In his speech before Women in Housing and Finance on Sept. 24, Comptroller of the Currency John Dugan repeated three arguments that have frequently been advanced in recent months by representatives of big financial institutions.

First, he claimed that mortgage brokers and nonbank mortgage lenders were mainly to blame for our current financial crisis. Second, he maintained that national banks did not play a significant role in precipitating the crisis. Third, he contended that federal preemption of state consumer protection laws has provided big benefits to our economy. Dugan is mistaken on all three points.

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