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David Dayen: GAO Report on Independent Foreclosure Reviews Exposes OCC, Fed’s Plan to Deliberately Minimize Evidence of Borrower Harm

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By David Dayen, a lapsed blogger, now a freelance writer based in Los Angeles, CA. Follow him on Twitter @ddayen

This morning the Government Accountability Office released their second report on the Independent Foreclosure Reviews. Kudos to Rep. Maxine Waters for getting GAO to take another look. At the time that the OCC and the Fed scrapped the reviews and amended their consent orders, this review, expected to be critical of the process, was seen as a proximate cause.

Rep. Brad Miller, a North Carolina Democrat, told The Huffington Post that the report, which has not been released, was “critical” and that the Office of the Comptroller of the Currency, which administers the review, was aware of its findings. Miller said that that one problem the GAO was likely to highlight was an “unacceptably high” error rate of 11 percent in a sampling of bank loan files.

That indeed is in the report, though I wouldn’t call it a major feature. And there are only a few big bombshells or pieces of corroboratory evidence in the report. Furthermore, its narrow scope – GAO only looked at the regulators’ design and ovesight of the foreclosure reviews, rather than what the independent reviewers did, and in fact they used the bank consultant reviewers as primary sources – tends to give a very circumscribed picture of the reviews. You could even say that this report will help get the bank consultants off the hook by putting the blame on OCC and the Fed.

But the regulators were definitely part of the story here, and once you get through the government audit-ese, you can begin to see the picture of how they conspired to ensure the reviews would offer little to no value, and indeed attempt to exonerate the banks. The ensuing calamity only shows how the scheme worked too well, burying any evidence of borrower harm among an avalanche of deliberately cracked design.

Remember why these reviews came together in the first place. State Attorneys General and federal regulators were moving forward with a joint process in the wake of the robo-signing scandal, and feeling lots of grassroots pressure to bring cases against the banks. OCC’s move was a classic divide-and-conquer tactic. They split off with their consent orders, even though around that time, then-director John Walsh said before Congress that he believed there were no illegal foreclosures as a result of the servicing errors. So the thumbs were on the scale even then. The reviews were a political maneuver to reduce the leverage in the larger investigation, and protect the mega-banks, who all have OCC as their primary regulator, from these widespread claims of borrower harm.

Given that, we should expect that little or no thought went into designing an accurate method for determining harm. GAO verifies this in two ways. First, they confirm that nobody actually dealing with borrowers on the ground was consulted about how to best figure out the major categories for servicer errors. This is from the report:

In addition, regulators did not consult with community groups, such as national organizations representing housing counselors that have worked with individual borrowers on their loan modification and loss mitigation applications. These consultations might have provided input on challenges specific servicers and borrowers experienced with the range of loss mitigation and loan modification activities which could have assisted in identifying high-risk loan categories or program elements to consider. For example, our prior work surveying housing counselors found that while assisting borrowers with HAMP applications, counselors experienced challenges with servicers, including missing documentation, lengthy decision-making processes, and miscalculations of borrowers’ incomes.

A targeted process, that just took the biggest categories well-known to any housing counselor, and had the reviewers simply check those boxes, would have been efficient and broadly accurate. Sure, things would have gotten lost in the shuffle, but the overwhelming majority of abuse would have been apparent, and with far less effort. But nobody at the regulators asked the counselors.

Instead, they created what I’d call the “illusion of comprehensiveness.” In ensuring that no stone was left unturned, they devised a process laden with unturned stones. They set the consultants down a path that created a confusing, complex, kludgy system requiring up to 50 hours per loan file to review, which is simply ridiculous and unnecessary. From the report:

The number of test questions used by third-party consultants to conduct the file reviews varied. For example, one consultant told us that they had approximately 2,600 test questions with more than 4,000 discrete steps, while another consultant told us they had 16,000 test questions. Further, third-party consultants from whom we obtained information stated that their reviewers spent as many as 50 hours to complete a full file review, although review times varied depending on the issue and type of review.

What GAO leaves unsaid is that the consultants had every incentive to draw out the process and lengthen the reviews. $2 billion worth of reasons, in fact.

This led to the chaotic process that has been well-documented by Yves (who I’m sure will have plenty to say about this report). But too much of this reads like an apology for the bank consultants. GAO’s had a mandate to review how the regulators managed the consent orders, not how the consultants dealt with it. Therefore, we get a lot about the lack of communication to borrowers, the inadequacy of the initial planning, the failings of oversight over the reviewers, and so on. With the reviewers as sources, frequently the report gives off the vibe that the reviews were just too darn hard, that the regulators gave too much conflicting information. With the consultants as sources, the critical eye never gets turned in their direction in this report.

