2016. Accessed

April 03, 2017. http://www.mhmarketingsalesmanagement.com/b logs/daily-business-news/tag/dodd-frank-act/. 16 Credit Managers Index, 2017. National Association of Credit Management. Retrieved from:

https://web.nacm.org/CMI/PDF/CMIcurrent.pdf 17 Jeb Hensarling. “Hearing Entitled ‘How prospective and current homeowners will be harmed by the CFPB’s

qualified mortgage Rule.’” February 25, 2017. Accessed February 26, 2017.

http://financialservices.house.gov/calendar/eventsingle.aspx?EventID=366144.

2008, 40.30%

30% Increase

0.00%

20.00%

40.00%

60.00%

80.00%

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Comparision of Credit Rejections Since Great Recession

51.6 (2017)

Page 5: Evaluating the Dodd Frank Act

Repealing Dodd Frank

4

Qualifying Mortgage (Ability to Repay Rule)

Requires 43 percent debt to income ratio

Credit score under 720 requires Private

Mortgage Insurance (PMI)

Down payments of 10%- 20% percent down

More expensive closing cost

More rules and paperwork for mortgage companies

Jay Richards and Tim Lundeen discussed the consequences of Dodd Frank; the policies

enacted from Dodd Frank had the effect of, “hurting the poor, and lowering the middle class into

the ranks of the poor.” 18 In 2010, democrats argued that Dodd Frank was ‘necessary’ to stabilize

the economy and rid risky loan portfolios, stop variable rate mortgages, and no money down home

lending programs. Peter J. Wallison wrote of how the false narrative of the financial crisis led to

Dodd Frank he called it, “The Obamacare of the financial system.” 19 Further, banks have had an

overflow of cash yet lending has decreased. Bank capital reserves grew from $1.9 billion in

August 2008 to $2.6 trillion in January 2015. 20 Home ownership peaked between 2003-2006

after Dodd Frank they are at its lowest rate since 1965. 21 GDP growth lowered post recessionary

periods. 22

18Jay W. Richards. Infiltrated: How to Stop the Insiders and Activists Who Are Exploiting the Financial Crisis to

control Our Lives and Our Fortunes. New York, NY, United States: McGraw-Hill Professional, 2013. (2).

19 Peter, Wallison. Bad history, worse policy: How a false narrative about the financial crisis led to the Dodd-frank .

Place of publication not identified: Aei Press, 2017. 20 Ben R. Craig., Mathew Koepke. Excess Reserves: Oceans of Cash. February12, 2015. Accessed March 19, 2017.

https://www.clevelandfed.org/newsroom-and-events/publications/economic-commentary/2015-economic-

commentaries/ec-201502-excess-reserves-oceans-of-cash.aspx 21 Joy, Blake. "US Census Bureau: Homeownership Rate Falls to Quarter-Century Low." Hinterland Gazette. April

28, 2015. Accessed April 05, 2017. http://hinterlandgazette.com/2015/04/homeownership-rates-fall-lowest-level-

quarter-century.html. 22 "What Role Does Housing and Real Estate Play in the Gross Domestic Product?" American Financial Resources

Blog. November 2012. Accessed April 05, 2017. http://afrmortgage.com/blog/what-role-does-housing-play-in-the-

gdp/#.WOUwYYWcGP8.

“In 2006, real estate comprised

of 8.9% of GDP, in 2011 it

comprised of 5% of GDP.”

Kimberly Amadeo

Page 6: Evaluating the Dodd Frank Act

Repealing Dodd Frank

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Negative effects of Dodd Frank on Real Estate, Lending, and Economy

Reduced Mortgage Lending

Reduced Homeownership Rates

Reduced GDP/Lower Economic Growth

Banks Richer Than Ever

Figure 2 1

Source: U.S Census Bureau cited in Hinterland Gazette

Greater Regulatory Burden

Dodd Frank Act has hurt economic growth and

stifled the housing recovery. Lain Murry from

the Competitive Enterprise Institute wrote that

financial reforms ‘inhibit’ access to the financ ia l

system.23 Murry gathered information that

supports the ancillary role of Dodd Frank, and its

intrusive design to violate financial privacy.

