Truth
As someone who works in the web hosting biz, I can say this is true. I've seen lots of websites running insecure CMSes and the like get exploited to host phishing sites. Chances are it's easier than signing up for a free hosting service. ;D
Phishers automate attacks using 'Google hacking'
Three in four phishing sites are hosted on compromised servers, according to a new survey. A study of 2,486 fraudulent websites found that 76 per cent were housed on hacked webservers, typically pwned after hackers identified well-known vulnerabilities using search engine queries. Free web hosting for fraudulent websites was …
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