- U.S. SECURITIES COMMISSION v CITIGROUP GLOBAL MARKETS INC | $285 Million Citi Settlement With SEC Rejected by Judge Jed Rakoff
- Loreley Financing v. Citigroup Global Markets | Citigroup Sued for Fraud Over $1 Billion of CDOs
- Morgan Keegan to Pay $200 Million to Settle Fraud Charges Related to Subprime Mortgage-Backed Securities
Matt Gardi | Save the Teachers! – Divest from Fannie Mae
Wells Fargo files Unlawful Detainer to evict DEADBEAT owners who strategically defaulted… But these “deadbeats” are a CITY GOVERNMENT
- “Ghetto Loans” City accuses Wells Fargo of engaging in illegal “Reverse Redlining”
- Deadbeats | Cape Coral Couple Sues Wells Fargo for Selling them Home it didn’t Own
- SEC Files Subpoena Enforcement Action Against Wells Fargo for Failure to Produce Documents in Mortgage-Backed Securities Investigation
SEC Charges Deloitte and Touche (JP Morgan’s Independent Foreclosure Review Firm) with Violating U.S. Securities Laws in Refusal to Produce Documents
- JPMorgan’s Independent Foreclosure Review Firm Deloitte & Touche LLP Recenly Sued for Failing to Detect Fraud that Led to more than $7 Billion in Losses
- Foreclosure Fraud – Texas Attorney General Abbott Charges American Home Mortgage Servicing Inc With Violating State Debt Collection Laws
- SEC Files Subpoena Enforcement Action Against Wells Fargo for Failure to Produce Documents in Mortgage-Backed Securities Investigation
Bloomberg’s Editorial On MBS Failures – The First Time Mortgage-Backed Securities Failed
- Why Mortgage-Backed Securities Aren’t (Backed by Securities): How MERS Toasted the Banks
- Bear Stearns Asset Backed Securities Trust 2005-4 v. EMC Mortgage Corp | JPMorgan Sued for $95 Million Over Mortgage Securities
- Another Wrist Slap | Wells Fargo Agrees to “Settle” with SEC for $11 million on Wachovia Securities Laws Violations Involving Mortgage-Backed Securities
A Must Read Fraudclosure Story | MSNBC – Inside the Wells Fargo Foreclosure Factory: Pushing the Files
Judes Tells Bank of America CEO Brian Moynihan He Must Testify in MBIA Lawsuit
- Bloomberg | Bank of America Said to Offer MBIA Settlement in Defective-Mortgage Suit
- MBIA Insurance Corporation v. Bank of America Corp., Countrywide Financial Corporation, Countrywide Home Loans, et. al.
- MBIA Insurance Corp. v. Countrywide Home Loans Inc | BofA Loses Ruling Against MBIA in Fight Over Loans
KABOOM | Bank of NY Mellon Must Face Lawsuit on Countrywide
- Mortgage Fraud | Bank of America, Bank of New York Mellon, Countrywide Home Loans Servicing, Law Offices of David Stern, Cheryl Samons
- New York Attorney General Accuses Bank Of New York Mellon Of Fraud, Moves To Block Bank Of America’s Mortgage Deal
- BAM! | US Judge Takes $8.5 Bln BofA Deal from State Court in Bank of New York Mellon vs Walnut Place
KABOOM | Bank of NY Mellon Must Face Lawsuit on Countrywide
- Mortgage Fraud | Bank of America, Bank of New York Mellon, Countrywide Home Loans Servicing, Law Offices of David Stern, Cheryl Samons
- New York Attorney General Accuses Bank Of New York Mellon Of Fraud, Moves To Block Bank Of America’s Mortgage Deal
- BAM! | US Judge Takes $8.5 Bln BofA Deal from State Court in Bank of New York Mellon vs Walnut Place
Deutsche Bank to Pay $32.5 Million to Settle Mortgage Suit – Massachusetts Bricklayers and Masons Trust Funds v. Deutsche Alt-A Securities
- Bear Stearns Asset Backed Securities Trust 2005-4 v. EMC Mortgage Corp | JPMorgan Sued for $95 Million Over Mortgage Securities
- Wells Fargo to Pay $125 Million to Settle Billion Mortgage-Backed Securities Fraud Case
- Another Wrist Slap | Wells Fargo Agrees to “Settle” with SEC for $11 million on Wachovia Securities Laws Violations Involving Mortgage-Backed Securities
IF TRUE, IT’S TREASON – CBO Director Douglas Elmendorf and the Impact of the Foreclosure Crisis

During the fall of 2010, Lan T. Pham, PhD was a “senior staffer financial economist” at the Congressional Budget Office. She was fired after less than three months on the job.
In February she tried to go public with details about her experience working for Mr. Douglas Elmendorf, first by releasing the story to the Wall Street Journal. But when the WSJ’s story, quite predictably in my mind, treated her like a disgruntled ex-employee, she decided she had to do more. So, a few days ago, Dr. Pham first approached Zerohedge.com, and then made public a letter she had written to Senator Grassley, ranking member of the Senate Judiciary Committee, on February 23 of this year.
Janet Tavakoli, President of Tavakoli Structured Finance in Chicago… and a hero of mine, by the way… picked up the letter and ran a piece about it on her HuffPo blog, referring to it as “Today’s Most Important Finance Story.” Tavakoli is brilliant when it comes to all things structured finance, like mortgage-backed securities and derivatives. I read a book she published a few years ago, titled: “Dear Mr. Buffett,” which led me to read others she had written like: “Structured Finance and Collateralized Debt Obligations,” which is where I learned enough to write many of the articles posted on Mandelman Matters over the last three plus years. (And yes, I realize that makes me sound like a nerd with no life.)
Janet’s HuffPo piece and the Zerohedge story covered what Dr. Pham described in her letter to Senator Grassley in a balanced, perhaps slightly careful way, in my view, primarily covering how the CBO had treated her as related to the “robo-signing scandal,” which had broken in the mainstream media during September of 2010.
Dr. Pham wrote about the implications of robo-signing, MERS, of a potentially broken chain of title, how all of that might impact investors and homeowners… and she did so in-sync with something that might have been written by Georgetown Law Professor Adam Levitin. In response, according to Dr. Pham, CBO’s leadership responded as follows…
The emerging foreclosure fraud problems in September 2010 were due to “media sensationalism,” and “the kind of event of the moment where we should be adding skepticism,” and “not just repeating the hype in the press,” and discussing it, “lacks judgment about what is important.”
I’m not going to spend any time on this aspect of her story, even though I know some of my readers just can’t seem to get enough “securitization failure,” and “robo-signing fraud and forgery,” and “MERS stole my home,” back story. And I’m not going to devote any time to those aspects of Dr. Pham’s story for three reasons that I want to make clear.
For one thing, it’s reached the point that you can catch a story about fraudulent documents embedded in recorder of deeds offices pretty much every night on either Rachel Maddow or Dylan Ratigan’s shows on MSNBC. In fact I just saw that Jeff Thigpen, the Recorder of Deeds from North Carolina was just on Rachel’s show last night.
(I did a podcast with Jeff covering everything said on that show and more last December, and you can catch it HERE, if you haven’t listened already… he’s a great guy and explains things very clearly and with that southern style of sarcasm that always makes me smile.)
The second reason I’m not addressing those aspects of Dr. Pham’s experience at CBO, is that I’m not even sure that I think the CBO was all that wrong to suppress her desire to voice an opinion on the impact of robo-signing and the related subject matter in her role as a financial economist at the CBO. For the most part, that’s because of the timing, the story only broke in mainstream media in September of 2010, and it was more than a year later before the “settlement” was announced… but besides that… even today, I’m not sure that anyone could credibly quantify any sort of financial risk related to those inadequacies, or illegalities, that seem to permeate the foreclosure process.
And third on my list of reasons for ignoring those aspects of Dr. Pham’s story is that I’m still not at all sure that the courts care all that much that the assignment of Deed of Trust was signed by Mickey Mouse, or even that the law views homeowners as having been damaged by such an occurrence.
I also know that as I say that, just last night attorney April Charney had a court stop her client’s foreclosure in Florida because the judge ruled that the person signing the “verification” either lacked sufficient knowledge or perhaps wasn’t even authorized to do so under Florida law – it looks like 1.110 (b), but don’t quote me. (You can find a copy of the judge’s order HERE on Matt Weidner’s blog.)
What I don’t know is what happens next for April’s client, or any other homeowner in similar situation, as a result of such a ruling. In this case it’s US Bank, so does US Bank just fix the problem and re-file, and if so, how long might that take… a couple months… six months… or am I to believe that it’s something that can’t be fixed… because I’m going to need to see some cases where that’s the case.
Last thing I’ll say about this for the moment is that I hear from various homeowners, or others from around the country every single day, telling me something about fraudulent transfers, forged signatures, or some other alleged impropriety having to do with the title or its recording, but I never receive anything tangible in terms of outcome for homeowners.
And frankly, I’m a little tired of vague and incomplete accounts of what I suspect are often pyrrhic victories, if they’re victories at all. I know some foreclosure defense lawyers have told me that the goal is to delay and thereby wear down the servicer who ultimately submits by throwing in a loan modification, but like I said… I’m going to need more details than that before I can communicate to homeowners that such strategies are effective in the prevention of foreclosures. Capicse?
Here’s why I agree with Jan Tavakoli that Dr. Pham’s story is the day’s MOST IMPORTANT FINANCE STORY. In fact, I think it’s even more important than that… like, maybe it’s the most important finance-economics-politics story in my lifetime, how’s that.