Nonetheless, GAO appears to know the scheme here. This conclusion is accurate IMO:

…the broad and expanding scope of the reviews and delays in defining key concepts could have been mitigated by more advanced planning from regulators, resulting in more efficient and effective reviews. Regulators may have missed opportunities to potentially narrow and refine the project scope—for example, through earlier definition of a harmed borrower or agreement on errors not resulting in remediation that may not have warranted additional review… conducting a planning process that involves all stakeholders provides an opportunity to examine preliminary information and pilot-test processes and procedures to help further define the scope of potential activities and hedge against the risk of future changes.

I’d say this is audit-speak for “the regulators screwed up royally.” And that was the whole point. OCC wanted these things to drown in data. It made it easier for the consultants to game the system. They may not have wanted the whole process to collapse, but as long as the evidence of borrower harm is ultimately relatively undefined, all the better.

You can read the report yourself – it’s at the bottom of this post. Just three more amazing things I flagged:

1) Like Treasury with HAMP – another program where the government regulator had different goals than they publicly stated – OCC and the Fed kept issuing new guidances and updates that would change the reviewers’ parameters (this, not the constant haggling between reviewers and their superiors, is used as the cause for delays in the IFRs). Regulators called it an “iterative” process, where they learned and refined as the reviews progressed. But it wasn’t so iterative that they got around to defining whether loan files missing documents counted as an error:

Guidance issued to consultants in March 2012 on how to determine whether a borrower suffered financial harm when key documents — such as documents that evidenced that foreclosure actions were taken or loan modification application documents — were missing indicated that consultants should treat those instances as errors on the part of servicers. However, this guidance noted that consultants should defer decisions on how to determine borrower remediation until regulators provided further guidance. In the absence of additional guidance, consultants indicated that they took a variety of approaches, including waiting to make remediation decisions, making preliminary considerations of whether the error might have caused financial harm, or working with their third-party law firm to review any applicable legal precedents. According to OCC staff, at the time of the agreements that led to the amended consent orders, they were planning to issue further guidance to consultants on remediation for borrowers with missing documents and they had informally provided additional direction about treatment of files with missing documents during their
regular meetings with consultants.

In the nearly two years of the review process, OCC and the Fed offered no guidance as to whether missing documents – really a basic servicer failing – counted as harm.

2) There’s a lot in here on sampling methodology, which the regulators clearly did not care about. Remember that there were basically two reviews, the review of files where the borrower submitted a complaint, and the “look-back” review, based on a sample of files. The regulators didn’t standardize the process, and so you ended up with differences in the expected population error rate (three consultants expected up to 10%, and eight of them assumed 0%, which completely changes how the sample gets viewed), the sample size per loan category, the categories themselves, and the review parameters. This effectively rendered the samples meaningless, at least as a comparative matter. When asked about this, OCC let loose with this gem:

OCC staff told us that their handbook on sampling methodologies—a reference their staff use for sampling and one that both regulators suggested consultants consider in designing their sampling approaches — generally assumes few or no errors will be found in a sample.

GAO explains why this is problematic. In their example, they show that the difference in expected population error rates changes the triggers that would lead to additional analysis of more loan files. Therefore, one consultant expecting a lower error rate would conduct additional analysis if one or more errors were found, but another would only conduct the analysis if five or more were found. Theoretically, they could be looking at the same sample and find the same amount of errors, but one consultant would do additional analysis and the other wouldn’t. It’s another way to game the system, filtering the sample methodology to ensure less rigorous analysis, for example. This is a great excuse by the Fed:

According to Federal Reserve staff, they anticipated that consultants would continue reviewing files until the sampling found no additional errors. However, unless a large majority of the population is examined for errors, reviewing files until sampling finds no more errors does not necessarily imply that all or most errors would be identified.

3) If the GAO’s analysis of how the payouts of the amended consent orders will work is at all accurate, we’re on the cusp of yet another train wreck. They’ve apparently learned absolutely nothing.

• They haven’t decided aspects of the reviews for SCRA violations and foreclosures on borrowers who weren’t in default
• They haven’t determined payment amounts for the different broad categories of borrowers
• They haven’t figured out what to do with leftover funds not claimed by borrowers
• They haven’t figured out the loss mitigation procedures for servicers, or criteria for what borrowers will be eligible

So here we go again.

GAO Report on the Independent Foreclosure Review

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53 comments

  1. Conscience of a Conservative

    I believe that the regulators(primarily the Fed, but this extends to the OCC, etc) are continually conflicted in their desire to see more lending and see banks with growing earnings versus their regulatory role which means there is no fraud in in the financial system and banks are not not taking undue risk putting the system at risk.

    Time and time again, they view the regulatory role as producing restrictive credit. I suppose they ask the banks, what can be done, and the banks respond(loosely paraphrased), “Don’t enforce the rules’.

