janet yellen's claims need further investigation she is correct that lending institutions not subject to the cra are responsible roughly half of recent subprime originations however a substantial portion was originated under cra she also provides no evidence that subprime delinquencies are either uniformly distributed or more highly concentrated in the non cra lenders if cra loans accounted for as few as of subprime loans they could still be a significant proportion of those in default she merely asserts that the loans were properly underwritten