To understand what I’m about to say, you have to first understand what the CBO is all about, which will only take a minute or two, so stay with me… please.
The Congressional Budget and Impoundment Control Act, which was signed into law by President Nixon in 1974, created the CBO, and its primary mandate is to provide Congress with “objective and nonpartisan analysis to aid in economic and budgetary decisions on a wide array of programs covered by the federal budget.”
That means that the CBO is there to shape and support our government’s decisions related to SPENDING our money… regardless of whether Democrat or Republican. It’s counterpart is the Joint Committee on Taxation, which provides Congress with estimates of the revenues that will be available to Congress, the Treasury Department, and for the Executive branch, which are then used to calculate our federal budget.
The CBO is required to submit to the budget committees in the House of Representatives and the Senate, detailed reports about fiscal policy with baseline projections of the federal budget, which is done annually in the Economic and Budget Outlook, and again in a mid-year update. And it shouldn’t be difficult to imagine that in order to conduct this type of detailed analysis for a country of our size and complexity, the CBO needs experts in different areas of study, including…
- Budget Analysis
- Financial Analysis
- Health and Human Services
- Macroeconomic Analysis
- Management, Business, and Information Services
- Microeconomic Studies
- National Security
- Tax Analysis
So, the Joint Committee on Taxation tells us the amounts we can expect to come in, and the CBO delivers data and analysis on what we should expect to go out for all federal spending, and since we never have anywhere near enough to balance the federal budget, the CBO’s work is also used to calculate the amount of our deficit… and therefore the amount of our national debt.
And the amount of our national debt, you should realize, is what tells the rest of the world how risky it is to lend us money, which is done when investors from all over the world buy the bonds that are issued by our Treasury Department.
Each year, CBO analysts produce, I don’t know… hundreds of reports… maybe thousands, and the one most recognized is titled: “An Analysis of the President’s Budgetary Proposals,” which is made available for the next fiscal year, and argued about while the cameras are rolling, but not so much once they’re not. You can even buy a copy at the Government Printing Office… then turn on C-Span and yell along at home. Fun!
(In case you’ve never perused our Government’s Bookstore, HERE’S A LINK. It’s not Disneyland or anything, but it’s worth a visit.)
(If you want more info on the CBO, here’s a link to a FACT SHEET they offer. Honestly, I haven’t read it, so if it says something a little differently that I just did, don’t freak out… I’m right, or close enough… LOL. In case you didn’t know, I taught 5th and 6th grade U.S. History and Social Studies a couple years back, and raised a daughter besides, so I’m like a walking D.C. tour guide… but without the umbrella and boxed lunch.)
ONE LAST POINT ABOUT THE ROLE OF THE CBO…
The CBO is not the only federal agency involved in budgeting, there’s also the OMB, or Office of Management and Budget, and the GAO, which stands for General Accounting Office, and there’s the Treasury Department too, which shows up with its own numbers when needed.
But, it’s the CBO that calculates the 35-year baseline projections, which are used so extensively in the budget process. Baseline projections are supposed to show future spending assuming current law, so they’re not supposed to be considered “predictors” of our economy’s most likely future path, but they’re referred to a lot and become the basis for a lot of “GO or NO GO” decisions.
Okay, so I hope everyone sees that the CBO is a big deal in Washington D.C. and really, around the world, since our spending impacts our entire planet… pretty much. It’s a place that employs so many PhDs I couldn’t even guess how many, and it’s why “PhD” is said to stand for, “Piled Higher and Deeper.” And it’s REALLY IMPORTANT that it’s one of the few places in Washington D.C. that’s truly non-partisan.
A CRIME to defy all reason…
I don’t know why everyone has focused on the robo-signing and document fraud aspects of Dr. Pham’s allegations, I’m sorry to have to say this, but doing so is only clouding the real issues involved. So, I’m going to be as clear as possible…
In Dr. Pham’s letter to Senator Grassley, she explained that while working at the CBO during the fall of 2010, she was told not to publish or incorporate any data about the U.S. housing and mortgage markets… NOTHING about the foreclosure crisis… NOTHING that might spoil the CBO’s “forecasts,” of course, that term extremely loosely.
In fact, Pham’s letter states that she was told in no uncertain terms by CBO leadership, or otherwise came to understand that…
- Statements could not be made that attributed the decline in property tax revenues to foreclosures and the decline in home prices.
-
Foreclosures had no impact on U.S. home prices.
-
The decline in home prices had no impact on U.S. household wealth.
-
“Alternative viewpoints are suppressed or questioned as ‘pessimistic’ by CBO Director Doug Elmendorf. Economic facts inconvenient to the CBO’s forecasts of economic growth, recovery and other estimates are omitted or suppressed so the desired message may be delivered.”
-
That even though the implications of foreclosures had profound financial and economic consequences that would be of compelling interest to Congress and the public, the CBO sought to SILENCE any such discussion of such risks.
In my mind, this set of statements, which I culled from Pham’s letter to Senator Grassley and from her letter written in response to the WSJ’s disappointing handling of the story, does NOT need any further qualification… I believe Dr. Pham is telling the truth, and so does everyone else that’s linked to Jan Tavakoli’s or Zerohedge’s coverage of the story. (You’ll find both of Dr. Pham’s letters linked to my Scribd account above.)
Also, according o the WSJ story, which ran on page A6 on February 2nd…
“The CBO declined to comment on Ms. Pham’s allegations. In a December 2010 termination letter, reviewed by the Journal, the CBO said she was unqualified for the job, produced “poorly organized” research and resisted direction from superiors.”
That’s simply not a credible response, if you’re trying to claim that the substance of what she claims happened… didn’t.
And, you see… although admittedly it’s been a few years now, as an economics major at both undergrad and masters program levels, I had quite a few economics professors with doctorates, and I can’t think of any that would make it through the rigorous and competitive hiring process at the CBO, and then just under three months later, be described as “unqualified for the job,” much less as having “produced poorly organized research.”
I mean, how much “research” could she possibly have produced in the first 10 weeks at that sort of job? And Lan T. Pham is 40 years old. By forty, you know if you’re organized or not, don’t you?
Besides… I was the CEO of my own consulting firm for almost 20 years, so you can believe me when I tell you that “organizational skills” are the sort of thing that most employers have long since figured out how to test for, or otherwise ascertain during the interview process. I may miss something when assessing someone’s critical thinking abilities, but I can always figure out whether someone can stay organized… at least for the first three months on a job.
As far as resisting direction from superiors, that much I understand… she thought the foreclosure fraud issues were a big deal, but it wasn’t going to be the focus of the CBO to make such judgments then, or probably now. So what and who cares?
The question is… Mr. Douglas Elmendorf, in your role as Director of the Congressional Budget Office, did you deliberately withhold, mask and knowingly deliver grossly distorted information vital to the current and future economic, political and social wellbeing of the United States of America during the most severe, prolonged and damaging national economic emergency since the 1930s?
Did you lie to Congress, if only by omission, because that would be bad enough. But, if you intentionally withheld critical information from and delivered misinformation to the President of the United States, Congress, and the citizens of this country during a national crisis, then you are a monster.
And all I can do is pray that you did this alone, because if you didn’t… if your actions were part of a conspiracy intent on seeing this country’s economy so substantively disrupted as to become utterly destroyed, with trillions of dollars in middle class wealth eviscerated and with no hope for its return in my lifetime… and if knowledge of your acts actually involved someone inside the White House… well then… Dear God, sir… what have you done?
The CBOs calculations are used as the basis for the single largest source of spending the world has ever known, they lead to establishing the amount of our deficit and then our national debt, which is the basis for our international credit standing. It’s simply inconceivable.
If you, as Dr. Pham describes, have produced numbers that fail to account for the impact of foreclosures on consumer wealth, spending, and property taxes… then those numbers are garbage… the sort you might have just chosen by throwing darts while wearing a blindfold.
When I think of what has been allowed to happen to the lives of hundreds of millions of American citizens… to the elderly… the destitute, to those too young to know… to say nothing of what such suppression of information has done to untold numbers of people around the globe?
When I think of how many times I was asked why our government wasn’t saying what I and others were saying in our countless articles… and I’d reply… “they have to know,” never understanding why such inconceivably poor decisions were being made.
Annually, hearing the news report things like, “The White House or unnamed economists say that the severity of the downturn in housing caught them by surprise,” and I’d think… how could that be… it didn’t catch anyone else involved in following it by surprise?
I guess I can’t know for sure what’s gone on here… I do believe Dr. Pham’s statements, but I don’t know the degree to which forecasts were manipulated with intentional blindness. I am physically sickened by the idea that anyone could have allowed that to happen.
You’re a graduate of Princeton with an undergraduate degree in economics, a Masters in Economics and then a doctorate in economics, and the last two degrees are from Harvard? You cannot claim ignorance or feign indifference.
I suppose I’ll never know who was involved or what you’ve done to this nation by manipulating or withholding such information from Congress, from the president, from the American people and from the world. If you did any of it, you are a traitor to this country.
How is it possible that even as you watched the economic situation worsen significantly, you just turned your back on the tens of millions who today live on food stamps, having lost all hope of employment for years to come?
I don’t know what else to say… I don’t like feeling like I’m being dramatic, but after spending 30 hours reading, researching, thinking and writing… learning about your past…
- Elmendorf worked on a team that concluded President Bill Clinton’s health-reform package would cost much more than originally thought. This analysis helped cripple the Clinton overhaul.
- Elmendorf worked under Clinton Treasury Secretary Lawrence Summers.
- In 2002, Elmendorf moved to the Fed, working under Alan Greenspan.
