Bending the Rule of Law to Help the Banks: Effort to Draft a National Foreclosure Statute Underway

There is a slow moving but nevertheless troubling effort underway to change foreclosure laws across the US. The Uniform Law Commission, the same body that created the Uniform Commercial Code, a model set of laws that sought to harmonize commercial laws in all 50 states, has had two full day public but not well publicized meeting of a “study group” on mortgage foreclosure. Note that it took over a decade to draft the first version of the UCC and a protracted period for it to be implemented by states (most states have adopted the updated version of the UCC, although certain articles of the new version have not been implemented in any states).

Given its august history, one would think the ULC would be above political influences. That would appear to be a naive assumption these days. The study committee’s public meetings meetings to solicit opinion from “stakeholders” on “problems” with foreclosures. Curiously enough, these “stakeholder” meetings had no representation of investors (Tom Deutsch of the American Securitization Forum would claim he played that role, but everyone in mortgage land knows the ASF is a sell side organization) and effectively no input from homeowners or consumer advocates (none at the first meeting, and only, at the second, in Washington last week).

I got reports from three people who attended the latest session, in Washington, last week, na all were disheartening. Tom Cox, the Maine attorney who broke the robosigning scandal, provided a memorandum that argues that the commission has effectively assumed that the “problems” require a legislative solution:

Before there can be a determination made as to whether there is a need for a new uniform act dealing with foreclosure issues, there must be an clear accounting of (1) what the problems are that cause legislation to be considered, (2) what has caused those problems to occur, and (3) only then, whether the problems lend themselves to a legislative solution that would be offered by a new uniform act. Unfortunately, it appears that the JEBURPA letter of May 30, 2011 and all of the subsequent steps leading to this stakeholders’ meeting have failed to conduct the step 2 analysis. Further, it appears that the assumption has been made that new legislation is the solution to the perceived problems without there having been analysis of whether other non-­‐legislative solutions might be more appropriate.

I suggest you read Cox’s memo in full:

Thomas A. Cox Memo for ULC Study Committee

Cox provided a detailed account of the January 13 meeting. Despite the fact that he and the academics present (including Kurt Eggert, Adam Levitin, and Alan White) all argued that the there is nothing wrong with existing laws, the problem is that they aren’t being followed, and a new statue won’t solve that. (Interestingly, the senior counsel of the American Bankers Association was the only other party present to speak against the initiative. Some participants, namely Judge Mize of the National Center for State Courts, and Dennis Ceuvas of the National Association of Attorneys General, said they were neutral).

The most disturbing part of Cox’s report is that this plan is NOT to develop a model statute, a la the UCC, which state legislatures would then have to approve, but that Professor William Breetz (the chairman) and member Barry Nekritz (the American Bar Association representative to the Committee) want to create an overlay statue. Moreover, he was apparently the only person in the room with any foreclosure experience, and a considerable amount of disiformation was conveyed by industry participants.

His comments were considerable more moderate than those of another observer, who wrote:

I wanted to vomit. I don’t think it’s going anywhere fast, but I wanted to scrub off the subtle corruption that permeated the area.

Cox also reported his understanding is that the Study Committee is making a recommendation that a uniform act drafting process begin and that ULC president Michael Houghton and executive director John Sebart are keen to see the project move forward.

Not only is it disheartening that this sort of effort is underway, but its slow timetable and largely invisible nature (until it is too late) will make it hard to organize against it. At a minimum, investors and consumer groups need to make their voices heard. The idea that elite attorneys from banks, financial services lobbying organizations, the Fed, and academia amount to “stakeholders” is offensive and absurd, particularly on an issue of importance to most citizens, the integrity of the laws protecting their biggest asset.

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  1. Lafayette

    At a minimum, investors and consumer groups need to make their voices heard.

    Goodness me, isn’t that the reason we have a Consumer Protection Act (CPA, Pub.L. 111-203, H.R. 4173) signed into law? Must we go into the ring again? Why does foreclosure of consumer debt not fall within the purview of that agency? And is it not a participant in these meetings?

    What? The CPA was yet another measure without prosecutorial teeth? A sop to the malcontents who were harping about consumers being ripped-off?

    And, long before foreclosures, was there not a Truth In Lending Act (1968) under which no one has been charged?

    What is happening to this shadow of an AG? He thinking perhaps of getting elected one day and does not want to upset corporate apple-carts?