    If the OCC had held the banks accountable the thinking goes, the banks would have paid out billions in fines, and would have walked from future mortgage lending. Just this week, Obama gave a speech intended to jawbone banks to lend more , with the FHA and the White House looking to provide more assurances that banks won’t be accountable if a loan goes bad. The Washington Post writes that it is expected the Dept of Justice would sign on to the agreement.

    1. Susan the other

      MERS will be the biggest problem with that scheme. The government cannot ignore it forever.

  2. Rob Harrington

    THE MAIN FLAW OF THE “INDEPENDENT” AUDITS IS THAT THEY FAIL TO ANALYZE WHETHER OR NOT THE LOANS WERE FRAUDULENT AT THEIR INCEPTION DURING ORIGINATION/UNDERWRITING/APPRAISAL… THE CONTRACTS -NOTES AND MORTGAGES – WOULD THEN BE VOID. IT WOULD THEN BE THE END OF THE WORLD, SIGNALING THE APOCALYPSE, AND THE INTRODUCTION OF THE ANTI-CHRIST (FOR GOV AND BANKER TYPES…)

    1. AbyNormal

      “I would wish you gods speed but I don’t want you to waste time looking for him.”

  3. Bravo

    From Page 45 of the GAO report:

    “According to regulator staff, they are meeting with examination staff and third-party consultants to discuss challenges with the servicers’ data that may make it difficult for servicers to determine borrowers’ direct
    payment amounts under the amended consent orders.”

    Translation: With the planning, design, sampling, management, and regulatory guidance of the foreclosure review process so poorly executed, we’re now looking at garbage in, garbage out data in return for the $2 billion we paid you guys. We can’t make heads or tails of it, much less rely on any of it to figure out who to pay who much.

  4. Mr. Jack Mehoff

    So, why don’t they cut to the chase, instead of issuing excuses and half assed remarks from which no resolve comes forth?

    Obama could just as well issue a decree saying that any and all fraud, lies, theft, and corruption by any TBTF institutions will be totally sanctioned by the US govt with full support of all brnches including military force.

    This would just serve to say once and for all, whats really fact.

      1. monday1929

        HSBC was the open admission of Fascism.

        What are you going to do, gentle NC readers?

  5. Leviathan

    When I was active in local government issues, any issue that was controversial or divisive raised calls for the creation of a “Blue Ribbon Panel.” The BRP was part delaying tactic, part PR cover, and (if all else failed) its results could be manipulated in any way the leadership saw fit. All the real action took place offstage: the timing of announcements (when were your opponents on vacation?), the wording of referendum questions (do you love apple pie or hate America?), etc.

    My point is, this is a game every layer of government plays, but the feds play it best. You can’t win. And this thing drags on and on and on. Whatever role owning a home has played in the creation of a stable, solid middle class in this country, has now been completely undermined. People who strove to pay their bills and play by the rules have become (of necessity) the worst sort of cheats, because that is the only way the government will help them survive.

    And the people who railed against any sort of legitimate help for victims of the housing crisis–mostly renters who felt closed out of buying and those who bought pre-bubble or in non-bubble regions–made their own nightmares come true. By not standing by the real victims in this mess, they allowed government and banks to collude in an extend and pretend surreal fantasy world that produces non-solution solutions and strings people along for long enough to recreate an echo bubble.

  6. TomDor

    The deliberate incompetence ______________(fill in appropriate legal definition) is the tell regarding the implementation of proper review, handled in the manner it was, despite hundreds of years knowledge base aquired throughout history.

    The building of a house goes through more planning than these foreclosure reviews. OCC is only now learning from their experience!!!!! hogwash. No possible way that the foreclosure reviews were simply ‘botched’ because of its ‘complexity’. They claim that they did not know that ‘planning was so important’ to the outcome is reprehensible and incompetent at any level.
    No – the reality is this review was a sophisticated plan to fail. A sophisticated plan to hide culpability…culpability of fraud by the enabled oligarchs of finance. Designed to further a system of economic rent extraction and power consolidation. The plan and implementation of the review was designed to created cover for the politicians and wall street criminals who plunged our economy into an abyss. The overarching truth is that fear (fear of economic, social and political failure) is being used as a tool by the uber criminal class (the true parasites) to pervert our constitution, our laws, our wealth so that all benefit their continued reign and plundering.

    We have elected people to represent us and, they continue to do no such thing. It is time to call them out for what they are….cowards for the most part, scared of their own shadows. If we are electing these folks… do we really want them to represent to the rest of the world that ‘we the people’ are a bunch of cowards?

    I apologize for ranting myself into a corner but, I am exasperated.