- In April 2010, Elmendorf spoke openly against the country’s growing debt level, saying under current plans the deficit is “unsustainable.”
- Elmendorf was Chief of the macro-economic analysis team at the Federal Reserve Board from 2002 to 2007.
- After graduating in 1989, he stayed at Harvard for five years, working closely with conservative economics professor Martin Feldstein, the director of the Council of Economic Advisers (CEA) under President Reagan.
- In 2008, Jason Furman, the director of the Brookings’ group known as the Hamilton Project left to join the Obama campaign and Elmendorf replaced him as director of the Hamilton Project, a forum for economic policy discussion that was created by Clinton Treasury Secretary Robert Rubin – an advocate of free trade and a small deficit.
- Elmendorf worked two years at Brookings. While there, he spent much of his time opining on the mortgage collapse, and the appropriate response by the government. While he only called for the nationalization of banks as a last resort, Elmendorf did support a bailout of struggling financial institutions.
I really don’t know what else to say… my only thoughts are… resign now… beg forgiveness, and pray for your soul.
Mandelman out.
IF TRUE, IT’S TREASON – CBO Director Douglas Elmendorf and the Impact of the Foreclosure Crisis

During the fall of 2010, Lan T. Pham, PhD was a “senior staffer financial economist” at the Congressional Budget Office. She was fired after less than three months on the job.
In February she tried to go public with details about her experience working for Mr. Douglas Elmendorf, first by releasing the story to the Wall Street Journal. But when the WSJ’s story, quite predictably in my mind, treated her like a disgruntled ex-employee, she decided she had to do more. So, a few days ago, Dr. Pham first approached Zerohedge.com, and then made public a letter she had written to Senator Grassley, ranking member of the Senate Judiciary Committee, on February 23 of this year.
Janet Tavakoli, President of Tavakoli Structured Finance in Chicago… and a hero of mine, by the way… picked up the letter and ran a piece about it on her HuffPo blog, referring to it as “Today’s Most Important Finance Story.” Tavakoli is brilliant when it comes to all things structured finance, like mortgage-backed securities and derivatives. I read a book she published a few years ago, titled: “Dear Mr. Buffett,” which led me to read others she had written like: “Structured Finance and Collateralized Debt Obligations,” which is where I learned enough to write many of the articles posted on Mandelman Matters over the last three plus years. (And yes, I realize that makes me sound like a nerd with no life.)
Janet’s HuffPo piece and the Zerohedge story covered what Dr. Pham described in her letter to Senator Grassley in a balanced, perhaps slightly careful way, in my view, primarily covering how the CBO had treated her as related to the “robo-signing scandal,” which had broken in the mainstream media during September of 2010.
Dr. Pham wrote about the implications of robo-signing, MERS, of a potentially broken chain of title, how all of that might impact investors and homeowners… and she did so in-sync with something that might have been written by Georgetown Law Professor Adam Levitin. In response, according to Dr. Pham, CBO’s leadership responded as follows…
The emerging foreclosure fraud problems in September 2010 were due to “media sensationalism,” and “the kind of event of the moment where we should be adding skepticism,” and “not just repeating the hype in the press,” and discussing it, “lacks judgment about what is important.”
I’m not going to spend any time on this aspect of her story, even though I know some of my readers just can’t seem to get enough “securitization failure,” and “robo-signing fraud and forgery,” and “MERS stole my home,” back story. And I’m not going to devote any time to those aspects of Dr. Pham’s story for three reasons that I want to make clear.
For one thing, it’s reached the point that you can catch a story about fraudulent documents embedded in recorder of deeds offices pretty much every night on either Rachel Maddow or Dylan Ratigan’s shows on MSNBC. In fact I just saw that Jeff Thigpen, the Recorder of Deeds from North Carolina was just on Rachel’s show last night.
(I did a podcast with Jeff covering everything said on that show and more last December, and you can catch it HERE, if you haven’t listened already… he’s a great guy and explains things very clearly and with that southern style of sarcasm that always makes me smile.)
The second reason I’m not addressing those aspects of Dr. Pham’s experience at CBO, is that I’m not even sure that I think the CBO was all that wrong to suppress her desire to voice an opinion on the impact of robo-signing and the related subject matter in her role as a financial economist at the CBO. For the most part, that’s because of the timing, the story only broke in mainstream media in September of 2010, and it was more than a year later before the “settlement” was announced… but besides that… even today, I’m not sure that anyone could credibly quantify any sort of financial risk related to those inadequacies, or illegalities, that seem to permeate the foreclosure process.
And third on my list of reasons for ignoring those aspects of Dr. Pham’s story is that I’m still not at all sure that the courts care all that much that the assignment of Deed of Trust was signed by Mickey Mouse, or even that the law views homeowners as having been damaged by such an occurrence.
I also know that as I say that, just last night attorney April Charney had a court stop her client’s foreclosure in Florida because the judge ruled that the person signing the “verification” either lacked sufficient knowledge or perhaps wasn’t even authorized to do so under Florida law – it looks like 1.110 (b), but don’t quote me. (You can find a copy of the judge’s order HERE on Matt Weidner’s blog.)
What I don’t know is what happens next for April’s client, or any other homeowner in similar situation, as a result of such a ruling. In this case it’s US Bank, so does US Bank just fix the problem and re-file, and if so, how long might that take… a couple months… six months… or am I to believe that it’s something that can’t be fixed… because I’m going to need to see some cases where that’s the case.
Last thing I’ll say about this for the moment is that I hear from various homeowners, or others from around the country every single day, telling me something about fraudulent transfers, forged signatures, or some other alleged impropriety having to do with the title or its recording, but I never receive anything tangible in terms of outcome for homeowners.
And frankly, I’m a little tired of vague and incomplete accounts of what I suspect are often pyrrhic victories, if they’re victories at all. I know some foreclosure defense lawyers have told me that the goal is to delay and thereby wear down the servicer who ultimately submits by throwing in a loan modification, but like I said… I’m going to need more details than that before I can communicate to homeowners that such strategies are effective in the prevention of foreclosures. Capicse?
Here’s why I agree with Jan Tavakoli that Dr. Pham’s story is the day’s MOST IMPORTANT FINANCE STORY. In fact, I think it’s even more important than that… like, maybe it’s the most important finance-economics-politics story in my lifetime, how’s that.
To understand what I’m about to say, you have to first understand what the CBO is all about, which will only take a minute or two, so stay with me… please.
The Congressional Budget and Impoundment Control Act, which was signed into law by President Nixon in 1974, created the CBO, and its primary mandate is to provide Congress with “objective and nonpartisan analysis to aid in economic and budgetary decisions on a wide array of programs covered by the federal budget.”
That means that the CBO is there to shape and support our government’s decisions related to SPENDING our money… regardless of whether Democrat or Republican. It’s counterpart is the Joint Committee on Taxation, which provides Congress with estimates of the revenues that will be available to Congress, the Treasury Department, and for the Executive branch, which are then used to calculate our federal budget.
The CBO is required to submit to the budget committees in the House of Representatives and the Senate, detailed reports about fiscal policy with baseline projections of the federal budget, which is done annually in the Economic and Budget Outlook, and again in a mid-year update. And it shouldn’t be difficult to imagine that in order to conduct this type of detailed analysis for a country of our size and complexity, the CBO needs experts in different areas of study, including…
- Budget Analysis
- Financial Analysis
- Health and Human Services
- Macroeconomic Analysis
- Management, Business, and Information Services
- Microeconomic Studies
- National Security
- Tax Analysis
So, the Joint Committee on Taxation tells us the amounts we can expect to come in, and the CBO delivers data and analysis on what we should expect to go out for all federal spending, and since we never have anywhere near enough to balance the federal budget, the CBO’s work is also used to calculate the amount of our deficit… and therefore the amount of our national debt.
And the amount of our national debt, you should realize, is what tells the rest of the world how risky it is to lend us money, which is done when investors from all over the world buy the bonds that are issued by our Treasury Department.
Each year, CBO analysts produce, I don’t know… hundreds of reports… maybe thousands, and the one most recognized is titled: “An Analysis of the President’s Budgetary Proposals,” which is made available for the next fiscal year, and argued about while the cameras are rolling, but not so much once they’re not. You can even buy a copy at the Government Printing Office… then turn on C-Span and yell along at home. Fun!
(In case you’ve never perused our Government’s Bookstore, HERE’S A LINK. It’s not Disneyland or anything, but it’s worth a visit.)
(If you want more info on the CBO, here’s a link to a FACT SHEET they offer. Honestly, I haven’t read it, so if it says something a little differently that I just did, don’t freak out… I’m right, or close enough… LOL. In case you didn’t know, I taught 5th and 6th grade U.S. History and Social Studies a couple years back, and raised a daughter besides, so I’m like a walking D.C. tour guide… but without the umbrella and boxed lunch.)
ONE LAST POINT ABOUT THE ROLE OF THE CBO…
The CBO is not the only federal agency involved in budgeting, there’s also the OMB, or Office of Management and Budget, and the GAO, which stands for General Accounting Office, and there’s the Treasury Department too, which shows up with its own numbers when needed.
But, it’s the CBO that calculates the 35-year baseline projections, which are used so extensively in the budget process. Baseline projections are supposed to show future spending assuming current law, so they’re not supposed to be considered “predictors” of our economy’s most likely future path, but they’re referred to a lot and become the basis for a lot of “GO or NO GO” decisions.