  2. Middle Seaman

    Tom Cox is fighting a good fight in a losing cause. The very serious people have decided that forclosures suffer from many ills such as delays, being thrown out of court and large loses to lenders due to the lack of a 1-2-3 law that will make everything foreclosure function like an expensive Swiss watch. That is the rich people elitist attempt to continue to add bricks to the wall enclosing the badly behaved middle class and poor people.

    Clearly, this is the latest attempt in a slew of others that push the American cart down the slippery slope with strong support of our elected officials. One wonders whether we can stop the cart without resorting to violence.

  3. Richard Kline

    Yves: “The idea that elite attorneys from banks, financial services lobbying organizations, the Fed, and academia amount to “stakeholders” is offensive and absurd, particularly on an issue of importance to most citizens . . . .” I agree with your visceral response here, Yves; rather despicably, the Congress does not in any way. At this point ‘stakeholders’ is Beltway code for ‘factions of the 1% + institutional players.’ The citizenry are definitely _NOT_ considered stakeholders by the Congress, in any way in anything. Not even hoi poloi but a vast sub-peasantry bereft of relevant contribution dollars, statute-gaming terms of art, and more than farcical leverage. I don’t see the language you caught here as a slip up: this is how the Beltway class really thinks, now. It’s like the invisible imposition of a property qualifiation for having a ‘vote’ in any policy discussion. If you or your institution aren’t holding at a minimum of seven figures, you aren’t qualified to ‘vote,’ i.e. participate in policy formation.

    To me, this goes a long way to explaining the far-beyond-tin-ear of the Congress for how hearings and policy now play with the public—the Beltway class _doesn’t care_. They don’t need chickenfeed donations to feed coin into the meter of the electoral cycle anymore, and if the votes aren’t (quite) there the line of no-scruple-remaining against simply faking votes was passed a dozen years ago with no one at the apex of the political class caring anymore. The political class in the US simply doesn’t see the vast majority of Americans—to the number of 99% at least—as political holders of the franchise. Congress and the political class are talking ONLY to factions of the 1% at this point in so far as I can tell.

    We haven’t been enslaved: we’ve been sold out. The parties are irrelevant because the political class as a group have deserted the citizenry for the City of Mammon. That’s my view . . . .

    1. Lafayette


      The parties are irrelevant because the political class as a group have deserted the citizenry for the City of Mammon

      Not so, they are very relevant and our present predicament is not hopeless.

      Parties exist at the will of the people. We all dislike “party politics” but the reason that a groupuscule can dominate a party is because they have the reins of financial power. That is, they can select candidates for office by blessing them with financial support – or not.

      It is for this reason that the present political class has been very largely corrupted and the very reason why we must stop the cancerous rot.

      That can only happen if we, the sheeple, decide to vote Progressive Politicians into Congress willing to change the “game rules”. That is, outlaw PACs and all means of directly funding candidates by corporations – who would be left to funding only one type of political program (as a tax reduction) and that would be to get-out-the-vote. (Which is sadly lacking in our politically apathetic nation. See our Voter Turnout record here – be sure to scroll down to the bottom of the list to find the US.)

      If we can outlaw the “financial gaming” of the political process, we shall have taken a great stride towards stopping money’s bad influence in politics.

      MY POINT

      First, however, we should ask ourselves this question, “Why is money so important to politics?” Because it runs campaigns. How’s that? Because campaigns get out the vote and also help “form” public opinion of a candidate, largely by means of Media Messaging.

      So, the further question is, “Why do we, the sheeple, allow ourselves to be manipulated in this manner?” Negative messaging and outright defamation seem to work wonders for a candidate.

      When, in fact, we should be more concerned about a candidate’s platform, that is, the nitty-gritty of what they propose or support in terms of policy-making and why is such policy necessary to our well-being. They must convince us by good reasoning, solid arguments based upon fact … and not impassioned bias or underhanded skullduggery. (Like the “swift-boat” trickery employed against Kerry by the Bushites. See here.)

      But in a world where representative government has gone berserk having been influenced skillfully by financial power, the above paragraph seems immensely naive as regards the facts on-the-ground.

      And yet … we are the people who vote. When we vote, that is. So, in fact, we have no one to blame but ourselves.

        1. Lafayette

          AD NAUSEAM

          Typical response – for a victimization fan without the slightest notion of democracy.

          Yes, we put these Ignominious Idiots in power (by our own neglect at the polls) and we can take them out (by our own concerted will).