  7. OMF

    Heh. Nice one the GAO.

    My own take on this is that “backwater” office like the GAO and Comptroller’s office are too far from the revolving door to have yet been infected by Wall Street shills, and instead are staffed by people who don’t have any problems with actually doing their job.

    It’ll only take one Goldman appointee to reign this kind of thing in though. These kinds of offices are about to become very observed ones in the coming years.

  8. steelhead23

    Completely off-topic and with a bit of hero worshiping, I wonder what Dr. Martin Luther King would have had to say about such things. Pardon me, but I have his words on my mind this morning. He was murdered 45 years ago today (April 4, 1968). A part of America died that day and we are struggling to get it back. Go with God Martin.

    1. just me

      Not forgotten: http://www.emptywheel.net/2013/04/04/fast-food-workers-reclaiming-mlks-legacy-by-striking/

      NYC fast food workers striking and meeting with some of MLK’s 1968 Memphis sanitation worker strikers for inspiration.

      http://www.theatlantic.com/business/archive/2013/04/the-mcjobs-strike-back-will-fast-food-worker-ever-get-a-living-wage/274645/

      The date, April 4, holds special meaning for the workers and many of their supporters in the community. It is the anniversary of Dr. Martin Luther King, Jr.’s assassination in Memphis, Tennessee. King was in Memphis to support the strike of the city’s sanitation workers, whose “I Am a Man” signs made clear that their labor struggle was part of the larger civil rights fight. Last week, two of those strikers, Alvin Turner and Baxter Leach, met with some of the fast food workers to share advice and inspiration.

  9. Paul Walker

    Error rates of 11%?! What a pile of selective crap. Inside initial contracted mortgage packet washing operations error rates run between 70-98%. The DOJ, Fed and other key players are well aware of these error rates so I would add the DOJ and Fed to the OCC on this as suppressing the rule of law has been and remains a key national security impperative.

  10. tnt

    this is all a bunch of crap.. you knowObama started this he needs to end it.. there’s no amount of money that can take away the hurt that these banks have done to us. they took the American Dream and is mainly shoved it up our asses.. I’m so angry and fed up with all of it the pain the humiliation these banks have caused us it’s time for justice it can’t go on it needs to stop.. this is America we need to fight back we want our homes back.. I was reading on the Ripoff Report about this rust consulting there a joke some people have been waiting two years to get a settlement from these people they sure were in a hurry to take my home why can’t they be in a hurry to pay us back for what they done to us this is America people we need to fight back there’s got to be more we can do but no all we can do is sit and wait by our mail boxes for some checks that were probably only going to get $200 is that all we’re worth another thing that makes me so angry what makes a service member home worth more than mine why are they getting most of the money I’m not being greedy but were Americans just like they are. we did everything the banks told us to do don’t make any payments we’re going to put you through a trial modification and they deny you after all that.. screw the American Way it’s time to fight back..

  11. 2little2late

    All of these charades would be humorous if they weren’t diverting attention from the underlying causation; widespread asset stripping through millions of fraudulent criminal acts, which cannot possibly be reduced to a small payout parlor game. Why doesn’t Curry just go to the OCC podium and call out…E59…..A47….at least there’d be some semblance of order in that.

    The IFR, combined with the 49 state AG settlement (add the installment of MERS without consent) are tragic firsts in U.S. history; the granting of widespread immunity to prosecutions through ordained criminality. The OCC might as well be holding millions of borrowers naked while the banksters do their Uncle Gropy routine. Did we learn nothing from Abu Ghraib?

    Not only was the home I hand-built stolen through fraudulent paperwork when the bank’s motion to dismiss was jubilantly signed off by the federal judge known to sign off on anything placed in front of him by the banksters, in addition, my credit was totally trashed in the process through yet more illegal acts and false credit reporting. This multi-pronged attack had the effect of crushing my successful, decades-old remodeling business into so much dust and debris, thus guaranteeing that I could never mount an effort to fight back or mount an appeal. Ever tried to run a business dealing with hundreds of subs, vendors, and clients with cash only, owing to the fact that a checking account/credit card is verboten thanks to the banksters false credit info? Believe me, it’s impossible. They hold all the game pieces.

    So here I sit in a cold damp camper on a remote hillside in Appalachia, awaiting the day that the OCC finally decides, through the path of least outrage, whether I will receive a check for $250 or $1000 or whatever, in payment for upending a lifetime of hard work through ordained extortion. I enjoyed camping in my youth; I just never thought I’d be spending my retirement years under the stars permanently.

    My only hope is that when Schneiderman finally gets his phone installed, he can fix all these problems as per our benevolent leader’s bold SOTU directive. Until then, pay me no mind when I stay seated during the national anthem.