Okay, so I hope everyone sees that the CBO is a big deal in Washington D.C. and really, around the world, since our spending impacts our entire planet… pretty much. It’s a place that employs so many PhDs I couldn’t even guess how many, and it’s why “PhD” is said to stand for, “Piled Higher and Deeper.” And it’s REALLY IMPORTANT that it’s one of the few places in Washington D.C. that’s truly non-partisan.
A CRIME to defy all reason…
I don’t know why everyone has focused on the robo-signing and document fraud aspects of Dr. Pham’s allegations, I’m sorry to have to say this, but doing so is only clouding the real issues involved. So, I’m going to be as clear as possible…
In Dr. Pham’s letter to Senator Grassley, she explained that while working at the CBO during the fall of 2010, she was told not to publish or incorporate any data about the U.S. housing and mortgage markets… NOTHING about the foreclosure crisis… NOTHING that might spoil the CBO’s “forecasts,” of course, that term extremely loosely.
In fact, Pham’s letter states that she was told in no uncertain terms by CBO leadership, or otherwise came to understand that…
- Statements could not be made that attributed the decline in property tax revenues to foreclosures and the decline in home prices.
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Foreclosures had no impact on U.S. home prices.
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The decline in home prices had no impact on U.S. household wealth.
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“Alternative viewpoints are suppressed or questioned as ‘pessimistic’ by CBO Director Doug Elmendorf. Economic facts inconvenient to the CBO’s forecasts of economic growth, recovery and other estimates are omitted or suppressed so the desired message may be delivered.”
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That even though the implications of foreclosures had profound financial and economic consequences that would be of compelling interest to Congress and the public, the CBO sought to SILENCE any such discussion of such risks.
In my mind, this set of statements, which I culled from Pham’s letter to Senator Grassley and from her letter written in response to the WSJ’s disappointing handling of the story, does NOT need any further qualification… I believe Dr. Pham is telling the truth, and so does everyone else that’s linked to Jan Tavakoli’s or Zerohedge’s coverage of the story. (You’ll find both of Dr. Pham’s letters linked to my Scribd account above.)
Also, according o the WSJ story, which ran on page A6 on February 2nd…
“The CBO declined to comment on Ms. Pham’s allegations. In a December 2010 termination letter, reviewed by the Journal, the CBO said she was unqualified for the job, produced “poorly organized” research and resisted direction from superiors.”
That’s simply not a credible response, if you’re trying to claim that the substance of what she claims happened… didn’t.
And, you see… although admittedly it’s been a few years now, as an economics major at both undergrad and masters program levels, I had quite a few economics professors with doctorates, and I can’t think of any that would make it through the rigorous and competitive hiring process at the CBO, and then just under three months later, be described as “unqualified for the job,” much less as having “produced poorly organized research.”
I mean, how much “research” could she possibly have produced in the first 10 weeks at that sort of job? And Lan T. Pham is 40 years old. By forty, you know if you’re organized or not, don’t you?
Besides… I was the CEO of my own consulting firm for almost 20 years, so you can believe me when I tell you that “organizational skills” are the sort of thing that most employers have long since figured out how to test for, or otherwise ascertain during the interview process. I may miss something when assessing someone’s critical thinking abilities, but I can always figure out whether someone can stay organized… at least for the first three months on a job.
As far as resisting direction from superiors, that much I understand… she thought the foreclosure fraud issues were a big deal, but it wasn’t going to be the focus of the CBO to make such judgments then, or probably now. So what and who cares?
The question is… Mr. Douglas Elmendorf, in your role as Director of the Congressional Budget Office, did you deliberately withhold, mask and knowingly deliver grossly distorted information vital to the current and future economic, political and social wellbeing of the United States of America during the most severe, prolonged and damaging national economic emergency since the 1930s?
Did you lie to Congress, if only by omission, because that would be bad enough. But, if you intentionally withheld critical information from and delivered misinformation to the President of the United States, Congress, and the citizens of this country during a national crisis, then you are a monster.
And all I can do is pray that you did this alone, because if you didn’t… if your actions were part of a conspiracy intent on seeing this country’s economy so substantively disrupted as to become utterly destroyed, with trillions of dollars in middle class wealth eviscerated and with no hope for its return in my lifetime… and if knowledge of your acts actually involved someone inside the White House… well then… Dear God, sir… what have you done?
The CBOs calculations are used as the basis for the single largest source of spending the world has ever known, they lead to establishing the amount of our deficit and then our national debt, which is the basis for our international credit standing. It’s simply inconceivable.
If you, as Dr. Pham describes, have produced numbers that fail to account for the impact of foreclosures on consumer wealth, spending, and property taxes… then those numbers are garbage… the sort you might have just chosen by throwing darts while wearing a blindfold.
When I think of what has been allowed to happen to the lives of hundreds of millions of American citizens… to the elderly… the destitute, to those too young to know… to say nothing of what such suppression of information has done to untold numbers of people around the globe?
When I think of how many times I was asked why our government wasn’t saying what I and others were saying in our countless articles… and I’d reply… “they have to know,” never understanding why such inconceivably poor decisions were being made.
Annually, hearing the news report things like, “The White House or unnamed economists say that the severity of the downturn in housing caught them by surprise,” and I’d think… how could that be… it didn’t catch anyone else involved in following it by surprise?
I guess I can’t know for sure what’s gone on here… I do believe Dr. Pham’s statements, but I don’t know the degree to which forecasts were manipulated with intentional blindness. I am physically sickened by the idea that anyone could have allowed that to happen.
You’re a graduate of Princeton with an undergraduate degree in economics, a Masters in Economics and then a doctorate in economics, and the last two degrees are from Harvard? You cannot claim ignorance or feign indifference.
I suppose I’ll never know who was involved or what you’ve done to this nation by manipulating or withholding such information from Congress, from the president, from the American people and from the world. If you did any of it, you are a traitor to this country.
How is it possible that even as you watched the economic situation worsen significantly, you just turned your back on the tens of millions who today live on food stamps, having lost all hope of employment for years to come?
I don’t know what else to say… I don’t like feeling like I’m being dramatic, but after spending 30 hours reading, researching, thinking and writing… learning about your past…
- Elmendorf worked on a team that concluded President Bill Clinton’s health-reform package would cost much more than originally thought. This analysis helped cripple the Clinton overhaul.
- Elmendorf worked under Clinton Treasury Secretary Lawrence Summers.
- In 2002, Elmendorf moved to the Fed, working under Alan Greenspan.
- In April 2010, Elmendorf spoke openly against the country’s growing debt level, saying under current plans the deficit is “unsustainable.”
- Elmendorf was Chief of the macro-economic analysis team at the Federal Reserve Board from 2002 to 2007.
- After graduating in 1989, he stayed at Harvard for five years, working closely with conservative economics professor Martin Feldstein, the director of the Council of Economic Advisers (CEA) under President Reagan.
- In 2008, Jason Furman, the director of the Brookings’ group known as the Hamilton Project left to join the Obama campaign and Elmendorf replaced him as director of the Hamilton Project, a forum for economic policy discussion that was created by Clinton Treasury Secretary Robert Rubin – an advocate of free trade and a small deficit.
- Elmendorf worked two years at Brookings. While there, he spent much of his time opining on the mortgage collapse, and the appropriate response by the government. While he only called for the nationalization of banks as a last resort, Elmendorf did support a bailout of struggling financial institutions.
I really don’t know what else to say… my only thoughts are… resign now… beg forgiveness, and pray for your soul.
Mandelman out.
SEC Files Subpoena Enforcement Action Against Wells Fargo for Failure to Produce Documents in Mortgage-Backed Securities Investigation
- Wells Fargo to Pay $125 Million to Settle Billion Mortgage-Backed Securities Fraud Case
- Another Wrist Slap | Wells Fargo Agrees to “Settle” with SEC for $11 million on Wachovia Securities Laws Violations Involving Mortgage-Backed Securities
- Did Federal Banking Regulators Inadvertently Expose Massive Mortgage Backed Securities Fraud as Part of Fraudclosure Investigation?
ProPublica | Four Whistleblowers Who Sounded the Alarm on Banks’ Mortgage Shenanigans
Naked Capitalism | The Legal Lie at the Heart of the $8.5 Billion Bank of America and Federal/State Mortgage Settlements
- Naked Capitalism | Yes, Virginia, Servicers Lie to Investors Too: $175 Billion in Loan Losses Not Allocated to Mortgage Backed Securities (and Another $300 Billion on the Way)
- BofA’s $8.5 Billion Settlement Could Fall Apart After Request Made To Move Mortgage Case From State To Federal Court
- Pam Bondi Press Release | Florida Enters $25 Billion Joint State-Federal Mortgage Servicing Settlement
New Jersey Supreme Court’s Guillaume decision meaningless – Should foreclosure defense rethink its strategy?

The foreclosure wars have always had two easily identifiable sides. It’s homeowners in one corner… and banks and mortgage servicers in the other. In the beginning the battle was largely over TILA and RESPA claims. After that, we fell into loan modifications, and then into the HAMP guidelines that were never really followed by the servicers, or if they were on occasion, no one could tell.
Lawyers who went to court over HAMP “rules” quickly discovered that they were more like pointers, intimations, tips, or perhaps clues… but whatever they were, HAMP had no teeth, and if there was anything that could be construed as a rule or law, then there was no private right of action. And as far as the HAMP contract between Fannie Mae/Treasury and the participating servicers, well… forget about it because borrowers were not considered third party beneficiaries to that contract.
I never liked any of these decisions one bit… and I still don’t. But I’m no lawyer, so I went along with whatever the foreclosure defense attorneys thought best. Obviously, on these points at least, the fix was in, so I climbed on the bus and went on down the road.
