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The Subprime VirusReckless Credit, Regulatory Failure, and Next Steps$
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Kathleen C. Engel and Patricia A. McCoy

Print publication date: 2011

Print ISBN-13: 9780195388824

Published to Oxford Scholarship Online: April 2015

DOI: 10.1093/acprof:osobl/9780195388824.001.0001

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Put to the Test

Put to the Test

OCC, OTS, and FDIC Oversight

(p.167) 9 Put to the Test
The Subprime Virus

Kathleen C. Engel

Patricia A. McCoy

Oxford University Press

This chapter discusses oversight by the Office of the Comptroller of the Currency (OCC), Office of Thrift Supervision (OTS), and the Federal Deposit Insurance Corporation (FDIC). In addition to instituting federal preemption and refusing to adopt binding rules that would have mandated safe underwriting practices, the OCC and OTS also failed to take formal enforcement actions against troubled banks and thrifts. The FDIC, however, did not preempt state anti-predatory lending laws for the community banks it regulated. While a few FDIC-regulated banks got into trouble with subprime loans, for the most part FDIC institutions steered clear of those products. Thus, FDIC-regulated banks only had a small role in the unfolding subprime crisis.

Keywords:   subprime lending, financial regulation, banking regulation, Office of Thrift Supervision, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, anti-predatory lending laws, community banks

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