March 18, 2013 | Testimony on Economy
the Committee on Small Business and Entrepreneurship
United States Senate
March 14, 2013
David B. Muhlhausen, Ph.D.
My name is David Muhlhausen. I am Research Fellow in Empirical Policy Analysis in the Center for Data Analysis at The Heritage Foundation. I thank Chairwoman Mary Landrieu, Ranking Member James Risch, and the rest of the committee for the opportunity to testify today on the Small Business Disaster Reform Act of 2013 (S. 415). The views I express in this testimony are my own and should not be construed as representing any official position of The Heritage Foundation.
After federally declared disasters, the Small Business Administration’s (SBA) Disaster Loan Program (DLP) offers taxpayer-funded direct loans to assist businesses, nonprofit organizations, homeowners, and renters in repairing or replacing property damaged or destroyed. Within the SBA, disaster loans are administered by the Office of Disaster Assistance (ODA). SBA offers four types of disaster loans:
Under current law, for disaster loan applicants who are unable to obtain credit elsewhere, the interest rate shall not exceed 4 percent. For those applicants who have access to credit elsewhere, the interest rate shall not exceed 8 percent. In the 112th Congress, there was a failed effort to set the interest rates for disaster loans at 1 percent for eligible applicants in declared disaster areas, regardless of whether applicants have access to credit.
In fiscal year (FY) 2010, the SBA approved $574 million in disaster loans for 15,356 applicants. The dollar amount of disaster loans increased to $739 million for 13,643 applicants in FY 2011. However, the total monetary value of disaster loans decreased to $690 million in FY 2012.
As of January 31, 2007, according to the Government Accountability Office, the SBA approved over $5 billion in disaster loans for homeowners and renters affected by the Gulf Coast hurricanes of 2005 (Katrina, Rita, and Wilma). The interest rate subsidy of these 2005 hurricane SBA disaster loans cost the federal government almost $800 million.
Unfortunately, as my testimony will illustrate, the Small Business Disaster Reform Act does not provide the necessary reform to our nation’s disaster prevention and recovery programs. My testimony focuses on the following deficiencies of the Disaster Loan Fairness Act:
Instead of considering legislation like the Small Business Disaster Reform Act of 2013, Congress should focus on reforms that make America more resilient to catastrophes and reduce recovery costs imposed on the federal taxpayer.
Increasing the Likelihood of Default
For disaster loans of not more than $200,000, the Small Business Disaster Reform Act allows the SBA to forego using the primary residence of owners applying for loans as collateral if the SBA concludes that the owner has other assets equal to or greater than the amount of the loan that could be used as collateral. In general, the prospective borrower should have enough assets to pay off the loan, so primary residence assets are instrumental in setting conditions where borrowers will be less likely to default on their taxpayer-funded loans.
Simply stated, borrowers who own their primary residences are more likely to do whatever is necessary to keep from defaulting on their loans and losing their homes. This very common and acceptable requirement helps protect both the taxpayer and the lender. Research has demonstrated that small-business owners putting up personal collateral are less likely to pursue unnecessarily risky projects as there is more at stake; therefore, they are less likely to default.
There is good reason to suspect that the Small Business Disaster Reform Act may increase the likelihood of defaults. A series of SBA Office of Inspector General (OIG) audits of 2005 Gulf Coast hurricane disaster loans have clearly found that the SBA awarded loans without regard to the applicants’ ability to repay them.
The Small Business Disaster Reform Act fails to reform serious problems at the SBA.
Failure to Update Credit Reviews. As of September 30, 2007, the OIG identified 11,217 loans totaling $1.1 billion in disbursements for which one or more disbursements transpired more than a year after initial loan approval. Due to the amount of time that can pass between initial loan approval and loan disbursement, the SBA often needs to perform credit reviews at the time of disbursement to ensure that loan applicants are still creditworthy. At the time of initial loan application, the applicant may be creditworthy, but circumstances can change when there is a delay between initial application and disbursement. When too much time passes, the creditworthiness of loan borrowers often changes, sometimes for the worse. To ensure that disbursements are not made to borrowers who are unlikely to repay the taxpayer-funded loans, the SBA needs to check the creditworthiness of borrowers prior to disbursement of funds when there are delays between initial loan approvals and disbursements.
