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	<title>Comments on: The Administration&#8217;s Cosmetic Credit Market Reform</title>
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		<title>By: Francois</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5115</link>
		<dc:creator>Francois</dc:creator>
		<pubDate>Fri, 14 Mar 2008 02:56:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5115</guid>
		<description>Anon @ 4:25 PM&lt;br/&gt;&lt;br/&gt;&quot;I sure do hope that I&#039;m wrong about this.&quot;&lt;br/&gt;&lt;br/&gt;Of course you are not wrong. If you want to know how cosmetic and shallow this Administration is about pretty much everything that has to do with what is essential for the good functionning of the American Society, check this:&lt;br/&gt;&lt;br/&gt;http://whistleblower.typepad.com/all_things_whistleblower_/2008/02/drug-import-mes.html&lt;br/&gt;&lt;br/&gt;Anything that foster a &quot;free-market&quot; (Bushie&#039;s code word for crony capitalism) has been done since 2000.&lt;br/&gt;&lt;br/&gt;And it keeps getting uglier and uglier. From our finances to our health, this government does not give a damn about the people.&lt;br/&gt;&lt;br/&gt;And no, I do not expect the Dems to do much better. perhaps a bit better, but not much. They need money to win elections and we know who provides it.&lt;br/&gt;&lt;br/&gt;Yves was right: we&#039;re going the way of Argentina.</description>
		<content:encoded><![CDATA[<p>Anon @ 4:25 PM</p>
<p>&#8220;I sure do hope that I&#8217;m wrong about this.&#8221;</p>
<p>Of course you are not wrong. If you want to know how cosmetic and shallow this Administration is about pretty much everything that has to do with what is essential for the good functionning of the American Society, check this:</p>
<p><a href="http://whistleblower.typepad.com/all_things_whistleblower_/2008/02/drug-import-mes.html" rel="nofollow">http://whistleblower.typepad.com/all_things_whistleblower_/2008/02/drug-import-mes.html</a></p>
<p>Anything that foster a &#8220;free-market&#8221; (Bushie&#8217;s code word for crony capitalism) has been done since 2000.</p>
<p>And it keeps getting uglier and uglier. From our finances to our health, this government does not give a damn about the people.</p>
<p>And no, I do not expect the Dems to do much better. perhaps a bit better, but not much. They need money to win elections and we know who provides it.</p>
<p>Yves was right: we&#8217;re going the way of Argentina.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5112</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Thu, 13 Mar 2008 20:25:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5112</guid>
		<description>From: Earl L. Crockett&lt;br/&gt;&lt;br/&gt;&quot;To little to late&quot;, &quot;Closing the barn door...?&quot; How about &quot;Pissing in the wind&quot; and/or suggesting to a patient in Intensive Care, on Life Support, that they make sure that they use hand lotion twice a day. And who, and what, do they think will be left in near term other than the Fed to apply these new regs?&lt;br/&gt; I sure do hope that I&#039;m wrong about this.&lt;br/&gt;Earl</description>
		<content:encoded><![CDATA[<p>From: Earl L. Crockett</p>
<p>&#8220;To little to late&#8221;, &#8220;Closing the barn door&#8230;?&#8221; How about &#8220;Pissing in the wind&#8221; and/or suggesting to a patient in Intensive Care, on Life Support, that they make sure that they use hand lotion twice a day. And who, and what, do they think will be left in near term other than the Fed to apply these new regs?<br /> I sure do hope that I&#8217;m wrong about this.<br />Earl</p>
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		<title>By: Ginger Yellow</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5107</link>
		<dc:creator>Ginger Yellow</dc:creator>
		<pubDate>Thu, 13 Mar 2008 16:49:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5107</guid>
		<description>&quot;Covered bonds, or any form of mortgage finance that requires a bank to use its balance sheet is inherently more costly than securitization and also requires banks to carry vastly more equity if they are to use this product on a large scale basis.&quot;&lt;br/&gt;&lt;br/&gt;Even with the balance sheet costs, covered bonds are far, far cheaper than (non-agency) securitisation. You can fund in single digits over Libor, compared with 100s of basis points for RMBS at the moment. The problem is (was) that the investor base for covered bonds was nowhere near as deep as that for RMBS. You could sell a $10bn RMBS quite easily, but covered bonds don&#039;t usually go above $2bn. Of course, the situation is reversed now.&lt;br/&gt;&lt;br/&gt;Also, Basel II removes most of the capital benefits of securitisation anyway, and FASB is planning to eliminate QSPE status, which would make off balance sheet treatment near impossible. So the balance sheet argument is going to be irrelevant fairly soon. In Europe, RMBS has been on balance sheet for years and people still did it for funding reasons.</description>
		<content:encoded><![CDATA[<p>&#8220;Covered bonds, or any form of mortgage finance that requires a bank to use its balance sheet is inherently more costly than securitization and also requires banks to carry vastly more equity if they are to use this product on a large scale basis.&#8221;</p>