    1. Wake Up America!

      “Until then, pay me no mind when I stay seated during the national anthem.”

      Well said and I echo your sentiment. I too had a front row seat to government sanctioned theft.

      It’s bad enough to have your home stolen but then having to try to pick up the pieces when, as you say, they hold all the pieces……. It becomes almost impossible to open a bank account, get a credit card, affordable insurance, an apartment, etc.

      The next time I’m at a baseball game, I think I’ll stay seated and leave my hat on when they play the national anthem.

      “O’er the land of the thieves and the home of the knaves.”

      1. 2little2late

        I went to open a checking account at a smaller community bank during the five years I duked it out with BofA. The overly-cheery lady sat me down and explained that it was my lucky day….as everyone opening a checking account that day would receive two free hot dogs and a large soda. I must have looked like she just told me my dog died, as I couldn’t put that bizarre rewards perk together with opening a checking account.

        In exchange for succumbing to their world of fraudulent securitization and grafted politicians, I could eat two tubes of antibiotic filled CAFO slime, and wash it down with a genetically modified pesticidal high fructose corn syrup drink. It was definitely my lucky day. Where do I sign?

        Then the cheery lady returned with a dire look on her face, and explained that she couldn’t open the account, but that she appreciated my coming in. She refused my inquiries as to why the sudden reversal of fortune. I pushed her. Finally she explained that I had rolled snake-eyes with ChexSystems, the credit reporting system. I was credit-unworthy. Outcast. Doomed for life to the tent city in the brackish swamp on the other side of the rails.

        “Does that mean I don’t get the hot dogs?”

        1. Wake Up America!

          The hot dogs were no great loss. They were probably made from mechanically separated beef. Sort of like how notes become separated from the deed.

          I also duked it out with BAC. Would love to compare notes with you if there’s a way to get in touch.

  12. tnt

    may God be with all of us.. that’s all I can say.. I know how you feel.2little2late. when the sheriff evicted me and my family from our home we were left to live in our motorhome also it’s not right they should be punished where in the hell did all of our money go none of the money that we paid towards our home went towards our payment.. all we can do my friends is pray.

    1. Jmac

      I pray. I pray hard. I will say that I know what Jesus would do, because he did it in the courtyard at the temple…the greedy will someday have to pay with eternity. If God needs my home to make his case against the greedy, so be it, but I don’t have to like that it is happening to me. All I can say after losing everything, (including my husband’s life since that is what put me in foreclosure in the first place), is that blessed are the meek, because we shall inherit the earth. I can’t wait till the end times to see those greedy snakes trying to come with us!

  13. Susan the other

    The whole fiasco achieved the ends they designed. But the public didn’t buy it. What a shame. All that feverish work to pretend to be making borrowers whole for foreclosure no-nos. Looks like just a big charade to distract us while they attempted to erase all the incriminating evidence of missing notes, multiple simultaneous rehypothecations of collateral, improper securitization dates and procedures and clouded titles.

    1. Brooklin Bridge

      Actually, it seems to me the public DID buy it; hook, line and stinker. I’m amazed at how few people think the banks were in any way to blame. They may agree that banks are too big (that’s an easy concept to grasp and doesn’t challange authority), but they are almost completely unaware of anything else, even that there was a review process, for instance.

      For most people, the whole thing can be summed up as:

      1) There was a crash and the government threw massive amounts of money at the banks.
      2) Some banks are too big but there is nothing anyone can do about it any more than they can do something about hurricanes or earthquakes.
      3) There are a ton of dead-beats that have been thrown out of homes they couldn’t afford.

      And further summed up as, the work ethic in America has declined dramatically.

      1. Susan the other

        You’re probably right. i just caught the last half of a cspan interview with Janet Yellen and the very first question was about the GAO report. She handled it adroitly. She said that there were simply too many aspects of the review process which served only to slow it down and so the Fed decided to scrap the whole thing so it could get money to injured borrowers faster and that they were in the process of doing just that. It was actually a staged question because she read the answer from her notes. Nobody followed up with, Well how exactly are you going to determine the level of harm to these borrowers? Because not very many people have questions that go beneath the surface, Yellen can get away with her answer.

  14. tnt

    well I’m going to go sit down by the mailbox and wait for the mail run maybe I will get my big ol fat check today from rust consulting I know it’s just going to be another let down but its worth a try. everyone have a great day.