This problem was particularly pronounced in the case of the 2005 Gulf Coast hurricane recovery efforts. “Because rebuilding efforts in the Gulf Coast region have been slow due to the extensive damage caused by the hurricanes,” according to the OIG, “many disaster loans were not fully disbursed until long after they were initially approved.” During this time period between initial approval and disbursement, the financial conditions of borrowers often worsened due to loss of business and employment in the region.
Originally, the SBA decided that there would be additional credit reviews if disbursement took place one year after the initial approval. During the response, however, the SBA extended the one-year credit review requirement to 18 months. The 18-month requirement was later changed to 24 months. Accounting for this evolving credit review requirement, the OIG found 1,117 loans that required updated credit reviews. Based on a random sample of 159 of these 1,117 loans, 110 loans (70 percent) worth $4.9 million were disbursed to recipients without any verification of their creditworthiness. From this sample, the OIG estimates that the SBA disbursed at least $29.2 million to borrowers that had a higher risk of defaulting.
The SBA, as a result, through downgrading the use of updated credit reviews “circumvented a critical management control, disbursing additional funds on these loans without first determining whether adverse changes had occurred in the financial condition of borrowers that would have impacted their ability to repay the additional loan proceeds that were disbursed.” According to the OIG:
[The SBA] explained that the credit review extensions were justified since economic conditions in the hurricane-hit areas had negatively impacted borrower repayment ability in many cases, through no fault of the borrowers. Therefore, they intended to disburse the full amount of the approved loans regardless of whether borrowers could repay their loans.
By disregarding the ability of borrowers to repay taxpayer-funded loans, the SBA “was negligent in carrying out its fiduciary responsibilities.” Further, “By law, SBA is authorized to make disaster loans, not grants.” In essence, the SBA’s disregard for borrower repayment ability transformed the disaster loans, in many cases, into a handout rather than a helping hand. According to the OIG:
SBA’s monitoring efforts were not adequate to ensure that the financial status of borrowers had not deteriorated to levels that would adversely impact their loan repayment ability. Generally, ODA did not: (1) perform annual credit reviews, as required by the Agency’s standard operating procedures, before making distributions of loan proceeds; (2) obtain updated financial information; and (3) cancel loans where the borrower had no repayment ability. As a result, SBA disbursed over $1 billion in loans 1 year or more after loan approval without assurance that borrowers had repayment ability.
Improper Loan Origination and Servicing. The OIG audited “early-defaulted” disaster loans—loans that defaulted within 18 months of first due loan payment—awarded to victims of the 2005 Gulf Coast hurricanes. The OIG randomly sampled 117 loans from 4,985 disaster loans that were at least 90 days delinquent or charged off as of September 30, 2007. The OIG “determined that improper loan origination and/or servicing may have contributed to early loan defaults because all but 4 of the 117 loans reviewed were either improperly originated and/or inadequately serviced.” Further, about “63 percent of the loans reviewed were approved although the applicants lacked repayment ability or were not creditworthy, and 79 percent were inadequately serviced after becoming delinquent.”
Based on its random sample, the OIG estimates that approximately 4,815 (96.6 percent) of the 4,985 early-defaulted loans, totaling $98.4 million, defaulted due to deficiencies in the SBA’s loan origination and servicing practices.
Failure to Require Insured Collateral. The National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973 dictated that federal loan programs cannot provide a loan that is secured by real estate located in federally defined flood hazard areas unless the loan is continuously covered with appropriate flood insurance. Further, if borrowers fail to purchase the required insurance, the loan-backing agency must purchase insurance on behalf of borrowers and charge them for the costs.
For the hurricanes of 2005 and 2008 and the 2008 Midwest floods, the OIG set out to determine the degree to which the SBA adequately monitored the coverage of required insurance policies on collateral properties in the disaster loan portfolio. From 23,068 fully disbursed disaster loans that required flood and hazard insurance coverage until maturity, the OIG randomly sampled 120 cases. The OIG “found that SBA did not ensure that borrower insurance policies provided adequate coverage and were continuously renewed.” Further, the SBA “did not comply with statutory requirements to purchase policies for borrowers who let their policies lapse.”
The 120 cases sampled comprised “$3.8 million in outstanding loan balances that may not be adequately protected.” Based on its sampling technique, the OIG estimated that at least 5,341 (23.2 percent) of the 23,068 loans had collateral properties that were not adequately covered by insurance. This deficiency means that the taxpayers were on the hook for $510 million in outstanding loan balances that were not adequately insured.