23 Lain Murry. “How Dodd Frank Harms Main Street.” 2015. Accessed February 26, 2017.

https://cei.org/sites/default/files/IainMurrayHowDoddFrankHarmsMainStreet.pdf.

“Large banks can absorb the costs of

burdensome new regulations.” “They have large

compliance departments, and can meet new

challenges by making them even larger.”

“Smaller banks, however, only have a few

compliance staffers.” Lain Murry 2015.

Page 7: Evaluating the Dodd Frank Act

Repealing Dodd Frank

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The law enables the CFPB to create “rulemaking authority,” and enables the government to make

changes and place restrictions on financial products and services. 24

Consumer Financial Protection Bureau and Consumer Credit

The CFPB is a small agency, it is improbable they will monitor the credit bureaus,

complaints about inaccurate credit reporting are the most common. As of February 2017, the

CFPB “handled approximately 185,700 credit reporting complaints.” 25 The credit reporting

system is a flawed system, under the Fair Credit Reporting Act consumers have a right to a

complete and accurate credit report, if the credit reporting is inaccurate credit scores are

suppressed. 26 Credit scoring systems such as FICO is developed by the Fair Isaac Company.

Credit scores are intricately related with data from consumer credit reports. FICO uses consumer

information as ‘triggering events’ to measure credit worthiness; such credit utilization, and how a

person pays bills. Because the CFPB regulates the credit bureaus, it has the discretion to modify

information on credit reports. 27

Andrew Rombach of Lend-Edu found most CFPB complaints are about credit reporting,

73.9% of complaints contained inaccurate information on the credit report. 28 Data is

maintained by the credit agencies, if data is incomplete or inaccurate it compromises integrity of

the credit score model making it more difficult and expensive to purchase a home or car.

24 Murry, (3). 25 CFPB Uncovers and Corrects Credit Reporting Problems. https://www.consumerfinance.gov/about-

us/newsroom/cfpb-oversight-uncovers-and-corrects-credit-reporting-problems/ 26 Ryan Wibberly. It’s Time to Re Visit Our Credit Scoring System.

https://www.forbes.com/sites/ryanwibberley/2015/01/20/its -time-to-revisit-our-credit-scoring-

system/#5dd9c0ec466a 27 CreditInfoCenter® Credit. “CFPB Regulating the Credit Reporting Bureaus.” 2016. Accessed February 26, 2017.

http://www.creditinfocenter.com/consumer-protection/credit-reporting-industry.shtml 28 Andrew, Rombach. CFPB Credit Reporting Complaints – Data & Report.” January 5, 2017. Accessed February

26, 2017. https://lendedu.com/blog/credit-reporting-complaints#3.

Page 8: Evaluating the Dodd Frank Act

Repealing Dodd Frank

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CFPB Deemed Unconstitutional

The Consumer Financial Protection

Bureau function is to oversee, supervise and

examine banks and financial institutions. The

constitutional question of the agencies broad

discretionary power of the director who has the power to impose fines on lending institutions. The

US Court of Appeals heard the case against PHH mortgage and the CFPB fining the company 103

million dollars for accepting insurance kickbacks for mortgage insurance. The administrative case

was argued in the district of Columbia alleging, “No head of either an executive agency or an

independent agency operates unilaterally without any check on his or her authority. Therefore, no

independent agency exercising substantial executive authority has ever been headed by a single

person.” 29 Further, “the Director enjoys more unilateral authority than any other officer in any of

the three branches of the U.S. Government, other than the President, unilaterally enforces 19

federal consumer protection statutes, covering everything from home finance to student loans to

credit cards to banking practices”. 30 The court ruled the CFPB to be structurally unconstitutiona l

and abuses its discretionary powers. PHH urged the court to kill the CFPB entirely alleging the

bureau, “structure cannot be reconciled with the Constitution’s dual promises of democratic

29 PNC Corporation v. CFPB United States Court of Appeals 2016. Retrieved from:

https://www.cadc.uscourts.gov/internet/opinions.nsf/AAC6BFFC4C42614C852580490053C38B/$file/15-1177-

1640101.pdf 30 Ben, Lane. "PHH urges Court of Appeals to kill CFPB." HousingWire.com. March 2017. Accessed April 23,

2017. http://www.housingwire.com/articles/39557-phh-urges-court-of-appeals-to-kill-cfpb.