We arrived at the battleground called “securitization fail,” and soon everybody on the homeowner side was learning to sing a new version of their ABCs that went like this… A to B, B to C, C to D, which represented the steps required to properly negotiate a note into a REMIC trust, steps that were almost never followed… or maybe never followed.
The argument, however, was a technical one and judges weren’t exhibiting much patience for the technical learning that was required to understand the argument. It seemed that the judges were having trouble seeing past the 300 cases on their dockets and the homeowner who hadn’t paid their mortgage payments in over two years. The argument may very well have been rock solid, but many lawyers came back from court reporting that their judges had heads that were solid as rocks.

Next up was the media darling “robo-signing,” a practice that created documents to be filed in the records that were forged or signed without knowledge of anything, or illegally notarized, or whatever else you could think of… the paperwork was all wrong.
This debate is still raging, but it hasn’t done a lot of good for many homeowners, truth be told. It certainly has delayed things, in certain instances, and it even slowed the number of foreclosures filed during the year… but it’s certainly not keeping people in their homes in any number.
The bank and servicer side of this argument says that it’s just sloppy paperwork, technicalities causing no harm to borrowers… to which the foreclosure defense side replies, “YOU’RE BREAKING THE LAW… and then in response we hear, “IT DOESN’T MATTER.” “YOU’RE BREAKING THE LAW.” “IT DOESN’T MATTER.” It’s annoying… I’ll certainly give it that.
Good Morning, New Jersey…
Well, yesterday the New Jersey Supreme Court ruled in the Guillaume case, a much-anticipated decision, so I’d been told… and the ruling says that in addition to the servicer’s name and address, the lender’s name and address must appear on the document that states that a bank intends to foreclose on a mortgage. (You’ll find a copy of the case at bottom.)
Earth shattering news? Yes, I thought so too. File this one right next to “Brown v. The Board of Education,” or “Plessy v. Ferguson.” I’m sure law schools all over the nation are rushing to change their curriculums to add a class on the “Much Anticipated but Meaningless.”
140 Elmwood Ave, East Orange, NJ
The case involves an East Orange, New Jersey home owned by Maryse and Emilio Guillaume. The couple received a notice of intention to foreclose in May of 2008, and that notice included the name and address of the mortgage servicer, America’s Servicing Co., but it failed to include the name and address of the lender. And somehow, this issue made it all the way to the state’s Supreme Court.
The state’s high court ruled that because the foreclosure notice that the servicer sent to the Guillaumes did not include the name and address of the lender in addition to that of the servicer, it did fail to comply with New Jersey’s Fair Foreclosure Act.
The court said that, failure to include such information creates the potential for “significant prejudice” to homeowners. According to the high court…
“A misunderstanding about a lender’s identity could prompt a homeowner to make a critical error at a time when he or she is struggling to avert foreclosure.”
From the sounds of that, you’d think that the decision represents some sort of a win for homeowners, right? Not so much.
While the court ruled that the lower court judge was wrong about the need to include the lender’s name and address on the notice of intent to foreclose in addition to the servicer’s, the ruling also said that the lower court was correct to order a default judgment against the couple. Specifically, the court ruled that the couple did not make a case for “excusable neglect” or a “meritorious defense” related to their foreclosure, so the Guillaumes still lose their home.
Additionally, the high court also reversed a separate appellate decision, known as “Laks.”
The Laks decision said that a foreclosure should be dismissed if the notice of intent to foreclose did not comply with New Jersey’s Fair Foreclosure Act, and by reversing that decision, now trial court judges that find a notice that’s fails to comply, will be able to either dismiss the action, or simply order a corrected notice, or even select another solution they deem appropriate.
So, now… after all this… while it’s true that the lenders name and address has to be included on the notice of intent to foreclose along with the name and address of the servicer’s, in the event that the lender’s name is missing, that will no longer necessarily mean that the foreclosure will be dismissed and the servicer will have to start over. Now, the judge will have the discretion to simply order a corrected notice and allow the foreclosure will proceed.
Throughout last year, uncertainty over how the court would ultimately rule in this case led servicers to postpone foreclosures in New Jersey, and as a result foreclosures were down by 80 percent.
Now, I’m not saying that’s necessarily a bad thing, and if it were the goal, then I would call it a success. But, time is the natural enemy of a loan modification, because the longer the delay, assuming no mortgage payments are being made, the greater the amount of arrearages that have to be dealt with in order to modify the loan.
Now consider that reports all indicate that there are at least 100,000 New Jersey foreclosures that were stalled throughout last year, and that will now move forward. That’s 100,000 or more homes that have less chance of being modifiable today than they would have a year ago. So was the delay truly beneficial to homeowners?
I suppose for those that have no chance to save their home by getting their loan modified, they got an extra year living in the house, but even these people might have been better off dealing with it a year ago and today being one year closer to rebuilding their credit and buying their next home, assuming that’s they’re goal. The point is that a delay can be a dual edged sword, because it almost never leads to saving homes from foreclosure.
Lawyers that represent servicers all appeared quite happy with this decision because now a process that’s been clogged by uncertainty has been clarified by the court, and foreclosures will be free to move forward.
But it occurs to me… homeowners would not have been happy regardless of how this decision had gone.
I suppose I could be missing something, but I just don’t see a potential win in this case for homeowners no matter what. It was from its outset, a lose – lose scenario.
Bloomberg, covering news of the decision, quoted Rebecca Schore of Legal Services of New Jersey, an attorney for the Guillaumes, saying that…
“While she was pleased with the ruling on the need to name the actual lender in a notice of intention to foreclose, she was disappointed that the court didn’t require dismissal of the complaint.”
Okay, I hate to say this but… does any of this really matter to homeowners? Aren’t both positions merely a delay, and not much of a delay at that?
I mean, one way the notice of intent to foreclose includes the name and address of the lender in addition to the servicer, and the other way the notice doesn’t.
It seems to me that we’re pretty much exclusively fighting for delays, these days… in the hope of gaining leverage… all to achieve one thing… an affordable and therefore sustainable loan modification, because that is the only way homeowners are remaining in their homes in any number. Everything else seems to carry the odds of a Hail Mary at best.

Why are we giving our government a pass?
In February of 2009, our president introduced a plan that was to provide a path to precisely that, a sustainable loan modification, but when the participating servicers weren’t following that program’s rules, no one was willing to enforce them. And because of that entirely unacceptable and unforgivable unwillingness to enforce the programs rules, our entire nation has endured unspeakable suffering and financial pain.
But we didn’t turn to our legislature to demand that something be done to correct the unjust situation, we followed other paths instead, perhaps for good reason. But the fact remains that we have largely ignored the fact that the failure of HAMP is our government’s failure. As such, it is our government that should be held accountable. And as this is an election year, it seems the timing for such efforts is fortuitous.
I’m certainly not saying that people and their attorneys shouldn’t be doing whatever they can to protect their homes, and I’m sure there are times when a delay is advantageous. All I’m saying is that when the rules set forth by a federal program are being ignored it’s up to our elected representatives to do something to make damn sure those rules are followed because they were written in best interests of the program’s participants.
EPILOGUE…
The rules set forth under HAMP should be followed. Now, with whatever the AG settlement says, we’re about to have a new round of rules… and since it’s possible that Congress will again refuse to enforce those rules, I believe that we should be working to structure and demand a private right of action and attorneys fees to allow homeowners and trial attorneys to turn to the courts for relief.
To be blunt, it seems to me to be insane that our president should be allowed to announce and implement a $75 billion program designed to save homes from foreclosure, in order to rescue our economy and protect our middle class population, and then when program applicants are abused because program rules are not followed, that our legislature sit on their hands pretending that nothing can be done… as we go off to try other approaches.
It also seems ridiculous that a $75 billion program, three years after its launch, has only spent five percent of its budget, and no one says a word. If we had a $75 billion program for rats and mice, and three years later only five percent of the budgeted amount had been spent, there would be people screaming about how we’ve underserved the rats and mice. In fact, I don’t think I’ve ever heard of a government program under-spending to this degree. Has it ever happened before?

Why is there no effort to hold the administration and member of Congress accountable for what has clearly been their failure related to the federal government’s loan modification initiative? Why are we accepting such utter failure and holding them accountable for nothing, when in point of fact, their failure has cost the country trillions, and destroyed the lives of millions?
Instead it seems that we’re being corralled into a position where almost all of our efforts, even if successful, only have the potential to lead to a delay… a delay that in most cases reduces the potential to save the home.
We still have a democracy of sorts, do we not? Isn’t it the responsibility of our elected representatives to protect us from abuses caused by inadequacies in federal programs? Aren’t we supposed to be holding them accountable and demanding they so something. That’s how democracy is supposed to function, is it not? Why are we not trying to force our democracy to function, as it was intended to function… as it has functioned for hundreds of years?

Or, what about at the state level? Our AGs settled and let us down. That much seems water under the bridge, so fine. Well, I for one want the “new” servicer standards or guidelines to be more than mere suggestions… can they be codified at the state level.
I’d certainly feel a lot less let down by the AG’s settlement if the servicer standards were made into law that had a private right of action and a provision for attorneys fees because that would save homes and stop foreclosures, and it would do so more effectively than any amount of money.
Let’s UNITE homeowners around fairness, instead of DIVIDING them over delays…
I’m not talking about bailouts for borrowers, I just want the rules associated with a federal program to be followed and enforced, and I think every homeowner in the country should and would want that too, regardless of whether at risk of foreclosure or not at this moment.