Inappropriate Collateral Releases. The OIG audited disaster loans from September 1, 2007 to May 31, 2010, to determine whether the SBA was releasing collateral appropriately. Under most circumstances, loan collateral is released when disaster loans are paid in full. However, borrowers can petition the SBA for a full or partial release of loan collateral. Releases of collateral can be approved by the SBA as long as there is sufficient collateral remaining to continue securing the loan.
The OIG “found that both servicing centers did not consistently make appropriate decisions to release collateral on active loans.” The OIG randomly sampled 120 cases from 2,706 incidences of collateral releases. Of these 120 cases, 55 (45.8 percent) collateral releases were inappropriate. These 55 cases were for property values of at least $3.1 million. Thus, the remaining collateral for many of these loans was insufficient to protect the taxpayer because the loan balances exceeded the values of the properties.
According to the OIG, these inappropriate collateral releases occurred because the SBA failed to perform a full collateral analysis. The OIG estimates that 979 (36.2 percent) of the 2,706 collateral releases for properties worth $33.7 million could be inadequately protected, exposing the taxpayer to a higher risk of loss.
Moral Hazard and Other Unintended Consequences
Generous federal disaster relief creates a “moral hazard” by discouraging individuals and businesses from purchasing natural catastrophe insurance. Currently, SBA disaster loans are awarded regardless of whether the beneficiaries previously took steps to reduce their exposure to losses from natural disasters.
Limiting the range of collateral that can be secured will likely encourage more defaults, leaving taxpayers increasingly at risk. Instead, congressional reform efforts should encourage Americans to become better prepared to prevent property losses from disasters. The Small Business Disaster Reform Act does nothing to reduce the exposure of Americans to property losses and the need for disaster assistance for future catastrophes.
While SBA disaster loans are intended to help applicants return their property to the same condition as before the disaster, the unintended consequence of this requirement is that borrowers are forced to rebuild in disaster-prone locations. For example, instead of relocating out of a town sitting in a major flood zone, applicants are required to rebuild in the exact same location. Thus, applicants are still located in a high-risk area. In many cases, the loans fail to offer a long-term solution. The Small Business Disaster Reform Act does nothing to stop rebuilding in high-risk areas.
Increasing Nationalization of Disaster Responses
By reducing the SBA’s options for securing collateral, the Small Business Disaster Reform Act does nothing to reduce the overreliance of state and local governments on the federal government for the provision of recovery assistance. Far too frequently, the federal government has been the primary source of recovery efforts for natural disasters that are inherently localized in small geographic areas and do not rise to the level that should require action by the federal government.
Overly generous federal assistance encourages state and local governments to underinvest in disaster preparedness, because state and local government expect the federal government to bail them out. Consequently, the more proactive the federal government becomes at supplying disaster recovery assistance, the more it provides an incentive for state and local governments to reduce their own investments in preparedness.
Increasingly, Americans are becoming overly dependent on federal assistance after natural disasters occur. In fact, there is evidence that with each new catastrophe, disaster victims have come to expect more federal relief than was previously offered. Further, disaster assistance appears to have become a political tool because the number of disaster declarations is significantly higher in election years compared to non-election years. For example, one study of Federal Emergency Management Agency (FEMA) disaster payments found not only that states having higher political importance to Presidents receive higher payments, but also that states with greater congressional representation on subcommittees with FEMA oversight responsibilities receive more in disaster payments than states with less representation receive.
Since 1996, the year President Clinton sought reelection, the number of disaster declarations issued by FEMA has increased dramatically. Chart 1 demonstrates this trend. As my Heritage Foundation colleague Matt A. Mayer has previously written, “the yearly average of FEMA declarations tripled from 43 under President George H. W. Bush, to 89 under President Clinton, to 130 under President George W. Bush.” The record for the most declarations in a year was set by President Clinton in 1996 with 158 declarations. However, President Obama smashed this record with 242 declarations in 2011.
Since 1953, there have been 3,478 disaster declarations. During the past 20 years, from President Clinton to President Obama, presidential declarations number 2,325—66.8 percent of all declarations. Since the beginning of President Clinton’s first term in 1993 through the end of 2012, there has been an average of 116.2 disaster declarations per year, compared to an average of 28.8 declarations from 1953 to 1992. Essentially, this trend is the result of disaster responses that were once entirely local in nature and handled by state and local governments becoming “nationalized” and thus the responsibility of the federal government.
