Archive

Archive for the ‘NEW LEGISLATION’ Category

LET’S GET REAL ABOUT THE CRAMDOWN

February 2nd, 2009

Larry Loheit, the venerable Chapter 13 Trustee in the Eastern District of California, forwarded reports of trouble brewing on Capitol Hill over the proposed “CramDown” legislation, with reports by Janet Morrissey and Bloomberg. The Mortgage Bankers Association of Washington and other banking trade groups came out swinging last week, saying that the House Bill, HR 200, and its Senate companion, S 61 — dubbed the “cramdown” legislation — would be a disaster for consumers in the long run and push the battered mortgage market into an even deeper downward spiral. Methinks the Banks doth protest too much.

Heres the real problem: Home values are going to keep going down until they hit bottom; the bottom is the realistic value of the collateral, not what it was at the peak of the real estate boom.. It also has nothing to do with the amount of the indebtedness securing the collateral. The reality of the situation is that the mortgage boom was fueled by greed, rampant speculation, and rapid false appreciation of value of homes because of the fraudulent, irresponsible lending policies by innovative products such as 100% loan to value, income stated, negative-am, or the ticking time bomb, the fixed variable loan. Of course, there was plenty of greed on the part of amateur speculators, but the Banks get most of the blame in my view because they are supposedly in possession of superior knowledge, and aware of the cyclical nature of the real estate industry. They obviously forgot about the early 1990s and what happened when interest rates jumped to 21% when Jimmy Carter was president. Alfred E. Newman must have at the helm, with the “What, me Worry? Attitude.

The underlying problem with the mortgage lending industry is that they treated loans as products or commodities to be bought and sold on the open market, not as a professional service. This led to lenders approving people for loans who would never qualify otherwise, had the lender taken the trouble to realistically evaluate the borrowers strength. If youll recall, historically, banking was a local service where lenders got to know the borrower and realistically evaluate the collateral. Until fairly recent times, forty years ago, interstate banking was not allowed. Then banking was allowed to become a regional practice. Remember First Interstate Bank? There is history lesson and a reason behind the name. As banking deregulation increased, banks became national conglomerates, and instead of providing personal service to individual consumers, loans became “commodities” sold and traded on the open market the second they were funded. This led to CDOs, CDS etc which were sold to investors on the secondary money market. This was an exciting product for bankers and investors, because it was a good way to monetize the borrower, and investors saw great potential with limited risk. The loans were bundled and sold with the premise that because they were in a portfolio, the return was practically guaranteed, and even if a number of borrowers defaulted, the portfolio would remain strong. Unfortunately, the entire premise was false, because the underlying loans were no good in the first place, because the Banks were selling a product, not a service. This eventually led to the demise of New Century, Option One, Lehman Brothers, Bear Stearns and Meryll Lynch and many others, because they overvalued the collateral and the strength of the borrowers in the first place.

The banks stopped being in the business or providing a service; they never intended to service the loans long term and instead as loans were sold on the secondary money market, this practice gave rise to the “Loan Servicing Agent.” This is another misnomer, because they were not providing a service at all to the borrower, they were just collecting payments to the borrowers. Anyone who has tried to call a “Loan Servicing Agent” knows that they cant help you with your loan, because their business is collecting money, not solving problems. The nature of the banking industry changed from being a personal service to a commodities exchange. The core issue behind all of the mortgage meltdown is lack of personal service to the borrower.

Clients with overvalued homes and oversecured loans have no incentive to keep making the existing payments. From a purely financial analysis, most borrowers in California should walk away from their homes, because if your paying on a loan thats $100,000 to $200,000 beyond the value of the house, youre wasting your time. Your better of walking away from the house or filing bankruptcy, because the cost of the loan over time simply doesnt justify the purchase price. Even if you have a foreclosure or bankruptcy on your credit record, if you run the numbers on what youre paying for compared to the value of what youre getting, youre better off going through the pain short term and then buying an REO or getting back into a house on a lease option or some other sort of creative financing, that actually allows you to benefit from real appreciation at a realistic loan rate.

The banking industrys objections to the proposed cram down provisions are not surprising. They want to get as much money out of the loan as they can. All a cram down does is force them to value the collateral at a realistic price and its also measured by the borrowers ability to pay. The cram down legislation will force the Banks to face reality, which is what they should have done in the first place.