  15. tnt

    it all started back in 2007 or 2008 times are hard for everybody at that time people are struggling to make it everyone’s trying to pay bills to make the house payment the stock market crashed the housing market crashed it was really rough for everyone then the banks came up with the loan modification and everyone thought wow I can final. ly get through this. they can lower my interest rate they can lower my payments too good to be true my friend we applied for the loan modification they told us we needed to be behind three months behinddon’t make any more payments at the time yet sounds a little fishy but we were desperate. okay then they tell if they were going to put it through a trial modification at the time with auto payments were going to be lower but they weren’t they jacked them up to 900 a month we made those payments for 9 month through this trial modification then we get a letter in the mail of denial you don’t qualify for a loan modification wow what the hell all this time we’re paying them $900 a month none of that money went towards our payment nor towards the interest now by this time were nine months delinquent on our house payment I totally want to puke now this time we’re getting letters in the mail from Chase telling us we’re going to sell your house on the courthouse steps we got these letters for 6 months talk about a hit to the gut in March of 2011 the share come knocking on my door you need to get the fuck out you’re being evicted I’m sorry I don’t mean to cuse I really think we would have been better off not knowing there was a settlement this settlement just brings up the memory of us losing our home and what these banks have done to us and I know there’s millions of people out there today that are going through the same thing that me and my family went through and it’s just not right these banks lied to us took our money and then took our homes

  16. kevinearick

    Internet Winter of Discontent

    The Internet is designed as a bomb, a slow-motion DNA bomb. Making proprietary systems, MS- etc, transparent closes all the exits, devaluing all national currencies, relative to emerging currencies. As a day trader, your last trade pair should have been with bitcoin. If you look, however, you can already walk onto properties and take them over to produce income, shorting the system more directly, at greater return. Regardless of the published data, the die-off is picking up steam, because the empire scale demographic Ponzi has hit the wall, and its participants cannot provide for their children. No children, no pension. Bernanke is simply piggy-backing to slow the descent of the US Dollar for his keepers, which are hoping, in vain, to hop onto another host.

    Have you ever been on an elevator that tried to go up, down, and change speeds simultaneously, just before it stopped mid-floor? It’s quite an experience. That happens because of ac backlash in the dc system. ThyssenKrupp is the worst because its implementation is the most arbitrary. It has many programs running the same product, making it quite difficult to determine in advance which resistor will pop, and it has many redundant resistors, hoping to bypass the backlash, increasing its probability, and its product material is quite cheap, pretty much ensuring stability, right up until it loses control. All of these governments are built the same way.

    The nuclear problem is similar as well. Not only are there a multiple loops between the guidance systems and anti-missile systems, but there are also “anti-“missile systems out there that the governments know nothing about. One too many nukes and they start flying all over the place, out of control. There are also submarines out there that no one is tracking, among other weapons. At some point, the pressure will become too great, and the real sh-show will begin.

  17. Westcoastliberal

    This was, as Geithner explained the real purpose of the HAMP program to Barofsky as outlined in the latter’s book, just another attempt to “Foam the runway” for the Banksters.
    Spending $20,000 per review to dole out a $200 check to the screwed-over homeowner? That’s our government at work!

  18. Marilyn

    Loan initiation issues more than likely exist on a majority of these loans. (example – Countrywide)…Loan officers and banks were known for saying “If they are breathing we can finance them” and that was the beginning, then appraiser and realtors looking to make a buck pushed the envelope to whatever the market will bear…making the numbers work, causing prices to artificially rise….THE BUBBLE…There is enough blame to go around. Many of the homeowner’s knew what they were doing (ie stated income loans, forged documents) but wanted to buy a home. To make matters worse everyone seems to be forgetting there are still many many homeowner’s in jeopardy of losing their homes and there are many homes that will still be foreclosed and this will have an impact on the current housing market. Housing market coming back… or is that just PROPAGANDA and HYPE…we will see. Let’s not forget all of the Housing Counseling Agencies stood to make lots of money too (millions). However there were some people injured through no fault of their own and I am hoping they do get the justice they deserve.

  19. Marilyn

    Loan initiation issues more than likely exist on a majority of these loans. (example – Countrywide)…Loan officers and banks were known for saying “If they are breathing we can finance them” and that was the beginning, then appraiser and realtors looking to make a buck pushed the envelope to whatever the market will bear…making the numbers work, causing prices to artificially rise….THE BUBBLE…There is enough blame to go around. Many of the homeowner’s knew what they were doing (ie stated income loans, forged documents) but wanted to buy a home or possibly take cash out of their home for the 2nd, 3rd or even 4th time. Let’s not forget that in some cases the homeowner took the equity from the home to spend as they saw fit not worrying about the future and frankly the economy did benefit from the free flow of cash at the time. To make matters worse everyone seems to be forgetting there are still many many homeowner’s in jeopardy of losing their homes and there are many homes that will still be foreclosed and this will have an impact on the current housing market. Housing market coming back… or somwe hear or is it just PROPAGANDA and HYPE…we will see. Let’s not forget the millions of dollars given to the Housing Counseling Agencies “helping” to save all these homes from foreclosure. How many do you think actually were saved and at what cost. The money spent going round and roung is in the billions. However there were some people injured through no fault of their own and I am hoping they do get the justice they deserve and I dont mean $250.