This nationalization has led to an ever-growing share of the total cost of natural disasters being dumped on an already strained federal budget. According to my fellow roundtable panelist Professor Howard Kunreuther of the Wharton School’s Risk Management and Decision Processes Center, the amount for aid provided by the federal government as a percentage of total damage caused by a major disaster is steadily increasing. For example, federal aid comprised 50 percent of the total damage caused by Hurricane Katrina (2005). Just three years later, federal aid increased to 69 percent of total damage caused by Hurricane Ike (2008).
The Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1998 (Stafford Act) established that for a disaster to be eligible for federal assistance, it must be “of such severity and magnitude that effective response is beyond the capabilities of the State and the affected local governments and that Federal assistance is necessary.” Regardless of this apparent requirement, FEMA “has approved disaster declarations for many natural disasters that historically and factually were not beyond the capabilities of states and localities.” Returning to the original understanding of what necessitates the federal government’s involvement does not mean that local natural disasters are not “catastrophic” for a particular community. Rather, “It simply means that most natural disasters occur within confined geographic areas and that states and localities can handle them without federal involvement.”
The majority of states do not benefit from federal assistance, because only a minority of states receives the benefit of FEMA disaster declarations. Thus, the majority of states send their disaster-response tax dollars to Washington, D.C., so the federal government can subsidize disaster response for the minority of states.
The Congressional Budget Office (CBO) reported throughout 2012 that the federal deficit for FY 2012 will be nearly $1.1 trillion. “Measured as a share of gross domestic product (GDP),” the CBO reports, “that shortfall will be 7.0 percent, which is nearly two percentage points below the deficit recorded last year but still higher than any deficit between 1947 and 2008.” GDP is the total market value of all officially recognized goods and services produced within a country in a given year. FY 2012 is the fourth year in a row that the federal government has posted a deficit exceeding $1 trillion. In 2009, the CBO warned that these “Large budget deficits would reduce national savings, leading to more borrowing from abroad and less domestic investment, which in turn would depress economic growth in the United States. Over time, the accumulation of debt would seriously harm the economy.”
These persistently large deficits have caused the federal government’s debt to explode. On December 31, 2011, the gross debt racked up by the federal government reached $15.2 trillion—the legal limit as authorized by Congress. In response, on January 12, 2012, President Barack Obama formally notified Congress of his intent to raise the nation’s debt ceiling by $1.2 trillion, from $15.2 to $16.4 trillion. In November 2012, the CBO reported that the nation’s gross debt stood at $16.3 trillion. The federal government’s debt has reached such a staggering sum that it is difficult for Americans to comprehend. If we did, we would be truly frightened at the prospect of paying it off.
While the deficit and debt are driven largely by entitlement spending—Medicare, Medicaid, and Social Security— the failure to reform federal disaster assistance and all the other spending programs advocated by Congress only moves the nation closer to fiscal insolvency. The Small Business Disaster Reform Act does nothing to reduce the cost of future disaster recoveries. Given the increasing financial stress facing the federal government, reform should be focused on preventive measures that limit the costs of disaster recovery.
The Small Business Disaster Reform Act fails as a reform effort. Weakening collateral requirements is neither fair to the federal taxpayer nor an effective reform of our nation’s disaster prevention and recovery policies. The Act fails to address the increasing nationalization of disaster responses while doing nothing to address the federal government’s out-of-control spending. The Act fails to address the SBA’s violation of its fiduciary responsibilities. Last, the Act fails to address the moral hazards of providing disaster loans.
Instead of considering legislation like the Small Business Disaster Reform Act, Congress should focus on reforms that make America more resilient to catastrophes and reduce recovery costs imposed on the federal taxpayer.
Bruce R. Lindsay, The SBA Disaster Loan Program: Overview and Possible Issues for Congress, Congressional Research Service, June 29, 2010.
The Disaster Loan Fairness Act of 2011 (H.R. 3042).
U.S. Small Business Administration, FY 2012 Congressional Budget Justification and FY 2010 Annual Performance Report, p. 56, http://www.sba.gov/sites/default/files/FINAL%20FY%202012%20CBJ%20FY%202010%20APR_0.pdf (accessed February 13, 2012).