Every homeowner in America should have an interest in federal programs operating as they were intended to operate. It’s not about who is at risk of foreclosure and who isn’t. It’s simply about being in favor of basic fairness in our federal or state programs. And basic fairness, competence and accountability from our elected officials. No one should, and few would, oppose any of those ideals, and those that suffered as a result of being deprived such fairness would engender sympathy from others.
Technically deficient paperwork, on the other hand, as was the crux of the Guillaumes decision by the New Jersey Supreme Court, is an entirely different matter. Guillaumes will appear to many to be a distinction without a difference. Who cares if the lender is mentioned on the notice or not… the answer is most assuredly not many people.
It will also appear to be a transparent a stall tactic, since even if the judge were to dismiss a foreclosure that failed to comply with the state’s Fair Foreclosure Act, the remedy would simply be to begin again. I realize that this would buy a homeowner some time, but it would not buy much, and the time it would buy would make it that much harder to get the loan modified, as time is the enemy of modifications.

The truth is, Guillaumes is what it appears to be… stalling… hoping for leverage, and losing a house to foreclosure. And that does not engender sympathy from homeowners not facing foreclosure. What it does is further divides those in foreclosure from those who are not.
Delays for technical reason are never going to make homeowners in foreclosure look good to those not in foreclosure. Don’t shoot the messenger, but it’s one thing if you’re being treated unfairly… screwed around by a government program where participating servicers who are receiving money from the program are not following the rules. That’s wrong in anyone’s book.
It’s quite another when it appears that all that’s happening is a delay of the inevitable based on what’s perceived as relatively trivial or technical, and that’s what comes to pass. This decision helps no one but servicers, and does significant further harm to the image of homeowners at risk of foreclosures as “deadbeats” postponing the inevitable.
I believe it is to large degree indicative of a need to re-think our strategy on behalf of homeowners and the foreclosure crisis. The track we’re on far too often has no win available, and can cause significant harm to the cause and the individual homeowners we’re trying to help.
I would appreciate responses to the ideas presented in this post, at least the Epilogue… Thank you.
Mandelman out.
Bank sues itself, wins, and then forces itself into bankruptcy to satisfy judgment

During the mortgage madness of 2003 – 2006, banks wore many hats related to the complex derivatives and mortgage-backed securities being packaged and sold to investors all over the world. Then, the meltdown forced many mortgage originators into bankruptcy and saw numerous financial institutions become insolvent. When the surviving banks acquired the various assets of the fallen… it became difficult or in some cases near impossible to ascertain from where certain risks might come.
Of course, the banking lobby has successfully resisted efforts aimed at breaking them up into more manageable entities, less capable of causing systemic damage to the global financial system. The industry’s position seems to be that every thing is just fine. Goldstein Such’s CEO, Lord Blankcheck, speaking at the dedication ceremony of the American Securitization Memorial, had the following to say…
“The size of our financial institutions is not the problem. Just because in some instances I have not been aware that we created a market in which we took a significant position and then on another floor were aggressively shorting that position, should not be a cause for concern. Remember, when that happened last year, we were able to unload our position as soon as we discovered it, and it was the Germans who ultimately took the hit. That’s what we mean when we say our systems are both agile and resilient.”
Critics, however, point to a recent case involving HPMagnum Chaste who, after acquiring the assets of Snare Burns and Punxsutawney Federal, buying some of the default servicing rights of Hemann Bros., the trustee division of Bakeley’s, a pool of loans once owned by World Slavings that had been originated by Dog Beach Mortgage before being sold to Dowdy Savings & Moan, which was later acquired by USA Bunko, and then buying Credit Default Swap counterparty positions once owned by Goldstein Suchs, but used as collateral for repo agreements involved in the hedging of assets tied to the commercial paper markets, until in 2008, the global financial behemoth began to arbitrage by becoming the bond holder and master servicer of a sub-set of loans that had been originated by Countrywide before BofA sold put options and preference shares to Morgan Stanley under an agreement whose terms may not be disclosed.
Apparently, Citibank was serving as trustee for the mezzanine tranches of some of the loans, and was the investor in the AA- 2-year CDO squared, but says the bank hired Wells Fargo to short AIG in order to protect itself from volatility in the asset-backed commercial paper market and the possibility of margin calls resulting from exposure to default by Greece, if it occurred in the third quarter of 2011, but through leveraging inverse interest rate swaps against bonds offered by Wachovia, through Merrill Lynch as trustee, IndyMac ended up as custodian, and servicer, with Deutsche as depositor.
In a bizarre twist of fate, when a homeowner is Shitsburgh, Tennessee lost his job at the local crayon manufacturing plant, and failed to make three months of mortgage payments, the entire structure unwound like a spring load bear trap, causing Moody’s to downgrade the country of Luxembourg from AA- to BB+, which forced MBIA to file for bankruptcy protection, and one of Jamie Dimon’s vacation homes to be sold at a trustee sale.
Goldman Sachs, however, says that it will record an $11 billion profit from the compound transaction although a spokesperson from the investment bank says the firms is not yet exactly sure why. “We know it’s a gain,” said Mimi Guffaw, a partner in charge of Goldman’s Double-barreled Default Anticipation Yield desk, known as D-DAY. “It’s always a gain. We just can’t put our finger on precisely where it’s coming from.”
The Tennessee homeowner says that the whole thing started when his bank called him to tell him that he qualified and should apply for a loan modification. He tried to explain that he had just bought the home a couple months back and had paid cash, but the Citibank representative said that it didn’t matter he would be receiving a Notice of Default later that month if he didn’t apply, or agree to pay 14 years of back taxes on the adjoining lot owned by a Danish concern.
In a related story, Bloomberg News is reporting that senior partners from cordovan loafer law firm, Mammoth, Pervasive & Bland LMNOP will testify in front of Senators Shelby and Bachus, along with several other members of the powerful Senate Banking Committee. The two partners, Godim Pervasive and Arenti Bland told the senators that the new regulations imposed under Doss Frank requiring banks to keep track of their capital positions and disclose derivatives that leverage defaulting sinking funds with option-adjusted durations, are far too onerous and if not repealed, will make our nation as a whole unable to compete globally and deprive hundreds of thousands of retired rail workers of their dental plans.
Heinreich Svenerrrson Bjork-Hadern, Assistant Monday Morning economist for the International Literary Fund said they are studying the problem carefully, but at this point all they could say with certainly is that either Spain is on much more solid financial footing than previously assumed, or Canada has unexpectedly just gone into default, causing firefighters in Muncie, Indiana to ask AIG for $4 billion in collateral and leaving U.S. taxpayers to pick up the tab.
President Oblabla held a press conference to try and calm global currency markets by introducing the head of his new Global Asset and Confounded Equity Derivatives Exposure Security Task Force, known as GAACEDESTF. No one noticed, however, and the president went to play golf with Herman Cain.

The Treasury Department is trying to unravel the global conflagration taking place in the over-the-weekend debt markets, which nobody had ever heard of, but apparently are crucial to keeping the power grid functioning in the mid-Atlantic states. Former SIGTARP Neil Barofsky has promised to try to figure things out, but again suggested that in the future Ben Bernanke refrain from accepting baseball card collections as collateral for loans made by the Federal Reserve, that the too-big-to-fail banks not be allowed to do more than three or four things at a time, and that leverage of 200,000 to 6 is taking things a bit far.
Bernanke says he doesn’t see the problem, noting that the Fed didn’t actually take possession of the baseball cards in question; rather it created a new form of security that is being called a “Promise to Insure Structure and Securitize.” Bernanke claims that by accepting PISS as collateral, the Fed is protected from fluctuations in the commodities markets that might otherwise lead to hyperinflation once oil prices have collapsed and the ongoing deflationary spiral has stalled.
“If something goes wrong, we won’t have the exposure that we might have had were we to be holding the actual cards, Bernanke explained. Under this structure, no matter what happens, all we’ll have as collateral for the loans is the PISS.”
Bernanke closed by saying that he thinks the U.S economy remains strong, even though the reverse opportunity swaps now secured by the Social Security Trust Account will like cause the Singapore Sovereign Wealth Fund to foreclose on The second and third floors of The White House sometime this summer.
Clearly, the obfuscation of information conveyance from financial institutes to the end consumer is a paradigm best explained by specialist terminology synergizing with superfluously convoluted modes of communication.
# # #
So, why did I write this? Because it makes just as much sense as everything else that’s going on in this country, and at least it made me smile.
Mandelman out.
100 INTRODUCTORY FACTS ABOUT MORTGAGE SECURITIZATION
It’s Gretchen Morgenson from The New York Times – A Mandelman Matters Podcast
One might imagine that these days there aren’t too many journalists that I have a whole lot of respect for, or that I find all that interesting, truth be told. I mean, watching the mainstream media ping-pong between the ignore-the-crisis and blame-the-borrower extremes, has changed my views of the media forever, I’d guess. Frankly, if you weren’t courageous enough to go against the grain on something this important… well, I don’t really have a use for you.
And, I know… there have been more showing up as it’s become more popular to do so, but that’s not the same as Gretchen Morgenson of The New York Times. She started writing about the economic meltdown in 2006, which was early… because it was before I started in 2007, which was also early. And she doesn’t write fluff… she’s just flat out really good.
When I read her, I can feel her passion or her honesty, I don’t think she writes what she doesn’t feel, and that’s both great writing and unfortunately rare writing. She’s done a huge amount of excellent work for many years now, even won a Pulitzer in 2002, but she’s a rock star of the economic meltdown and foreclosure crisis, no question about it.
