barriers have become more prevalent. administrative protection in the form of antidumping suits and countervailing duties is a case in point. while these forms of protection have often been imposed under the label of promoting “ fair trade, ” oftentimes they are just simple guises for inhibiting competition. typically, antidumping duties are levied when foreign average prices are below average cost of production. but that also describes a practice that often emerges as a wholly appropriate response to a softening in demand. it is the rare case that prices fall below marginal cost, which would be a more relevant standard. antidumping initiatives should be reserved, in the view of many economists, for those cases where anticompetitive behavior is involved. contrary to popular notions about antidumping suits, under u. s. and wto law, it is not required to show evidence of predatory behavior, or intention to monopolize, or of any other intentional efforts to drive competitors out of business. in the end it is clear that all economic progress rests on competition. it would be a great tragedy were we to stop the wheels of progress because of an incapacity to assist the victims of progress. our efforts should be directed at job skills enhancement and retraining – a process in which the private market is already engaged. thwarting competition, by placing barriers to imports, will prevent the needed transitions of the productive capital stock of the united states and other nations that enable it to continuously concentrate on producing those goods and services most desired by consumers. protectionism will also slow the inevitable transition of the workforce to more productive endeavors. to be sure, an added few years may enable some workers to reach retirement with dignity, but it will also keep frozen in place younger workers whose better job opportunities decline with time. i regret that trade policy has been inextricably linked with job creation. we try to promote free trade on the mistaken ground that it will create jobs. the reason should be that it enhances standards of living through the effects of competition on productivity. it is difficult to find credible evidence that trade has impacted the level of total employment in this country over the long run. indeed, we are currently experiencing the widest trade deficit in history with a level of unemployment close to record lows. certainly, the distribution of jobs by industry is affected by international trade, but it is also affected by domestic trade. it is the relative balance of supply and demand in a competitive

more easily identify price disparities that require investigation. if disparities are found to violate the ecoa or fha, certain federal agencies are authorized to compel lenders to cease discriminatory practices and, among other remedies, obtain monetary relief for victims. the public disclosure of price information under hmda - in the form of spreads between the annual percentage rate ( apr ) on a loan and the rate on treasury securities of comparable maturity - is designed to ensure that the data continue to be useful in improving market efficiency and legal compliance. the apr represents the cost of credit to the consumer and captures the contract - based interest rate on a loan as well as the points and fees that consumers pay up front, converted to a percentage rate. but since these fees have to be amortized over the term of the loan to calculate the apr, and since interest rates vary over time, even the apr can be difficult to use as a basis of comparison across loans. because of interest - rate fluctuations, the hmda rules require lenders to report the difference between the apr and the rate on treasury securities of comparable maturity for any loans with rate spreads that exceed prescribed thresholds. for first - and second - lien loans, the thresholds are 3 percentage points and 5 percentage points above the treasury security of comparable maturity, respectively. these particular thresholds were chosen to exclude the reporting of the vast majority of prime - rate loans and include the vast majority of the subprime - rate loans, minimizing the burden of the data collection on lenders while providing information on that portion of the market where concern about consumer abuse is most prevalent. although the addition of the price data significantly increases the robustness of hmda data, the data alone do not prove discrimination. instead, the data will be used as a screen to identify any aspects of the higher - priced end of the mortgage market that warrant closer scrutiny. the new hmda data are clearly limited : they do not include credit scores, loan - to - value ratio, or consumer debt - to - income ratio - all factors relevant to the cost of credit. because these important determinants of price are missing, one cannot draw definitive conclusions about whether particular lenders discriminate unlawfully or take unfair advantage of consumers based solely on a review of the hmda data. the new data will be useful to examiners in identifying particular loan products or geographic areas with significant pricing disparities and establishing one or more focal points for