U.S. Small Business Administration, FY 2013 Congressional Budget Justification and FY 2011 Annual Performance Report, p. 53, http://www.sba.gov/sites/default/files/files/FY%202013%20CBJ%20FY%202011%20APR.pdf (accessed February 13, 2012).
U.S. Small Business Administration, Summary of Performance and Financial Information: Fiscal Year 2012, p. 2, http://www.sba.gov/sites/default/files/files/FY%202012%20Summary%20of%20Performance%20and%20Financial%20Information.pdf.pdf (accessed March 9, 2012).
U.S. Government Accountability Office, Natural Disasters: Public Policy Options for Changing the Federal Role in Natural Catastrophe Insurance, November 2007, p. 16, http://www.gao.gov/assets/270/269745.pdf (accessed February 13, 2012).
For an example of proposed reforms, see Matt Mayer, David John, and James Jay Carafano, “Principles for Reform of Catastrophic Natural Disaster Insurance,” Heritage Foundation Backgrounder No. 2256, April 8, 2009, http://www.heritage.org/research/reports/2009/04/principles-for-reform-of-catastrophic-natural-disaster-insurance.
Sumit Agarwal, Souphala Chomsisengphet, and Chunlin Liu, “Determinants of Small Business Default” in The Analytics of Risk Model Validation, ed. George Christodoulakis and Stephen Satchell (Burlington, Mass: Academic Press, 2008), pp. 1–12.
U.S. Small Business Administration, Office of the Inspector General, “Annual Credit Reviews for Gulf Coast Hurricane Disaster Loan Disbursements,” Report Number 08-10, March 28, 2008, p. 1, http://www.sba.gov/sites/default/files/oig_dl_8-10.pdf (accessed March 11, 2013).
Ibid, p. 2.
Ibid, p. 1.
Ibid., p. 3.
Ibid., p. 4.
Ibid., pp. 2–3.
U.S. Small Business Administration, Office of the Inspector General, “Early-Defaulted Gulf Coast Hurricane Disaster Loans,” Report Number 08-19, September 12, 2008, http://www.sba.gov/sites/default/files/oig_dl_8-19.pdf (accessed March 11, 2013).
Ibid., p. 1.
Ibid., p. 2.
U.S. Small Business Administration, Office of the Inspector General, “Monitoring of Insurance Coverage for Disaster Loan Recipients,” Report Number 10-01, October 20, 2009, p. 2, http://www.sba.gov/sites/default/files/oig_reptbydate_10-1.pdf (accessed March 8, 2013).
Ibid., pp. 2–3.
Ibid., p. 1.
Ibid., p. 2.
U.S. Small Business Administration, Office of the Inspector General, “Release of Collateral by the Disaster Loan Servicing Centers,” Report Number 11-15, June 3, 2011, http://www.sba.gov/sites/default/files/Audit%2011-15%20Release%20of%20Collateral%20by%20the%20Disaster%20Loan%20Servicing%20Centers.pdf (accessed March 8, 2013).
Ibid., p. 1.
Ibid., p. 6.
Ibid., pp. 1–2.
Ibid., p. 6.
Matt A. Mayer, Homeland Security and Federalism: Protecting America from Outside the Beltway (Santa Barbara, Cal.: Praeger, 2009); James F. Miskel, Disaster Response and Homeland Security: What Works, What Doesn’t (Stanford, Cal.: Stanford University Press, 2008).
Erwann Michel-Kerjan and Jacqueline Volkman-Wise, “The Risk of Ever-growing Disaster Relief Expectations,” University of Pennsylvania, The Wharton School, Risk Management and Decision Processes Center Working Paper No. 32011-09, July 2011, http://opim.wharton.upenn.edu/risk/library/WP2011-09_ReliefExpectations.pdf (accessed February 13, 2011); Michele L. Landis, “Fate, Responsibility, and ‘Natural’ Disaster Relief: Narrating the American Welfare State,” Law & Society Review, Vol. 33, No. 2 (1999), pp. 257–318; and Michele L. Landis, “Let Me Next Time Be Tried by Fire: Disaster Relief and the Origins of the American Welfare State 1789–1874,” Northwestern University Law Review, Vol. 92, No. 3 (1998), pp. 967–1034.