CFPB DISCLAIMER: THE CFPB

DOES NOT ACT ON BEHALF OF

CONSUMERS AND DOES NOT

ACT AS AN ATTORNEY ON

CONSUMERS BEHALF.

Page 9: Evaluating the Dodd Frank Act

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government and separated powers, and the external check that Congress ordinarily exercises

through the power of the purse.” 31

Change to Credit Reporting

There are three major credit agencies responsible for maintaining consumer data. The Fair

Credit Reporting Act is a law that requires consumer credit agencies report complete and accurate

credit information on millions of U.S borrowers. If credit information is inaccurate, it is very

unlikely the CFPB can assist consumers to correct mistakes, borrowers can complain to the CFPB,

however, the CFPB cannot intervene on behalf of consumers as stated in their disclaimers. The

CFPB enforcement division of banking and finance also has ‘rulemaking authority’. To say the

least, serious challenges exist with this new agency, especially quality control and adequate

consumer protection.

In 2016, Wells Fargo fraudulently opened 2 million accounts fraudulently even though the

CFPB was conducting periodic examinations. 32 Texas congressman Jeb Hansarling called the

CFPB a “rogue agency”. He said, “Even though the CFPB inspected Wells Fargo they didn’t do

anything about it, it came out of the LA city attorney office and the L.A times,” the action was led

by the Los Angeles city attorney Marc Feuer. 33 Other issues related to privacy is the CFPB data

collection program. House representative Shawn Dufey of Wisconsin alleges the CFPB of “data

mining,” he says the agency could be violating the 4th amendment of the constitution. 34 PHH

31 Lane, 2017. 32 “Rep. Jeb Hensarling Calls Consumer Financial Protection Bureau A ‘rogue agency.’” February 24, 2017.

Accessed February 26, 2017. http://www.npr.org/2017/02/24/516983751/rep-jeb-hensarling-calls-consumer-

financial-protection-bureau-a-rogue-agency. 33 “Wells Fargo Allegations Sparked by L.A. Times Story, City Attorney’s Investigation,” September 8, 2016,

accessed February 26, 2017, http://ktla.com/2016/09/08/wells-fargo-allegations-sparked-by-l-a-times-story-city-

attorneys-investigation/. 34 “Examining How the Consumer Financial Protection Bureau Collects and Uses Consumer Data.” Accessed

February 26, 2017, https://www.gpo.gov/fdsys/pkg/CHRG-113hhrg82858/html/CHRG-113hhrg82858.htm.

Page 10: Evaluating the Dodd Frank Act

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mortgage fought against CFPB agency overreach. The U.S court of appeals Judge Bret Kavanaugh

found the CFPB to be “structurally unconstitutional,” the ruling further added, “cannot be headed

by a single director who can be removed only for cause by the president.” 35

HIGH RISK CATAGORIES

CFPB Role in Consumer Credit

High Number of Consumer Complaints on Credit Reporting

CFPB (Rulemaking Authority) questionable?

CFPB- Funds Not Appropriated by Congress

Lack of Accountability and Quality Control

Policy Recommendations

Repealing Dodd Frank is necessary to cut bureaucratic red tape. All regulatory control and

enforcement action should revert to the Office of the Comptroller of the Currency and Federal

Trade Commission. The Fair Credit Reporting Act needs to be amended opposing the seven-year

statutory requirement for reporting accounts in collections, charge offs, or similar status. There are

several bills in congress, this first is HR 1031 to repeal Dodd Frank, 36 the second is the Choice

Act by Rep Hansarling. I support full repeal HR 1031 of the law because the system is more stable

today and the cost of Dodd Frank has had on lending, an intrusive regulatory burden on consumers

and businesses and mortgage lending. Reports of CFPB regulators going after what they deem

’high risk’ industries are arbitrary. Restoring enforcement authority back to the Federal Trade

Commission, compliance and examination processes under authority and jurisdiction of the Office

35 Joseph Lawler, Court Rules Consumer Bureau’s Structure Unconstitutional , (The Washington Examiner),

October 11, 2016, http://www.washingtonexaminer.com/court-rules-consumer-bureaus-structure-

unconstitutional/article/2604229.

