Subprime and predatory lending are the most controversial and visible topics involving the Community Reinvestment Act and fair lending. If we are to establish good public policy on this matter, it must draw from all three components of the “CRA Triangle” — community groups, regulators, and the industry. There must be a constant give and take, a dynamic tension, among this trio, and no one interest should overpower the others.

Whereas community groups may have traditionally been outgunned by the financial industry, the opposite is the case in the current subprime and predatory lending debate. We have witnessed a nonstop stream of horror stories from predatory-lending victims on the television networks and in the print media.

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