          But, of course, if you think politics is a spectator-sport, as most Americans seemingly do (since so many stay away from the voting booths), then all that is left to salve the injury is bitching-in-a-blog.

          And if we cannot coalesce behind some standard a lot more meaningful than indignation, then nothing will change in Congress and very little in the presidency.

          Which means another four years of gridlock, maybe 8 years, to come – as our standard of living worsens and worsens and worsens.

          Ad nauseam …

          1. Foppe

            my dear chum, all you’re doing is apologizing for the status quo by suggesting that it is primarily through laziness that they got there.
            Historically, it seems to that the primarily reason for the rightward move of the dems was because a whole bunch of people let reagan and consorts get away with destroying the unions. This meant the dems had to start looking for different donors, which they found in big finance. Now, you can blame the public for not noticing that political parties work this way, and that it’s just a case of bribing a party first or best, but by now it is certainly the case that there is little chance that the neoliberal power base in the democratic party will be unseated, except by attacking the very idea that political parties and elections should be allowed to be funded privately.
            More fundamentally, though, the whole anti-labor ideology has to go; if you want to know why, read Mark Ames’s Going Postal. Yet this isn’t happening, and one of the reasons for it is because many people seem to think they deserve their place on the bottom, or at least they don’t accept it when others suggest that they do *not* deserve their place. And you are doing your mighty best to reinforce that notion, by doing nothing but hammer on the fact that all of the criminal actions taken since Reagan took was elected occurred simply because people voted for the wrong 1%-sponsored candidate. In other words, you’re being simplistically patronizing beyond belief, while encouraging people to feel far more personally responsible than is in any way reasonable.

      1. lafayette

        That was another time long, long ago.

        I suspect that modern-day plutocrats are completely indifferent to the consequences of their fellow citizens.

        The haven’t one moral bone in their spineless body. They slither through life, never upright, and think they do not need one.

      2. Richard Kline

        So Lambert, I’m in sympathy with your perspective here, and I’m sure it applies to some of the political calss. Rahm Emmauel; yeah, I’m sure he groove on making life harder for ‘the proles.’ Jim DeMint, Orrin Hatch, the soulless wax-fax labled Ryan in the house stealing pennies from paupers and snickering at them; yeah, all of them, and dozens more. But these are ‘special’ kinds of squeeky geeks. Most pols in my view are in far too much of a frenzy to get themselves paid off and promoted to care whether the proles suffer or not so long as the citizenry stays our of the way while ‘serious people’ stuff their pockets with loot; kind of a ‘dust beneath our chariot wheels’ kind of thing.

        The political class has become the kind of bastard klepto-aristocracy which gets itself wholesale in various places and times. I’m just sayin’ . . . .—that they have it coming should it come to that. O’ course, they’ll off a large bunch of of first, these things are messy fer sure. Better to make change than ’em sorry, is my view.

        1. Lambert Strether

          Richard, I see what you’re saying, but would respond that in a generation we will have a full-fledged aristocracy, and then what I’m talking about will indeed be the norm. We can already see an aristocracy in embryo when we think of all the multi-generational media and political families.

          Also, you speak only of the political class, but they’re not really in charge, are they? The rentiers are. And what is austerity but the deliberate infliction of pain?

          1. F. Beard

            And what is austerity but the deliberate infliction of pain? Lambert Strether

            Yes, there are genuine sadists and deflation vultures out there. And masochists too. And other pathologies too. But there is a lot of gold standard and “government must balance its budget” and “government must tax or borrow before it can spend” insanity too.

        2. Lafayette


          Between a Rahm Emmauel and a Mitt Romney, there seems little intrinsic difference. They are both highly intelligent men who, by determination and hard work, have imposed themselves and their beliefs.

          They are both utterly convinced that their notion of democracy should prevail and would lead to the betterment of all of us in general. It fuels their egos and propels them forward.


          True egalitarian values are the keystone of any society and economic policy choices are made accordingly. What is best for all of us is also best for each of us – even if that means constraining our ability individually to amass wealth.

          In America, we thought to have won the war with Communism – and perhaps we did. But we did not win out against egalitarianism. Europe has become a Social Democracy with egalitarian values. Whereas America is still anchored in the belief of individual achievement – and particularly the outward demonstration of one’s status.

          We worship our heroes (of sports or the arts or business) and find it perfectly natural that their reward should be uncountable riches.Some say that’s fine.

