The banking industry suffered credit crises in the 1970s, 1980s, 1990s, and 2000s. An unavoidable conclusion is that its loan loss reserves were in all cases too small. 

The National Association of Realtors (NAR), which pushed Congress to give FHA yet more responsibilities, is now trying to show that the agency is not really insolvent. But the slippery "facts" they are using show how tenuous their argument is.

The fat years of the housing bubble lasted from 1999 to 2006 - seven years. The bubble was deflating by the beginning of 2007 and collapsed into the panics of 2007-09. Since then we have been struggling in its deflated wake. If we get the Biblical sum of seven lean years, the housing and related debt markets will bottom in 2013 - not a bad forecast. 

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On January 31, 2011, the Financial Accounting Standards Board (FASB) issued for public comment a proposed approach for recognizing impairment allowances on financial assets.

Reform focused on sustainable lending would have FHA target a projected average claim rate of 5 per 100 insured loans under normal circumstances and 10 per 100 insured loans under stress circumstances.  This rate is about five times the normal default level for prime loans and about half the FHA's traditional default level under normal circumstances.

The housing finance system of the future needs to have countercyclical factors built into it and much bigger loan loss reserves in good times to avoid the illusory profits which feed booms and bubbles.

To make financial markets less vulnerable to their inevitable cycles, it is an essential responsibility of both private financial actors and government officials to study, develop and implement countercyclical approaches.