36 “Actions - H.R.1031 - 115th Congress (2017-2018): To Eliminate the Bureau of Consumer Financial Protection

by Repealing Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Commonly Known as

the Consumer Financial Protection Act of 2010,” February 14, 2017, accessed February 26, 2017,

https://www.congress.gov/bill/115th-congress/house-bill/1031/all-actions?overview=closed#tabs .

Page 11: Evaluating the Dodd Frank Act

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of the Comptroller for supervision is recommended as a revision to the CFPB ancillary role over

banking and consumer credit. More funding is needed for the comptroller and the FTC to safeguard

enforcement measures to maintain stronger compliance and supervisory powers, not the CFPB.

Works Cited

--- “Actions - H.R.1031 - 115th Congress (2017-2018): Repealing Title X of the Dodd-Frank

Wall Street Reform and Consumer Protection Act, Commonly Known as the Consumer

Financial Protection Act of 2010,” February 14, 2017, accessed February 26, 2017,

https://www.congress.gov/bill/115th-congress/house-bill/1031/all-

actions?overview=closed#tabs.

Blake, Joy. "US Census Bureau: Homeownership Rate Falls to Quarter-Century Low."

Hinterland Gazette. April 28, 2015. Accessed April 05, 2017.

http://hinterlandgazette.com/2015/04/homeownership-rates-fall- lowest- level-quarter-

century.html.

Bureau of Labor Statistics, Center on Labor and Policy Priorities (citation needed)

---CreditInfoCenter® Credit. “CFPB Regulating the Credit Reporting Bureaus.” 2016. Accessed

February 26, 2017. http://www.creditinfocenter.com/consumer-protection/credit-

reporting-industry.shtml

Craig., Ben., & Koepke., Mathew. Excess Reserves: Oceans of Cash. February12, 2015.

Accessed March 19, 2017. https://www.clevelandfed.org/newsroom-and-

events/publications/economic-commentary/2015-economic-commentaries/ec-201502-

excess-reserves-oceans-of-cash.aspx

---CFPB Uncovers and Corrects Credit Reporting Problems.

https://www.consumerfinance.gov/about-us/newsroom/cfpb-oversight-uncovers-and-

corrects-credit-reporting-problems/

---“Examining How the Consumer Financial Protection Bureau Collects and Uses Consumer

Data.” Accessed February 26, 2017, https://www.gpo.gov/fdsys/pkg/CHRG-

113hhrg82858/html/CHRG-113hhrg82858.htm

---Financial Crisis Inquiry Commission Report 2011. Retrieved from (citation needs correction)

https://www.gpo.gov/fdsys/pkg/GPO-FCIC/pdf/GPO-FCIC.pdf

Page 12: Evaluating the Dodd Frank Act

Repealing Dodd Frank

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Giryavets, Alexander. “Recessionary Levels in Credit Conditions” as cited in

http://www.zerohedge.com/sites/default/files/images/user5/imageroot/2015/04/Dynamika

Commentary20150331.pdf

Hensarling, Jeb. Hearing Entitled: “How prospective and current homeowners will be harmed

by the CFPB’s qualified mortgage Rule.” February 25, 2017. Accessed February 26,

2017. http://financialservices.house.gov/calendar/eventsingle.aspx?EventID=366144

---“Hensarling Calls Consumer Financial Protection Bureau A ‘rogue agency.’” February 24,

2017. Accessed February 26, 2017. http://www.npr.org/2017/02/24/516983751/rep-jeb-

hensarling-calls-consumer-financial-protection-bureau-a-rogue-agency.

Hester, Pierce & Broughel, James. Dodd-Frank: What It Does and Why Its Flawed. Arlington,

VA: Mercatus Center at George Mason University, 2012.

---“Housing Advocacy Team,” What is Behind the Lending Disparities? February 24, 2015,

accessed February 26, 2017, http://hatdc.org/?p=1920.

Howley, Kathleen. “U.S homeownership Falls to its Lowest Levels Since 1960”. July 28, 2015.

Retrieved from https://www.bloomberg.com/news/articles/2015-07-28/u-s-

homeownership-rate-falls-to- lowest-since-the-1960s

https://www.census.gov/housing/hvs/files/qtr215/currenthvspress.pdf (citation Needed)

Lane, Ben. "PHH urges Court of Appeals to kill CFPB." HousingWire.com. March 2017.