          Others might think, however, that 20% of the households possessing 93% of the nation’s wealth is far, far too much. (One percent of households own, in fact, “only” 47% of the wealth.)

          MY POINT

          Which means what? Which means that whilst you may be earning a living, you are also help build enormous wealth for a minority of the population.

          One would have to be blind to have no problem with such incredible disparity. Is that the sort of game you would suggest your best friend play at a Las Vegas casino.

          Well, it IS the game that 80% of us are playing – and the deck is stacked against us …

  4. jake chase

    The Cox letter provides an excellent catalog of foreclosure abuses, many of them criminal. But the letter’s argument, that variations in State foreclosure laws are a consequence of important variations in State ‘philosopy’ which must be respected for all time, is pure BS. You could have said the same thing in 1860 about slavery, and many people did.

    The fundamental truth about the foreclosure crisis is that greedy originators and greedy banksters and greedy speculators and imprudent consumers combined to create a housing bubble that ultimately exploded as all credit bubbles eventually do. Because the securitization industry used MERS to bypass prevailing legal requirements concerning note and mortgage assignments, foreclosure in accordance with existing state law is now all but impossible. Does this mean a legislative solution is impossible? That depends on whether foreclosure laws create immutable substantive rights in favor of borrowers who certainly did borrow the money and unquestionably used the houses as collateral. That is probably a political question rather than a legal question, but nobody will know for certain until the Supreme Court decides it. I for one cannot wait to hear from that bunch of annointed solons. Somebody please remind me again who they are.

    1. YankeeFrank

      This comment is off base in several ways. First off it repeats the canard that the crisis was everyone’s fault and so it was no one’s fault. That meme has been debunked here and elsewhere (esp. in the work of Bill Black) in great detail so I won’t bother with it now. But this comment needs criticism:

      “Because the securitization industry used MERS to bypass prevailing legal requirements concerning note and mortgage assignments, foreclosure in accordance with existing state law is now all but impossible.”

      The securitization industry certainly did use MERS. But MERS is a completely illegal operation that only “bypasses” state and county requirements because the banks say it does. Furthermore, not only is MERS a flagrant violation of a thousand years of property law but its usage doesn’t even conform to the securitization rules for MBS that the securitization industry itself drew up. In other words, they didn’t just violate property laws in total, they violated their own rules as well.

      Given these facts I will answer your question — yes. A legislative solution to outright criminality, in effect to legislate away that criminality so that bank servicers can happily continue their foreclosure spree, another violation of the law with respect to their fiduciary duty to MBS investors, is completely inappropriate. The appropriate solution is to prosecute the banks and servicers for their outright criminal acts (the ones specified above, as well as document forgery, perjury, bearing false witness, etc.), and to perform loan modifications to avoid both foreclosures (and the deleterious social effects of same) and larger investor losses (also deleterious to society) that are the direct result of the lawless foreclosure over modification strategy of the servicer/banks. That is the solution, not legislation to destroy the state right to manage property rights and cover over gross destructive lawbreaking.

      1. Binky the Bear

        MERS-could it qualify as a racket under the RICO laws, making those who used it accessories?

        1. zadoofkaflorida

          I’m so with you on the RICO thing. The banks own the servicers, the servicers put fraudlent docs in front of “rocket docket” judges called up from retirement, who know nothing about property law, bada-boom-bada-bing you loose your house. MBS that were “sorta” put in to Security vehiciles, sold to pension funds, but they are empty!

          WHERE IS RICO?????????????????????

  5. Jack Straw

    I smell another rat here, but some of the points Iyves makes don’t mesh with my theory – for example, the AmBankstersAssoc opposition – but I’ll throw it out anyway. State law has always been a thorn in the side of the national aspirations of Big Origination/Servicing/Securitization etc.. Worse yet is that local custom creates variability within states themselves. Big O and Big Servicing “BS” tolerated the foreclosure mills presence in the revenue stream because they didn’t have much of a choice. The white shoe Big Law firms don’t do (very much) of the icky work of foreclosure and try hard to avoid the public image problems associated with it, particularly for their alumni who have judicial and/or political and/or social leadership ambitions. Plus, it’s not the kind of work that leads to the big fat bills that those firms are used to. The Big Firms do show up once the $50k retainer checks get written, but seem uninterested in the, say $2300 going rate for doing the foreclosure itself.