Is it unfair to other homeowners who arent in default and paying their loans? Of course it is. Well, maybe. Maybe not. On the other hand, if people dont stay in their homes and the foreclosure rate proceeds at the current rates, (there are estimates of 8-10 million foreclosures in the coming year) non-defaulting borrowers are going to continue to see the values of their homes go down. So another possible piece of legislation that Congress should consider is forcing the Banks to do loan modifications on loans that were made during the bubble period.. Right now, doing a loan modification outside the Bankruptcy court is very difficult, if not impossible. The Banks of course, will categorically reject this, but the reality is that they need people to stay in their houses just as much as the borrowers do.

The TARP thus farm has proved to be nothing but a welfare program for the banks. Thats because instead of freeing capital to lend to borrowers and small businesses, the Banks are saving their own sorry “assets,” and sitting on the money. Just talk to any real estate broker, the Retailers Association or the Building Industry, which stated that 50% of their members were going to go out of business in the next year, not because of lack of work, but because banks are yanking their members line of credit.

Its just a continuation of the pattern of self interest, greed, and lack of service to the consuming public. Congress needs to stop listening to the Banks crying “poor me” when they were the responsible financial parties who created the problem in the first place. The cramdown provisions are needed to stabilize the devaluation of homes and the astronomical loss of wealth in America that is destroying this country.

If Obama wants transparency and the Rule of Law, he should reject the pork in the current bailout package and tell Congress to forget about their partisan political agenda. Any legislation must include accountability on behalf of the banks on where their money is going in order to implement the greater purpose of restoring the health of the economy and confidence in the banking system.

Paul Bartleson

paulbar NEW LEGISLATION, PROPOSED LEGISLATION, Uncategorized , , ,

California Imposes New Notice Requirements Prior to Foreclosure

December 3rd, 2008

In the wake of the foreclosure crisis, the California legislature passed new laws requiring lenders to give additional notice to borrowers prior to recording a Notice of Default or Notice of Trustee’s Sale.

Senate Bill 1137 was signed by Governor Schwarzenegger on July 8, 2008, and became effective September 8, 2009. The following is a summary of new rules regarding foreclosure practices of lenders:

(a) A Notice of Default (NOD) cannot be filed until 30 days after contact is made with the borrower either in person or by telephone to assess the borrower’s financial situation and explore options to avoid foreclosure. The borrower must be advised that he or she has a right to request another meeting within 14 days.

(b)  The borrower must be provided with the toll-free telephone number of the U.S. Department of Housing and Urban Development (HUD) to find a HUD- certified housing counseling agency.

(c) If a Notice of Default is filed, it must include a declaration that the lender or authorized agent contacted the borrower, tried with due diligence to contact the borrower, or the borrower surrendered the property.

(d) If a Notice of Default was filed before July 8, 2008, then the lender or authorized agent must include as a part of the notice of sale a declaration that states that the borrower was contacted and lists any efforts made to contact the borrower.

(e) A borrower may designate a HUD-certified counseling agency, attorney or other advisor to discuss with the lender or authorized agent on his or her behalf, options to avoid foreclosure. Any modification or workout plan must be approved by the borrower.

(f) A Notice of Default may be filed when the borrower has not been contacted if the failure to contact the borrower occurred despite the due diligence of the lender or authorized agent to contact the borrower.

(g) A lender or authorized agent must provide a means for the borrower to contact them in a timely manner, including a toll-free telephone number that will provide access to a live person during business hours.

(h) If the lender or authorized agent has a Web site, certain specified information must be posted to assist borrowers to avoid foreclosure.

(i) When posting a notice of sale on a property, a trustee or authorized agent must also mail to the “Resident of the Property Subject to Foreclosure Sale” a specified notice in English, Spanish, Vietnamese, Tagalog, Chinese and Korean, stating that the property may be sold at foreclosure and if you are renting the property, the new owner may give a new lease agreement or provide you with a 60 day eviction notice. A copy of this notice is available on the DRE website at www.dre.ca.gov/mlb)industry.html

Interested persons should review the complete text of the law at www.leginfo.ca.gov.

paulbar NEW LEGISLATION

Positions by Seo-Watcher