Lately, Gretchen has been really going strong on foreclosure-related topics… the fraudulent document scandal, the Fannie report, DocX, the AG settlement, so I thought now would be a good time to have her on a Mandelman Matters Podcast. We had been planning to do it for a while, but I kept blowing it… she’d send me an email that would say, “How about this Tuesday,” or whatever, and I wouldn’t find it in my inbox until Thursday… stuff like that.
(I really do have to do something about my email situation… LOL.)
Anyway, she knew I really wanted to do it, so she set aside time on Saturday morning, right before she left for a week’s vacation on the slopes… and that makes her the nicest person on the planet, on top of being every other wonderful thing she clearly is. So, turn up those speakers, sit back and relax and listen to Gretchen Morgenson of The New York Times, as we talk about her book, “Reckless Endangerment,” the scandals, the settlement… and more on a Mandelman Matters Podcast.
CLICK TO PLAY NOW!
In the latter part of last year, the book that she and Josh Rosner co-authored, “Reckless Endangerment,” was released and even though I was in the middle of reading several others at the time, I rushed right down to buy it as soon as it arrived in stores. I didn’t read it right away,… I was in the middle of two or three at the time, as I said and so I flipped through it and went back to whatever I was doing.
To be entirely candid, it looked a little GSE heavy to me, so I didn’t even crack the book until Christmas came around and I had the time to devote to it that it deserved. Besides, by then I had started getting more suspicious that Fannie and Freddie were responsible for more of the problems than I had previously thought.
So, all I can tell you is… GET IT. You’ll like it a lot, and it’s not an intimidating read in the least. Plus, it fills in some blanks that you won’t find in any of the other books that are now displayed on the “meltdown” table at my Barnes & Noble.
CLICK BOOK TO BUY NOW ON AMAZON!
Mandelman out.
Why No Investigation?
Here's a bombshell: the San Francisco City Assessor commissioned a serious audit of foreclosure documentation filed in the past few years. The audit examined 400 foreclosures. It found problems with 85% of them, often multiple problems. What's more, some of the problems are pretty serious as they implicate not only borrowers' rights, but the integrity of mortgage-backed securities and the property title system.
The San Francisco City Assessor's audit also serves as a benchmark for evaluating the Federal-State servicing settlement. The San Francisco City Assessor managed to accomplish in a few months what the Federal government and state Attorneys General weren't able to do in nearly a year and a half with far greater resources at their disposal: perform a credible investigation of foreclosure documentation with serious implications about the securitization process in general. That's a lot of egg on the face of Shaun Donovan, Eric Holder, Tom Miller, et al. The SF City Assessor report shows that it really wasn't so hard for a motivated party to undertake a serious investigation. And that raises the question of why the largest consumer fraud settlement in history proceeded with virtually no investigation.
The lack of investigation was the compelling criticism that led the NY and DE AGs to stay out of the settlement for quite a while. I've never heard an answer as to why no serious investigation. As the SF City Assessor's audit shows, the documentation is all a matter of public record. It's not that hard to do, especially if you have the resources of the federal government. So the resources were there. The capability was there. So why no investigation? The answer has to lie with lack of motivation. Were the Feds and AGs scared of what they would find if they delved too deeply into the issue?
I hope that members of Congress will question the Attorney General and HUD Secretary the next time they show up to testify on the Hill. The issue is also worthy of a GAO or IG examination.
Now to be fair, there was a federal bank regulator review of some 2800 foreclosures and state banking supervisers did some sort of audit of Ally Financial's practices (the results of which are not public). But these audits are only as good as what they were looking for. If the focus was on narrow robosigning--the mindless signing of documents without verify the statements therein--that's a really different audit from what the SF City Assessor did.
The robosigning itself and similar lack of internal controls are the small potatoes. There are much more serious things in the SF City Assessor report.
First, the SFCA audit compared assignments in the public record with those that were represented to MBS investors in SEC filings. Anyone who's been following this blog knows that this is the securitization fail problem. And the SFCA audit finds evidence aplenty of this. Curiously, the OCC foreclosure review protocols don't include this sort of examination. Hmmmm. Wouldn't want to find out that we've got a massive securitization fail problem. That could trigger another financial crisis. So let's not look into it. If we ignore it, then Levitin and Yves Smith and others can just keep howling into the wind.
Similarly, the SFCA audit does a cross check between MERS records and foreclosure filings. As alleged in the DE AG suit against MERS, these records often don't match. That's a problem. Let me rephrase that: this is a HUGE problem. MERS is a self-privatization of part of a real property title system. Whatever one thinks of self-privatization of property records (reversing an Anglo-American tradition of government recordation that goes back to at least Richard I in 1194), the unreliability of the MERS system is just disasterous for real property title. As Judge Young said, MERS is the "wikipedia of land registration systems". The SFCA audit makes that seem like a generous comparison, as Wikipedia is often more accurate. Pretending the problem doesn't exist isn't going to make it go away.
The SF City Assessor report is yet another indication of how thoroughly rotten the Federal-state settlement is. While I'm on the topic, though, let me add in another one: the Federal-state settlement has folded into it a settlement between HUD and Bank of America for BoA embezzling from the FHA. The price tag for this was $1B, which seems to be double counted as part of BoA's contribution. That's appalling. Lee Farkas went to jail for a smaller fraud on the FHA. Think anyone from BoA is going to be in the pokey?
Let me suggest this: when a federally-chartered entity commits insurance fraud on the federal government, it should lose its charter and FDIC insurance. National banks exist by the grace of the federal government. That grace can be removed. Oh wait, we can't do that to BoA--it's too big to fail! Stripping BoA of its charter for defrauding the government just does not compute in the bank regulator mindset, which ignores that a federal banking charter is a privilege, not a right.
So there we have it. Once again, the federal government is held captive by the banks. The Too Big to Fail problem isn't a financial risk problem--it's a political problem, as too-big-to-fail means too big to regulate. The administration has had three chances to deal with too-big-to-fail: the bailouts, Dodd-Frank, and now the mortgage crisis, and it has shyed away every time. It's hard to think of a greater failing of this Administration.
Yes, the Administration did pass Dodd-Frank, which has important reforms in it, like the CFPB. But on what is really the most important financial regulatory issue--the need to end the political power of the banks, which will otherwise always be used to stymie effective financial regulation (or the administration of justice as we see here). Successful financial reform requires political reform, and breaking up the large banks is the only way we will see that political reform happen.
Note by way of comparison how the Feds brought the hammer down on Milken and Drexel for creating a junk bond bubble through a daisy chain of S&Ls (and a corrupt life insurer) that financed the destructive corporate raiding of the 1980s (and resulted in the creation of the CDO!). Drexel wasn't Too Big to Fail, and Milken wasn't from the same social millieu as many of the regulators. He wasn't their classmate, he wasn't white shoe, his lawyers hadn't been the regulators previous, and the regulators weren't looking for future employment with DBL. And he went to jail.
Today TBTF is a get-out-of-jail free card. But I want to emphasize that TBTF isn't the only thing going on here. Part of the problem, I think is a social one, as our political leadership is part of the same social milieu as our financial leadership and unwilling to call out criminal acts by their peers. The white shoe firms who were having their lunch eaten by Milken had no such qualms.
In the end, despite lack of investigation, 49 AGs signed onto the federal-state deal. Some of them signed on because they were able to narrow the scope of the release and get some level of federal buy-in and support for investigations on the securitization side of the bubble. In other words, for them, this settlement is conceived of as a first step, and signing on was part of a bargain. I hope it turns out to be a wise bargain, but thus far, the settlement seems an awful lot like Swiss cheese--it's got plenty of wholes and smells ever worse with time.
The Servicing Settlement: Banks 1, Public 0
What are we to make of the servicing settlement announced today with much hoopla? The short answer is not much. The settlement is the large consumer fraud settlement ever, but it accomplishes remarkably little in terms of either alleviating the foreclosure crisis of holding to account those responsible for the housing bubble and subsequent foreclosure abuses. As my Texas relatives say, it's “All sizzle, no steak.”
Instead, I think the settlement needs be seen as the conclusion to round one of an on-going struggle for accountability and reparations for the enormous damage the housing bubble did to the United States. Whether we will ultimately see meaningful accountability and reparations in the end is very much in question. Round two, featuring the Residential Mortgage-Backed Securities Fraud taskforce, could well be stillborn; the taskforce combines more motivated and more capable agencies, but it isn't clear of the motivated can leverage the more capable or will be bogged down by them. But as for this settlement, if this is all that we get, it’s a big nothing.
There are two big issues to parse in the settlement: what does it cover and what sort of relief does it provide. Not surprisingly, both are quite limited; the banks wouldn’t pay big dollars for a small release.The settlement covers mortgage servicing abuses, as well as a $1 billion settlement of claims that Countrywide (BoA) was cheating the FHA. It also includes settlements of litigation by the Arizona and Nevada AGs for BoA’s violations of an earlier settlement. It also covers some origination claims on which the statutes of limitations have run or will shortly expire. The settlement apparently (and here the precise language is crucial) excludes securitization-related claims, fair lending claims, false claims acts violations, MERS issues, and criminal claims. It also doesn’t prevent homeowners or investors from bringing their own suits. So it’s really covering robosigning and overbilling in foreclosures.
Given the relatively narrow scope of this settlement, it’s not surprising that the dollars involved are quite small compared to the overall harms created by the housing bubble and aftermath. The formal price tag for the settlement is $25 billion, although it is projected to accomplish up to $40 billion in relief. Only $5 billion of that is hard cash contributed by the banks. Let me repeat that. The five banks involved in the settlement, which have a combined market capitalization of over $500 billion, are putting in only $5 billion. That’s less than 1% of their net worth. And they are admitting no wrongdoing. To call that accountability is laughable.