    The foreclosure mills, on the other hand, are generally small biz and entrepreneurial, and focused on doing volume work where the margins are exceedingly thin – non-existent for potential competitors without the basic network infrastructure and business judgment for the work. Nonetheless, most markets seem to have a few of these law firms (literally and functionally “vendors”). And usually, the 2 or 3 senior masthead attorneys have made nice income over the last 15 years.

    So, my theory is that at least part of the push for a national overlay is to squeeze that profit opportunity out of the system so that BS can play a more direct role in Big Foreclosure and capture more of that revenue.

    Furthermore – I’m just guessing here – I would estimate that there are about 200 of these small firms who do 90%-plus of the securitized mortgage foreclosures and “somebody” is looking to thin the herd and grab the dough. Another guess is that while it may include the usual suspects, there may be other interests that are not as obvious, like say, legal publications who are eyeing either a threat to the pot of money ($500 – $1000 per foreclosure) they receive from published foreclosure notices (defensive), or trying to fundamentally change how a part of the process is done and be there as a ready beneficiary/vendor (offensive). I wouldn’t be shocked if the big institutional information companies were a large unnoticed presence at the ALI/ULC meetings.

    This is an interesting post and thanks to Iyves for pointing this out. The SloMo aspect of it makes it hard to nail down what is really going on, but it is reminiscent of the 1990s effort that created MERS, admittedly through a very different process.

  6. Susan the other

    A National Foreclosure Statute that is an “overlay statute” covering all existing law with its modifications. So what is an example of this besides the UCC? I don’t think they are trying to do a uniform foreclosure code because they will first have to do a uniform mortgage origination code and a uniform mortgage securitization code. And then they will have to do a uniform mortgage-trust credit default swap code. An overlay statute is an empty idea unless it is a remedy for how we got here. We got here by fraud. In fact we got here by a fraud bubble. Foreclosure law has nothing to do with it.

  7. JS in SD

    From Reuters; Insight: Top Justice officials connected to mortgage banks ( U.S. Attorney General Eric Holder and Lanny Breuer, head of the Justice Department’s criminal division, were partners for years at a Washington law firm (Covington & Burling) that represented a Who’s Who of big banks and other companies at the center of alleged foreclosure fraud, a Reuters inquiry shows.

  8. Paul Tioxon

    When the laws are changed, it is not breaking the rule of law, it’s changing the law. There seems to be some confusion about being politically dominated and some idealized, cherished but non sensical view of the world. The populace is being steam rolled, the rules of the game are being changed for the money power global system, but no one is committing a sin against god and man. What has usually been the case, the world changes with the stroke of a pen. We are just now, more of us, educated, and able to observe the process. The struggle against it begins with awareness that it is going on at all. But it is not bending the law, breaking the law or going over or around or above the law. It is simply the rewriting in favor of those nearly every other aspect of the law already favors.

    1. Bridget

      Yep. I always say, “if you don’t like the rules, don’t ignore or break them, change them”.

      But I’m agin these changes. My own state of Texas has escaped the worst of the bubble, in part because of strict laws regarding home equity loans. Once upon a time we had even stricter laws, but the Big Banks prevailed on the voters to loosen things up in the 1990’s. I smell the banking lobby trying to make their lives easier and in the process eliminate the protections that sane states have built into their real estate laws. Screw ’em.

  9. Patriot

    This possibility has been inherent in our system for a long time. I remember during law school reading the Restatement of Contracts and thinking that it was the kind of thing that would be easy to manipulate. The American Law Institute, ALI, drafts the Restatements. Distinguished (read establishment) attorneys are the members of ALI. The conferences where people gather to draft the Restatements don’t have any disclosure rules etc, because they are not formally a part of government. Therefore it would be a simple matter for large businesses to hire their chosen white-shoe firms and have them push the dialogue in a certain direction. I’m positive that this kind of legislative discussion takes place regularly, orchestrated by big firms in fields like contracts and labor law.

    It probably wasn’t so big of an issue in the past when our elites still had some concept of the general welfare, or public obligation. That’s what built things like the interstate highway system, water distribution, big public transit, etc.

    But, with the rise of the Friedman/Randian discourse taking over intellectual life at the law schools, that has changed. One can argue that the funding for the discourse shift came from industry/finance. They wouldn’t have had a constituency, however, if not for the backlash politics so well described by Rick Perlstein in Nixonland. Simply put, a large segment of white society decided that they did not want to share a common good with blacks or latinos, therefore, they would eliminate the public good altogether and retreat into privatized enclaves. This is very visible in Louisiana. Huey P. Long built a semi-socialist state, using oil money to do big public works programs, and fund the Louisiana State University system. However, post-civil rights era Louisiana renounced such things, and defunded public institutions in favor of private ones.