<p>Even with the balance sheet costs, covered bonds are far, far cheaper than (non-agency) securitisation. You can fund in single digits over Libor, compared with 100s of basis points for RMBS at the moment. The problem is (was) that the investor base for covered bonds was nowhere near as deep as that for RMBS. You could sell a $10bn RMBS quite easily, but covered bonds don&#8217;t usually go above $2bn. Of course, the situation is reversed now.</p>
<p>Also, Basel II removes most of the capital benefits of securitisation anyway, and FASB is planning to eliminate QSPE status, which would make off balance sheet treatment near impossible. So the balance sheet argument is going to be irrelevant fairly soon. In Europe, RMBS has been on balance sheet for years and people still did it for funding reasons.</p>
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		<title>By: Ginger Yellow</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5104</link>
		<dc:creator>Ginger Yellow</dc:creator>
		<pubDate>Thu, 13 Mar 2008 16:39:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5104</guid>
		<description>&quot;So my impression is that a structure isn&#039;t shopped very often; instead, a deal is massaged repeatedly until the rating agency signs off on it.&quot;&lt;br/&gt;&lt;br/&gt;Depending on how you define shopping, it certainly goes on. For instance, in European CMBS, Moody&#039;s requires more credit enhancement at lower rating levels, so you often see deals with triple-As from the big three, but only Fitch and S&amp;P ratings for subordinated notes. Then there&#039;s bigger picture stuff like the fact that Fitch refused to give triple-A ratings to CPDOs, so obviously nobody bothered to get a rating from them. &lt;br/&gt;&lt;br/&gt;It&#039;s not so much about shopping a deal to agencies and seeing who gives you the best rating, so much as only going to the agencies you know are going to give you the rating you wantb because of their methodologies. For common asset classes and structures you don&#039;t really need to do the iterative approach, because you can just plug your numbers into the agencies&#039; models. It&#039;s only really for new/unique asset classes and structural features that iteration happens.</description>
		<content:encoded><![CDATA[<p>&#8220;So my impression is that a structure isn&#8217;t shopped very often; instead, a deal is massaged repeatedly until the rating agency signs off on it.&#8221;</p>
<p>Depending on how you define shopping, it certainly goes on. For instance, in European CMBS, Moody&#8217;s requires more credit enhancement at lower rating levels, so you often see deals with triple-As from the big three, but only Fitch and S&#038;P ratings for subordinated notes. Then there&#8217;s bigger picture stuff like the fact that Fitch refused to give triple-A ratings to CPDOs, so obviously nobody bothered to get a rating from them. </p>
<p>It&#8217;s not so much about shopping a deal to agencies and seeing who gives you the best rating, so much as only going to the agencies you know are going to give you the rating you wantb because of their methodologies. For common asset classes and structures you don&#8217;t really need to do the iterative approach, because you can just plug your numbers into the agencies&#8217; models. It&#8217;s only really for new/unique asset classes and structural features that iteration happens.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5103</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Thu, 13 Mar 2008 16:23:00 +0000</pubDate>
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		<description>It&#039;s not the regulations that are the problem:&lt;br/&gt;&lt;br/&gt;To illustrate:&lt;br/&gt;&lt;br/&gt;Some of the States have been putting in place moderate requirements for mortgage brokers.&lt;br/&gt;&lt;br/&gt;State Farm has a bank.  They have their independent insurance agents making loans.  When Ohio wanted these agents to register as mortgage brokers, State Farm ran to the OCC and got a letter from their counsel that State Farm’s independent agents were exempt because State Farm’s bank is a “National Bank”  regulated by the OCC and exempt from state law.&lt;br/&gt;The Judge slapped that attempt down for procedural issues, but also noted  that the OCC had never previously shown any interest in regulating the independent mortgage brokers associated with National  Banks.&lt;br/&gt;&lt;br/&gt;It’s not really the laws, it’s the people doing the regulating.&lt;br/&gt;&lt;br/&gt;russell120</description>
		<content:encoded><![CDATA[<p>It&#8217;s not the regulations that are the problem:</p>
<p>To illustrate:</p>
<p>Some of the States have been putting in place moderate requirements for mortgage brokers.</p>
<p>State Farm has a bank.  They have their independent insurance agents making loans.  When Ohio wanted these agents to register as mortgage brokers, State Farm ran to the OCC and got a letter from their counsel that State Farm’s independent agents were exempt because State Farm’s bank is a “National Bank”  regulated by the OCC and exempt from state law.<br />The Judge slapped that attempt down for procedural issues, but also noted  that the OCC had never previously shown any interest in regulating the independent mortgage brokers associated with National  Banks.</p>