That $5 billion in hard cash is going to the state and federal government, only some of which will be given to borrowers. What about the other $20 billion? That’s to come in the form of $3 billion in refinancings and $17 billion in principal reductions, deeds in lieu, short sales, anti-blight measures, etc. The banks receive variable credit for these actions, depending on whether these measures are taken for loans owned by the banks or owned by others and serviced by the banks. Basically, it’s full credit if the bank owns the loan, and half credit if the bank merely services the loan. Because of this formulation, the $17 billion in principal reductions, DILs, short sales is anticipated to result in $32 billion in actual relief. In other words, it is expected that the banks will modify the loans owned by others rather than the loans they themselves own. And when a second lien loan owned by the bank is involved, it only has to be written down pari passu (at the same percentage) as the first lien loan. So from absolute to relative priority, which is a major handout to the big banks, which have large underwater second lien positions.
Or put differently, $32 billion of the settlement is being financed on the dime of MBS investors such as pension funds, 401(k) plans, insurance companies, and the like—parties that did not themselves engage in any of the wrong-doing covered by the settlement. This shouldn’t be a surprise—the state Attorneys General previously cut a similar deal with Bank of America, which promised to make up for its wrongdoing by modifying loans own by other parties.
But let’s get to the bigger problem. Whether this is a $25 billion or $40 billion settlement is really beside the point. It’s a drop in the bucket relative to the scale of the problem. There is approximately $700 billion in negative equity nationwide weighing down the housing market and the economy. Add to that legions of homeowners dealing with unemployment or underemployment and we’ve got a problem that absolutely dwarfs the settlement numbers. It’s Pollyannism to think that this settlement will have any impact on the national housing market. At best it makes some incremental improvements and helps a small number of homeowners. But at worst, it lets the banks off the hook for the largest financial crime in history.
I can’t say I’m surprised, however. There was no investigation was done prior to this settlement. That had been the sticking point for a number of attorneys general who eventually signed on to the settlement, but only once it was narrowed. But that doesn’t take away the problem that there was no investigation. If you go bear hunting without any ammo, you aren’t going to bag a bear.
To illustrate how little the settlement does for the housing market, let’s take the settlement’s most optimistic projections and assume that it really results in $40 billion of mortgage relief of various sorts. How much does that translate into per distressed homeowner? Let’s assume that the universe of distressed homeowners is limited to those underwater—roughly 11 million. So we’re talking $3,636 per homeowner. That doesn’t help a whit in terms of preventing foreclosure.
Now to be sure, the relief will be more concentrated on a subset of these homeowners. The settlement is estimated to help about 2 million homeowners, hopefully to the tune of about $22,000 each. That's certainly a lot better than $3,636, but consider that the average negative equity is about $50,000. At a very generous best, then the settlement only gets rid of less than half of the negative equity for 18% of underwater homeowners. So we're talking about a solution that has less than a 10% impact. Best case scenario is less than 1 in 10 are helped. In any case, those luck few, will be chosen not by where the relief will help the most or by who is most deserving, but by what will be most advantageous to the banks. So some lucky group of homeowners will have “won the lottery” and in some cases might avoid foreclosure. For most distressed homeowners, it’s “no soup for you!” And because fixing the housing sector is about volume, this means that there's no soup for all of us--the housing sector will remain severely depressed.
What about the argument that the settlement will help the housing market by enabling foreclosures to start up again and for banks to clear through the shadow inventory? Well, what’s causing the shadow inventory? Is it the possibility of state and federal prosecutions for robosigning? Is it lack of uniform servicing standards? Nope, and nope. The shadow inventory problem is at core the result of two problems. First, the foreclosure system only has limited bandwidth—there are only so many foreclosures that can be processed at a time. Second, the banks have their own staffing issues. And third, the bigger problem is that the banks don’t have their paperwork in order to foreclose. This servicing settlement doesn’t affect any of these problems (maybe it will encourage better staffing on behalf of the banks, but if that hasn’t happened by year 5 of the crisis, I can’t imagine it will any time soon). National servicing standards as part of a settlement in no way replace existing state and local requirements, and to the extent they supplement them, it may make things harder for the banks. The fact that a bank is in compliance with the servicing standards in the settlement doesn't mean that the bank can in fact foreclose, and litigation of foreclosure actions is private litigation, not governed by this deal. (And this leaves aside the question of bank compliance with this settlement.)
The settlement also creates really awful incentives. It has zero deterrent effect against future wrong-doing. This settlement set a price-tag for mortgage servicing abuses. If the abuses are more profitable than the cost of settlement, what rational bank wouldn’t engage in them? The early CFPB-settlement analysis that was leaked months ago envisioned $25 billion as being simply the disgorgement component, not the remedial component. Here we have a settlement with $ 5 billion in actual disgorgement and very little that’s remedial, let alone punitive (which is necessary to have deterrence).
Also announced in conjunction with the big settlement were the fines the OCC is imposing as part of its consent orders. They total $394 million, but they are payable either in cash or in kind via relief given to homeowners as part of the OCC Potemkin foreclosure review process. Please Hammer, Don't Hurt 'Em! (Hmm, maybe the banks' theme song should be "U Can't Touch This".)
Is this really the best our government can do? I hope not. This settlement might or might not be the end of the attempt to rectify the financial crisis, but as things stand, we have a settlement in which the banks commit to follow the law and pay out some pocket change. The settlement doesn’t fix the housing market. It doesn’t create accountability for the financial crisis. It doesn’t even create incentives against future wrong-doing. But it provides the Obama Administration (and those attorney generals who just jumped in for the settlement at the last minute) with a fig leaf of political cover. It galls me is that the Obama Administration is going to trumpet this settlement as evidence that it is serious about prosecuting the crimes behind the financial crisis and helping homeowners. It was heartening to hear Obama talk about protecting the middle class in his State of the Union address. It was the right message, but the President is simply not a credible messenger. If Obama wants to run as the champion of Main Street against Romney, the Captain of Wall Street, he’s going to need to do something a lot more credible than this settlement.
The score: Banks 1, Public 0.
Federal Government and State Attorneys General Reach $25 Billion Agreement with Five Largest Mortgage Servicers to Address Mortgage Loan Servicing and Foreclosure Abuses
- Senators Urge OCC to Work with State Attorneys General, DOJ, and HUD to Hold Mortgage Servicers Accountable and Prevent Future Abuse
- Naked Capitalism | Yes, Virginia, Servicers Lie to Investors Too: $175 Billion in Loan Losses Not Allocated to Mortgage Backed Securities (and Another $300 Billion on the Way)
- NY Times | Attorneys General May Be Rushing Proposal for Loan Servicers
David Dayen | HUD Secretary Expects “Substantial” Payment of Foreclosure Fraud Settlement with MBS Investor Money
- David Dayen | The Schneiderman Gambit: Financial Fraud Unit Appears Designed to Fail, and Grease Skids for Foreclosure Fraud Settlement
- David Dayen | Consequential Monday Foreclosure Fraud Meeting Less than Consequential
- David Dayen | IG Report Whitewashes Firing of Foreclosure Fraud Investigators in Florida
Foreclosure Politics Here and Across the Pond – Professor David Coates on a Mandelman Matters Podcast
Since 1999, Professor David Coates has been the Worrell Chair of Anglo-American Studies at Wake Forest University. Prior to joining the faculty at Wake Forest he directed the International Centre for Labour Studies, and was Professor of Government at the University of Manchester in the United Kingdom. He also writes a blog at www.davidcoates.com, and it’s absolutely a fantastic read in all cases.
I found Professor Coates’ blog last year on my birthday as I was searching the Web for like voices and when I came across his, I felt like I had been given a birthday present. And I wrote to him at the time and told him exactly that.
David’s latest article, for example, is titled: Republican Truth and the Real Truth: GSEs and the Housing Bubble.
David and I have been communicating over the last year and I invited him to join me on a podcast because he offers points of view that are as fascinating as they are erudite and well-considered. They are also not the same thing you’ve heard before, as they cover the foreclosure crisis both here in the U.S and in the UK. He also talks about the global financial crisis and the political ramifications that are manifesting themselves in this country and frankly, what he says is important at every turn.
David has also written two books, both of which you can find on his blog. One is, “Answering Back,” which offers “liberal responses to conservative arguments,” and the other, “Making the Progressive Case.” Both are worth reading.
I’ve learned a lot from Professor Coates and I’m confident you will too. So, turn up your speakers… click below… sit back and relax… and listen to an uninterrupted hour with Professor David Coates as he talks about the foreclosure crisis here and in the UK, why democracy and progressive politics are more important today than perhaps ever before… and whole lot more… on A Mandelman Matters Podcast.
(Plus… I don’t know about you, but somehow the foreclosure crisis sounds better in a British accent… go figure.)
CLICK BELOW
Mandelman Out.
Schneiderman’s Fraud Task Force Subpoenas 11 Banks
U.S. Attorney General Holder, State and Federal Officials Announce Collaboration to Investigate Residential Mortgage-backed Securities Market
- Petition the Inspector General: Investigate Attorney General Bondi’s Firings of June Clarkson and Theresa Edwards
- Attorney General Eric Holder Justice Department looking into home foreclosure mess
- Ohio | Attorney General DeWine and Ohio Department of Commerce Announce Settlement with Carrington Mortgage Services