  20. Johnny

    The American dream

    The problem of owning a home today is that you never really own it since the Real Estate taxes today per month are equivalent to what the monthly house payments use to be in the mid 80’s. Since home values are up 600% in many areas over the last 25 years the interest rates are not all that affordable even at 3%. It’s like we are paying 18% now instead of the traditional 10% of yester year.

    80% if working class Americans have lost ground with real wages in the last 30 years. It is harder to find a full time job that you can depend on. Few have a pension plan and almost everyone these days have to provide their own family health care insurance. Inflation has also hit with the price of cars, food, fuel, electricity and health care. The fact is if it were not for inflation of the last five years our GDP would likely be half of what it is today. If Ben were not pumping 85 billion a month into our 14 trillion dollar economy our GDP we would be down another trillion a year. Now with Sequestration in place folks need to get a grip on their ankles and hold on. Change is Cumming.

    No one trust their Banker, Broker, Politician, Minister or Realtor these days let alone the Media, the Internet or Nature. The court system, legal system and all the government protection agency’s seem to be for hire. Our school systems are cheating the test scores and athletes are gaming the system. Bend over, Relax, change is Cumming.

    The Grand Bargain is now on the horizon coming at us like a Black Swan. The Tin Man has all the bullets he needs and Jack is up in the Bean Stock crying a river of rain. Have you heard? Goldie Locks is dead. Alice in Wonderland has dementia and the Rotary Oscillator tipped over in Shit Crick and things are getting messy worldwide.

    Oh happy days!

    Johnny Lunch Box

  21. Byron godwin

    I am so upset with this created nightmare. can anyone tell me if a loan should have been funded December of 2006 based on rising home prices that were not really rising in atlanta. Just trying to figure when did prices start to fall off

  22. Darla

    The more I read these articles, the more I want to pull my hair out. Just give us our money already you bullies!!

    1. LifelongLib

      You don’t understand. As far as the wealthy are concerned, it’s THEIR money. People like you and me stole it from them with unions, minimum wage, Social Security, the GI Bill, government employment, Medicare… Without those things we’ll have to work for next to nothing and die when we’re no longer useful. Which to the wealthy is how it should have been all along. They’re just getting back what’s rightfully theirs.

      1. Faith

        Interest rates are low but none of us can afford after being scammed by HAMP.

        With our credit destroyed and no equity left are homes are ripe for the picking.

        Those low rates are for rich investors to buy in bulk and make even more $$$
        while stealing our homes.

        Do not fall for the Short Sale Scam.-Stay in your Homes and fight!

        They are trying to bully you into selling so they can fix their fraudulent trail.

  23. Hanusia

    One think I don’t understand , how can they put people in to different categories of harm if they don’t do the acctual reviews ? My understanding is that they have no idea if how many people are harmed , so they should see how many people had foreclosure from 2009-2010 devide the settelment to all those people equally and done . It then will be fair and square . No one would say that got more or less . EVEN . I don’t know if you people agree but that’s the only logic I see .

    1. Mad as hell

      I so agree with you! I looked at the Remediation Framework and it is a dang joke. We are subject to get the scraps of what’s left in this whole ordeal. The military personnel are at the top of the charts and seem to be the only ones alllocated to received the $125k, well, I disagree. I lost my home because my mortgage servicer sat on their behinds and just kept asking me for the same documents that I had already sent. They never offered me a modification, I had to ask and then play they paper shuffle game, and all the while, they were processing my home for foreclosure. I never received a modification. I was right in the middle of my third attempt to get one when the ax came down.
      Those of us that actually “lost” our homes, are at the low end of the Framework. Why???? They took our downpayments, charged extremely high interest and sold us the homes for much less than they were worth.
      I’m sorry, but $250 – $2k is like saying to me “oh well, so you lost your home, here’s some chump change. Go have dinner and a drink on us. This is our tab. They should be ashamed. We don’t matter in this whole darn game. We had to rebuild our lives, accept whatever place that would let us in after foreclosure, relocating, illness of mind, taking our life savings to keep our homes, loss of funds (retirement, etc.), all because nobody gave a damn about what was going on with these darn banks! Now that you say you are going to give us some relief, I feel like you just slapped me in the face again with what you are offering us. Make them give back what they have taken! Where is my home, can I get it back????? At least give me back what I paid into it, they stole my house and I want them to be prosecuted to the fullest extent of the law and make restitution- damn it!
      They need to rethink this entire framework, speed up the process and pay for the mistakes and unconcerned attitudes they had for screwing with so many lifes!!!!!!
      I’m so pissed and they could care less.

