Letter AL 2003-2 describes predatory lending as including the following: Loan "flipping" – frequent refinancings that result in little or no economic benefit to the borrower and are undertaken with the primary or sole objective of generating additional loan fees, prepayment penalties, and fees from the financing of credit-related products; Refinancings of special subsidized mortgages that result in the loss of beneficial loan terms; "Packing" of excessive and sometimes "hidden" fees in the amount financed; Using loan terms or structures – such as negative amortization – to make it more difficult or impossible for borrowers to reduce or repay their indebtedness; Using balloon payments to conceal the true burden of the financing and to force borrowers into costly refinancing transactions or foreclosures; Targeting inappropriate or excessively expensive credit products to older borrowers, to persons who are not financially sophisticated or who may be otherwise vulnerable to abusive practices, and to persons who could qualify for mainstream credit products and terms; Inadequate disclosure of the true costs, risks and, where necessary, appropriateness to the borrower of loan transactions; The offering of single premium credit life insurance; and The use of mandatory arbitration clauses. Predatory lending towards minority groups Because many minority communities have been excluded from loans in the past, they are and have been more vulnerable to deception. Oftentimes, they are targeted because of these vulnerabilities. Organizations and agencies including ACORN, HUD, the American Civil Liberties Union, United for a Fair Economy and more prove that predatory loans are disproportionately made in poor and minority neighborhoods. Brokers and lenders preyed on these neighborhoods with the knowledge that these people were often denied for loans and the demand for loans were high. Lenders called these neighborhoods never-never land. This created the subprime predatory lending world. Subprime lenders specialize in B, C, and D paper. Predatory lending is the practice of overcharging a borrower for rates and fees, average fee should be 1%, these lenders were charging borrowers over 5%. Consumers without challenged credit loans should be underwritten with prime lenders. In 2004, 69% of borrowers were from subprime lending. The 2007 mortgage drop and economy fail were from over lending. Organizations such as AARP, Inner City Press, and ACORN have worked to stop what they describe as predatory lending. ACORN has targeted specific companies such as HSBC Finance, successfully forcing them to change their practices. Some subprime lending practices have raised