Thomas R. Garrett and Russell S. Sobel, “The Political Economy of FEMA Disaster Payments,” Economic Inquiry, Vol. 41, No. 3 (2003), pp. 496–509, and Erwann Michel-Kerjan, “Catastrophe Economics: The U.S. National Flood Insurance Program,” Journal of Economic Perspectives, Vol. 24, No. 4 (2010), pp. 165–186.
Garret and Sobel, “The Political Economy of FEMA Disaster Payments.”
The data presented in Chart 1 are based on Matt A. Mayer, “Congress Should Limit the Presidential Abuse of FEMA,” Heritage Foundation WebMemo No. 3466, January 24, 2012, http://www.heritage.org/research/reports/2012/01/congress-should-limit-the-presidential-abuse-of-fema.
Matt Mayer, “States: Stop Subsidizing FEMA Waste and Manage Your Own Local Disaster,” Heritage Foundation Backgrounder No. 2323, September 29, 2009, p. 1, http://www.heritage.org/research/reports/2009/09/states-stop-subsidizing-fema-waste-and-manage-your-own-local-disasters.
Some may argue that the growth of the federal government’s role in disaster recovery is a result of the states not being able to afford to finance their own disaster recoveries. The federal government is facing a severe financial crisis and can no longer bail out the states that avoid their responsibilities. Public safety is a priority of state and local governments. If state and local governments are not willing to adopt policies to mitigate the effects of natural disasters and recover from these incidents afterward, then they are not fulfilling their obligations to their citizens.
Howard Kunreuther and Erwann Michel-Kerjan, “People Get Ready: Disaster Preparedness,” Issues in Science and Technology, Vol. 28, No. 1 (2011), pp. 1–7, http://opim.wharton.upenn.edu/risk/library/J2011IST_PeopleGetReady.pdf (accessed March 11, 2013).
Ibid., p. 3.
42 U.S. Code § 5191(a).
Matt A. Mayer, David C. John, and James Jay Carafano, “Principles for Reform of Catastrophic Natural Disaster Insurance,” Heritage Foundation Backgrounder No. 2256, April 8, 2009, p. 3, http://www.heritage.org/research/reports/2009/04/principles-for-reform-of-catastrophic-natural-disaster-insurance.
Mayer, “States: Stop Subsidizing FEMA Waste and Manage Your Own Local Disaster,” p. 3.
Congressional Budget Office, The Budget and Economic Outlook: Fiscal Years 2012 to 2022, January 2012, p. x, http://www.cbo.gov/ftpdocs/126xx/doc12699/01-31-2012_Outlook.pdf (accessed December 11, 2012); Congressional Budget Office, An Update to the Budget and Economic Outlook: Fiscal Years 2012 to 2022, August 2012, p. 1, http://www.cbo.gov/sites/default/files/cbofiles/attachments/08-22-2012-Update_to_Outlook.pdf (accessed December 11, 2012).
Congressional Budget Office, The Budget and Economic Outlook: Fiscal Years 2012 to 2022, January 2012, p. x.
Congressional Budget Office, An Update to the Budget and Economic Outlook: Fiscal Years 2012 to 2022, p. 1.
Congressional Budget Office, The Long-Term Budget Outlook, June 2009, p. xii, http://www.cbo.gov/ftpdocs/102xx/doc10297/06-25-LTBO.pdf (accessed December 11, 2012).
U.S. Department of the Treasury, Bureau of the Public Debt, “Monthly Statement of the Public Debt of the United States, December 31, 2011,” Table 1: Summary of Treasury Securities Outstanding, December 31, 2011, http://www.treasurydirect.gov/govt/reports/pd/mspd/2011/opds122011.pdf (accessed December 11, 2012).
David Nakamura, “Obama Asks Congress for Debt Limit Hike,” 44 (blog), The Washington Post, January 12, 2012, http://www.washingtonpost.com/blogs/44/post/after-delay-obama-asks-congress-for-debt-limit-hike/2012/01/12/gIQAA3ADuP_blog.html (accessed December 11, 2012).
Congressional Budget Office, Federal Debt and the Statutory Limit, November 2012, November 2012, p. 1, http://www.cbo.gov/sites/default/files/cbofiles/attachments/43736-FederalDebtLimit-11-12-12.pdf (accessed December 11, 2012).