      1. relief will never come

        mad as hell:
        I was in the same predicament! I hear you loud and clear! I went thru exactly the same thing you did, as far as the modification….paper shuffle is right! I called one day to check on my loan, to my (not) surprise it was sent to Foreclosure! I immediately filed Bankruptcy and have been in that hell for 5 years! So yes, I agree why are some people entitled to more compensation than others!! Just another slap in the face! I filed bk because I had so much equity built up in my home and did not want to lose it….but after the 5 years of hell my family has been in…. I honestly can’t say it was worth it!!! :( Now there is an additional 5 billion set aside to help borrowers with mortgage assistance! Yeah well good luck trying to find someone/anyone who has any knowledge of how a borrower is to get this assistance!!!! Unbelievable!!!

  24. Carlee

    I don’t understand. I thought the lowest payment they would send out was $500 not $200 or $250, but I’m seeing a lot of those numbers did the amounts change?

  25. belinda crawford

    well well checks go out april 12, 2013 lets see how they pull their stunts waited all this time let’s see what we get probably pennies.

  26. derrick haley

    I filed a complaint directly to the OCC 11-28-2011 and was given Case #01887017. I also filed for review of my foreclosure in the Independant Foreclosure Review 12-28-2011 and was given Ref.# 1811662791. The case filed with the OCC should have concluded in about 90 days.The OCC deliberately held up giving me a decision for over a year and two months pretending to need information from BoA they already had. Finally on January 30, 2013 I recieved a letter from the OCC stating that my case with the OCC was being dismissed because it was in the scope of the IFR. I filed an appeal. Prior to the dismissal I had been told by the OCC Houston Office Manager Ms. Melinda Goodnight that Mr. Larry Hattix had instructed them not to review my case and to dismiss my case and all cases like mine were to be handled that way. In other words the OCC has thousands of claims filed directly to them like mine they refused to review and dismissed to keep the harm the servicers did to us hidden. My case filed with the OCC was dismissed January 30, 2013 because it feel in the scope of the IFR. By the way I am one of the 53 foreclosed on who was not in default and one of the 2800 original cases reviewed by the OCC in 2010. They did nothing then or now, The things done in regards to the IFR were conspired and more than poor management at work. I have much more proof of this. I am also one of 250 borrowers complaints reviewed by 39 state attorney generals in 2009 which was posted on the internet April 29,2009. Check it out AG’s Take Action on CWN Reports of Foreclosure Abuse. Nothing was done to stop what happened to us by any of them. Our home was sold October 5,2011 to my home church, who tore it down to build a life center.The banks controlled it all. We had one of the first post in August 15,2008,Check it out Countrywide Cashing in on Surprising Group of Homeowners | The Consumer Warnin The OCC, Louisiana Attorney General and Louisiana Office of Financial Institutions all had these internet post and over 50 pages of evidence concerning our complaints and did nothing.

  27. Ellen

    It is continually sad to me, to realize the dishonesty, deceit, and full out lieing that keeps this process injuring Americans over and over. WE UNJUSTLY HAD OUR HOMES TAKEN FROM US! Does it not matter that I now pay almost double the amount of a house payment to a landlord? Or that I have no credit worthiness to “begin again?” Maybe the fact that I’m in my mid 50′s and will not have the opportunity to take out a 30 yr mtg. in 10 yrs? Even tho our income has risen (due to our accepting promotions by relocating 3 times around the U.S.), we cannot qualify for much of anything, much less a mortgage. Savings? no…that goes toward the enormous rent we now pay to fund someone else’s retirement. Our mistake? Trusting our mortgage company, when we went from 2 incomes to 1 (due to medical issues), and they told us we had to be 2 mos. behind to receive a modification…we did, and then they denied it and unless we had the back payments, PLUS late charges, and “penalties.” So, thinking it was “better” to short sale, we actually got a good price on the home, plus the mtg. co. got money from the government for a mtg “guarantee.” So, in the end, the mtg company actually received MORE than they were owed….and we lost our “forever” home. Now, for THAT, we may get a check for $250.00….whoopee!
    Come on, politicians…do something that just might make a bit of a difference in our lives to help fix this incredible wrong. Quit giving the $$$ to those who stole it in the first place!

  28. dee

    I am blaming all the politicians who let the banks ruined our lives for this. And when I go to heaven, you greedy ones will be asking me for a drop of water.

    1. relief will never come

      Hanusia, I unfortunately was with Morgan Stanley therefore have NOT received a check!! And don’t know when I will?! :(
      How do you think they came up with $1000.00 they issued you. I know it’s not what you deserve but I’m happy You received more than the $250.00 everyone is receiving!? :(

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