    It does seem that in democratic systems, some people end up having specialities that allow them to accrue considerable informal power. In this case, it is the attorneys who draft the “model” legislation. With so much in play in a typical legislative session, I can see how legislators would look to institutions such as ALI to tell them how to proceed. Things like contracts and real estate law simply are not big campaign issues, yet the little details are very important. Imagine being a freshman state legislator who previously worked as a non-profit community organizer or small business owner. How are they going to make sense of something as dry as contracts or real estate law? Very likely they will listen to a nice, well manicured man from ALI who explains the model legislation drafted by committee of distinguished practitioners and jurists.

    Maybe that’s inevitable. Ultimately though, the idea of “rule of law” is just another ideology, the idea that people should all be treated in a uniform way by the system, and that people should obey the mandates of said system. That still calls for personal integrity, and at the minimum, a sense of responsibility for the common good in those who have accrued such power. Another thing to think about is the role of the various local power networks, struggling against each other. Now that the USA is more unified economically, and schooling at the university level more uniform, it reduces the amount of inter-factional struggle.

    More and more I think that ordinary people have found freedom in the interstices of freedom that result when various factions do battle. A good example of this today is the fight against SOPA. Very clearly this became a tech/IT industry vs content provider fight. The command of the means of IT production (search, aggregation, curation, p2p social networking) gave a group of Silicon Valley manager/owners a lot of power to shift the public debate, and they did so. Congress backed off pretty quickly once the tech business people mobilized their forces.

  10. Glen

    As an engineer, I plead ignorance to most aspects of the law.

    Then again, how does MERS, as organized and executed, not represent a big juicy RICO target?

  11. stopGOVTwaste

    If we are to allow bankers, for the sake of expediency, to press foreclosure without absolute proof they hold the note (wet ink) and have standing, then property rights in this country are at an end.

    Steve Schwarzman would not stand for it, Carl Icahn would not stand for it, Warren Buffet would not stand for it, and no judge would disagree with them – a homeowner behind on payments is no different just because his lawyer costs less than a billionaire’s; these are fundamental principles that set us apart from the Middle Ages.

    Banks cannot turn upside down the entire reason for our existence as a society and 800 years of progress from the Magna Carta forward – there is no ‘Grand Compromise’ that smooths out the minor detail of not holding the note.

    Otherwise, a lawyer could claim a skid-row bum in NYC for a client and sue in Florida to foreclose on a Palm Beach mansion in arrears; the bum would have as much standing as anyone else, including any neighbor to the home-owner in Palm Beach.

    If the banks persist in this, we just as well replace the 50 stars on Old Glory with a banana and then hold yearly auctions for licensing rights between Chiquita, Dole and Del Monte – that would fit nicely with selling signage to the highest bidder on the side of the SCOTUS building; wasted space begging for a use.

    R. LAW

    1. Lafayette

      Proof! Where’s your proof?

      Otherwise you are just pissing into the wind with such unfounded defamation.

  12. Lafayette

    Before there can be a determination made as to whether there is a need for a new uniform act dealing with foreclosure issues, there must be an clear accounting of (1) what the problems are that cause legislation to be considered, (2) what has caused those problems to occur, and (3) only then, whether the problems lend themselves to a legislative solution that would be offered by a new uniform act.

    And, to do so, we need an all-azimuth Congressional hearing on the matter, with not only Industry Rep’s but also representatives of Consumer Credit groups (meaning the “users”).

    Such “fact-finding” must not be a one-sided affair. (As it is all-too-often in such matters.)

    The credit-industry committed the error of burying ownership of the property beyond sight in the securtization process – now they can be expected to fix it. And, with I.T. data-mining tools, that should become very easy.

    This is clearly a matter that in which the new Consumer Protection agency should take charge of the legislative oversight responsibility and also any eventual application of the legislation. This agency needs teeth.

  13. Gregory Dean Lemke

    We are following this foreclosure crisis to the end for it’s unlawful acts and abuses. We will find reform regardless of these who are trying to stop us.

    Meet us at


    Gregory Dean Lemke
    Advoate for Reform that works for the people, Not only for the too big to fail banks. Unlawful foreclosure acts are a violation of the law period ! We will find resolve in court and or with new laws to protect the public from this kind of continued abuses.

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