seven of all new FHA insured loans. The report also found that Nehemiah-assisted loans comprised about half of all private-nonprofit-assisted loans (in the full data period). The Milken Institute performed a study of the Nehemiah Program and published a report on it in April 2004 (herein, the "Milken study"). Although the report did not explicitly identify the parties who had commissioned the study, its Acknowledgement page listed the Nehemiah Corporation of America, the United States Conference of Mayors, and CitiesFirst. The study generally found that the nationwide surge in home prices in the United States "created additional wealth" for recipients of the Nehemiah Program and that an expansion of homeownership had "positive tax consequences" for the counties in which the recipients lived. When the Milken study was published, HUD had already commissioned its own study of seller-funded down-payment assistance programs. It was performed by the Concentrance Consulting Group and published in March 2005 (herein, the "Concentrance study"). Unlike the earlier OIG reports, the Concentrance study was based largely on a cross-sectional analysis of data collected in interviews with individual homebuyers, sellers and various types of real-estate professionals in ten metropolitan areas. Their findings corroborated some of the claims made by the nonprofit organizations, particularly that the typical recipient was a person who would not otherwise have been able to become a home owner. But the interviewees also generally corroborated some of the claims made by detractors of the programs—that sellers were routinely raising their sales prices to recoup the payment made to the nonprofit organization, and that the price increases led to higher loan costs for the buyers along with a higher risk of default on their loans. The study was not restricted to the Nehemiah Program; no particular program was singled out in the body of the report. However, the appendices gave summary results of questionnaire answers from real-estate professionals. These results indicated that the Nehemiah Program was the most active program in the ten metropolitan areas covered by the study. The Government Accountability Office ("GAO") published its own report in November 2005 (herein, the "GAO study"). The report examined trends in the use of seller-funded down-payment assistance, its impact on home prices, the performance of the FHA insured loans that had received this assistance, and the standards used by the FHA for approving and monitoring these loans. Its findings generally corroborated those of the earlier government reports and