Accessed April 23, 2017. http://www.housingwire.com/articles/39557-phh-urges-court-

of-appeals-to-kill-cfpb.

Lawler, Joseph. Court Rules Consumer Bureau’s Structure Unconstitutional, (The Washington

Examiner), October 11, 2016, http://www.washingtonexaminer.com/court-rules-

consumer-bureaus-structure-unconstitutional/article/2604229.

Martin, Bailey, & Klein, Aaron. "The Impact of the Dodd-Frank Act on Financial Stability ..." October

2014. Accessed April 3, 2017. Retrieved from: https://www.brookings.edu/wp-

content/uploads/2016/06/Baily-Klein-PPTF-1.pdf

Murry, Lain. “How Dodd Frank Harms Main Street.” 2015. Accessed February 26, 2017.

https://cei.org/sites/default/files/IainMurrayHowDoddFrankHarmsMainStreet.pdf.

Olick, Diane. “How Dodd-Frank Changed Housing, for Good and Bad,” Real Estate July 16,

Page 13: Evaluating the Dodd Frank Act

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2015, http://www.cnbc.com/2015/07/16/how-dodd-frank-changed-housing-forgood-and-

bad.html.

PNC Corporation v. CFPB United States Court of Appeals 2016. Retrieved from:

https://www.cadc.uscourts.gov/internet/opinions.nsf/AAC6BFFC4C42614C8525804900

53C38B/$file/15-1177-1640101.pdf

Richards, Jay. Infiltrated: How to Stop the Insiders and Activists Who Are Exploiting the

Financial Crisis to Control Our Lives and Our Fortunes. New York, NY, United States:

McGraw-Hill Professional, 2013.

Rombach, Andrew. “CFPB Credit Reporting Complaints – Data & Report.” January 5, 2017.

Accessed February 26, 2017. https://lendedu.com/blog/credit-reporting-complaints#3.

Sliver, Mathew. “The Dodd-Frank Legacy: Billions Spent, More Designated, Questionable Gains .” July

2016. Accessed April 03, 2017.

http://www.mhmarketingsalesmanagement.com/blogs/daily-business-news/tag/dodd-

frank-act/

---There are big, big problems’ - The Shocker Crushing the Economy Revealed,” April 13, 2015,

accessed February 25, 2017, http://www.zerohedge.com/news/2015-04-13/unseen-

recession-shocker-crushing-economy-revealed-credit-rejections-soar-most-ever.

---“US Middle Class Stays Dead: Homeownership Drops to 48 Year Low; Median Asking Rent

Soars to All Time High,” July 28, 2015, accessed February 25, 2017,

http://www.zerohedge.com/news/2015-07-28/us-homeownership-drops-48-year- low-

median-asking-rent-rises-new-record-high.

Wallison, Peter. “Is the Dodd-Frank Act Responsible for the Economy’s Slow Recovery from

the Financial Crisis and the Ensuing Recession?” 2015. Retrieved from:

https://www.hillsdale.edu/wp-content/uploads/2016/02/FMF-2015-Dodd-Frank.pdf

Wallison, Peter J. Bad history, worse policy: how a false narrative about the financial crisis led

to the Dodd-frank. Aei Press, 2017.

Weller, Christine. “Access Denied.” September 2007. Accessed February 25, 2017.

https://www.americanprogress.org/wp-content/uploads/issues/2007/08/pdf/credit_access.pdf

---“Wells Fargo Allegations Sparked by L.A. Times Story, City Attorney’s Investigation,”

September 8, 2016, accessed February 26, 2017, http://ktla.com/2016/09/08/wells-fargo-

allegations-sparked-by- l-a-times-story-city-attorneys-investigation/.

Page 14: Evaluating the Dodd Frank Act

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---"What Role Does Housing and Real Estate Play in the Gross Domestic Product?" American

Financial Resources Blog. November 2012. Accessed April 05, 2017.

http://afrmortgage.com/blog/what-role-does-housing-play- in-the-

gdp/#.WOUwYYWcGP8.

Wibberly, Ryan. It’s Time to Re Visit Our Credit Scoring System.

https://www.forbes.com/sites/ryanwibberley/2015/01/20/its-time-to-revisit-our-credit-

scoring-system/#5dd9c0ec466a

.