<p>It’s not really the laws, it’s the people doing the regulating.</p>
<p>russell120</p>
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		<title>By: S</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5102</link>
		<dc:creator>S</dc:creator>
		<pubDate>Thu, 13 Mar 2008 16:18:00 +0000</pubDate>
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		<description>Barney Frank has a plan. treasury Sec has a plan. Bush has a plan. bernanke has a plan. How is it that everyone has a plan. What happens when the fed bails out the housing losses (zero sum) and then the Muniicipalities start to fail as tax revenue drys up. Then the local tax regimes start to raise sales tax on top of already high inflation. Nice offset to any stimulus. At some point we can dance around and play musical chairs. Someone is ggoing to take the loss. This notion that suddenly everyone starts throwing money at a problem that no-one has (including the gov) is incredible. You don;t buy your way out of insolvency. What is it so hard to get this. The great unwind continues. As the French Foreign minister says the American magic is gone - well said.</description>
		<content:encoded><![CDATA[<p>Barney Frank has a plan. treasury Sec has a plan. Bush has a plan. bernanke has a plan. How is it that everyone has a plan. What happens when the fed bails out the housing losses (zero sum) and then the Muniicipalities start to fail as tax revenue drys up. Then the local tax regimes start to raise sales tax on top of already high inflation. Nice offset to any stimulus. At some point we can dance around and play musical chairs. Someone is ggoing to take the loss. This notion that suddenly everyone starts throwing money at a problem that no-one has (including the gov) is incredible. You don;t buy your way out of insolvency. What is it so hard to get this. The great unwind continues. As the French Foreign minister says the American magic is gone &#8211; well said.</p>
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		<title>By: Anonymous</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5096</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Thu, 13 Mar 2008 13:52:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5096</guid>
		<description>Funny:&lt;br/&gt;&lt;br/&gt;THURSDAY, MARCH 13, 2008&lt;br/&gt;&lt;br/&gt;The Fed&#039;s Bank Bailout&lt;br/&gt;&lt;br/&gt;&lt;br/&gt;http://www.theonion.com/content/amvo/the_feds_bank_bailout&lt;br/&gt;&lt;br/&gt;Econolicious</description>
		<content:encoded><![CDATA[<p>Funny:</p>
<p>THURSDAY, MARCH 13, 2008</p>
<p>The Fed&#8217;s Bank Bailout</p>
<p><a href="http://www.theonion.com/content/amvo/the_feds_bank_bailout" rel="nofollow">http://www.theonion.com/content/amvo/the_feds_bank_bailout</a></p>
<p>Econolicious</p>
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		<title>By: dd</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5093</link>
		<dc:creator>dd</dc:creator>
		<pubDate>Thu, 13 Mar 2008 13:21:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5093</guid>
		<description>Pope Paulson&#039;s blanket absolution:&lt;br/&gt;&quot;We aren&#039;t singling out any group of market participants, because...there were mistakes made by all,&quot;&lt;br/&gt;&lt;br/&gt;Mistakes? Wow, he&#039;s all the way up to &quot;mistakes&quot; but no problem because everyone did it and therefore there will be no punishment only forgiveness.</description>
		<content:encoded><![CDATA[<p>Pope Paulson&#8217;s blanket absolution:<br />&#8220;We aren&#8217;t singling out any group of market participants, because&#8230;there were mistakes made by all,&#8221;</p>
<p>Mistakes? Wow, he&#8217;s all the way up to &#8220;mistakes&#8221; but no problem because everyone did it and therefore there will be no punishment only forgiveness.</p>
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		<title>By: S</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5092</link>
		<dc:creator>S</dc:creator>
		<pubDate>Thu, 13 Mar 2008 13:15:00 +0000</pubDate>
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		<description>FT article today claiming the FED will not let a deep recession happen as it will do anything necessary. The dollar is responding with the middle finger. These guys are the height of arrogant to think they can reverse the tide.</description>
		<content:encoded><![CDATA[<p>FT article today claiming the FED will not let a deep recession happen as it will do anything necessary. The dollar is responding with the middle finger. These guys are the height of arrogant to think they can reverse the tide.</p>
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		<title>By: Independent Accountant</title>
		<link>http://www.nakedcapitalism.com/2008/03/administrations-cosmetic-credit-market.html#comment-5090</link>
		<dc:creator>Independent Accountant</dc:creator>
		<pubDate>Thu, 13 Mar 2008 12:17:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.nakedcapitalism.com/2008/03/the-administrations-cosmetic-credit-market-reform/#comment-5090</guid>
		<description>Danny:&lt;br/&gt;I say It&#039;s the only regulation.</description>
		<content:encoded><![CDATA[<p>Danny:<br />I say It&#8217;s the only regulation.</p>
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