Reviewing the Foreclosure Fraud Settlement

When the news broke about the settlement with the large mortgage servicing banks, led by the National Association of Attorneys General in cooperation with about a dozen federal agencies, I was happy and hopeful that the long months of work to get this done had come to a fruition about which I could be proud.  I knew it was possible, however, that the banks, partly through dragging their feet and partly through lobbying efforts, had gotten their way and avoided penalties for their despicable role in creating the housing bubble and unconscionably pushing foreclosures through without documentation or serious efforts to modify mortgages.

Probably both situations are partly true.  The reviews of the settlement by colleagues I have worked with in this effort have not been very favorable.  Today I will look at the criticisms from Dean Baker of the Center for Economic and Policy Research in light of the goals I previously highlighted in a July 2011 posting.  There I wrote the following.

Among the key items of our agenda are:

• broad availability of principal reductions to reset the housing market and remove the risk of more foreclosures;
• remedies for all who have been harmed by fraud or other criminal acts, whether they have already suffered foreclosure, are in process, or are facing impending foreclosure;
• the end of dual tracking, with simultaneous loan modification discussions and foreclosure procedures;
• all possible efforts for loan modifications and other non-foreclosure procedures should precede the initiation of foreclosure procedures;
• criminal prosecutions for criminal acts; and
• regulatory regimes to keep this kind of mortgage fraud from being repeated.

Baker's criticisms, which he calls the "big three" among many others that can be made, address a number of the points above.

He says first that it is not clear which loan modifications, principal reductions, and short sales will count toward the $17 billion amount the banks agreed to.  Will cases already completed or in progress count?  If so, then what does the dollar number mean about what banks will be expected to do now that the settlement has been agreed.  This raises the question whether there is "broad availability" of solutions, especially principal reductions, for homeowners.  If they can count what they have already done, and this pitifully small number has been set aside for the banks' total requirement, then most families facing foreclosure will not find any help in this settlement.

Second, Baker says, the banks may count loans they "service," not only loans they own.  So any principal write-downs or short sales in cases of serviced mortgages will not come out of the banks' own money.  They will be taking the money from owners of mortgage-backed securities or other purchasers of mortgages.  Obviously, it will be in their interest to use this legal caveat to avoid charging themselves any financial cost for their role in this crisis affecting so many homeowners.  In that sense, the agreement does not penalize the banks.  It allows them to use court authority to penalize investors.

Baker's third criticism addresses the last four of my points in the list above.  He says that thus far there is little evidence that the abuses that have led to and perpetuated this crisis have stopped.  He cites a case in San Francisco County, CA, in which an audit in the past month revealed a steady pattern of continued incomplete, falsified, and otherwise illegal documentation in foreclosure filings.  Fully 84% of the hundreds of filings had at least one violation of the law.  This matter of changing the way things are done is why North Carolina United Power continues its organizing strategy to audit county records to look for cases of foreclosure fraud.  Citizens, and public officials who will rise to their calling as public servants, must continue to gather data and press the case for changing the way of doing business when it comes to banking, mortgage, and foreclosure.

Defending Our Homes and Communities from NC UnitedPower on Vimeo.

Attorneys General Must Get Tough on Foreclosure Fraud

NAAG is the National Association of Attorneys General.  AGs from the fifty states and the various other jurisdictions such as territories, districts, etc., gather periodically to cooperate in how to manage common issues and work together on multi-state problems.  Some of the cooperative work they have done includes the Tobacco Settlement and the current Foreclosure Fraud Investigation.

Through North Carolina United Power, I have been participating with a working group of national organizations who are in conversation with the AGs about the Foreclosure Fraud Investigation.  Recently, we took a group to Chicago to meet with some of them about their work to protect homeowners and keep families in their homes.  I was interviewed by the local CBS radio affiliate in the hours before our meeting.

Among the key items of our agenda are:

• broad availability of principal reductions to reset the housing market and remove the risk of more foreclosures;
• remedies for all who have been harmed by fraud other criminal acts, whether they have already suffered foreclosure, are in process, or are facing impending foreclosure;
• the end of dual tracking, with simultaneous loan modification discussions and foreclosure procedures;
• all possible efforts for loan modifications and other non-foreclosure procedures should precede the initiation of foreclosure procedures;
• criminal prosecutions for criminal acts; and
• regulatory regimes to keep this kind of mortgage fraud from being repeated.

We were able to meet with four of the state Attorneys General:  Lisa Madigan of Illinois, Tom Miller of Iowa (the leader of the task force working on the foreclosure fraud investigation), Roy Cooper of North Carolina (President of NAAG who pushed the foreclosure fraud investigation forward), and George Jepsen of Connecticut (newly elected).  Our conversation was formal, perhaps overly so.  We discussed our agenda, they discussed their records, and then we exchanged questions and vague answers.  The time was short:  only 30 minutes.  There was very little new that came out of the meeting, but do not assume that I am saying it was not worthwhile.  Let me clarify why this was such an important meeting.

In organizing, we plan an action to get a reaction.  When we get our reaction, then we evaluate what we have learned and begin to plan future research and actions in light of it.  Our action in Chicago revealed a number of important things about our work on to change the conditions faced by so many families being hit by foreclosures.

This action showed something to our organizing groups, to the four AGs present in our meeting, to the many other AGs at the hotel but not at our meeting, and to the press and their readers.  To us, it showed that we have the power to bring the key law enforcement figures in the foreclosure negotiations to the table, even if we and they know they cannot negotiate publicly with us about potential criminal proceedings against banks.  Not only do they meet with bankers.  They also meet with us.

To the AGs present, we were able to deliver a multiracial, multiethnic, knowledgable, prepared, faith-based and non-faith-based, nationwide constituency to speak intelligently and passionately about this critical work they are doing.  They found us to be what we said, representatives of hundreds of thousands of citizens, thousands of churches and synagogues and mosques, and from states all across the nation.

To the AGs not present, we made it publicly clear that their colleagues who are leading in this foreclosure investigation are willing to meet with us.  Miller, Cooper, Madigan, and Jepsen will meet with us not only in their private chambers back home but in a public forum where they can express, even with the press in the room, their strong agreement with our agenda.  They were very adamant that they would not settle for an agreement that did not fundamentally change the practices of mortgage lending and foreclosure.  They believe the result must benefit homeowners and borrowers, not primarily get lenders off the hook.

To the press and their readers (including bankers) we were able to show that the case for principle reduction remains strong, with a powerful constituency.  Among the key items reported was the commitment to take banks to court if the negotiations do not bring fundamental change.  These AG negotiators  have not given up on a strong settlement and will not accept a weak settlement.  Our action got broad coverage in newspapers and in banking industry news sources.

The investigation and negotiation of a settlement could come very soon.  Or it could drag on through the summer.  Sooner is better, and we are expecting to see a court decree with tools to provide real help to homeowners.

Witness at Bank of America Shareholders Meeting

On May 11, 2011, North Carolina United Power (NCUP) gathered with some allies to challenge Bank of America to clean up its act concerning mortgage modifications and foreclosures.  We brought banners and posters, including a banner displaying the text of Micah 2:1-2.

Associated Press photo

Alas for those who devise wickedness
  and evil deeds on their beds!
When the morning dawns, they perform it,
  because it is in their power.
They covet fields, and seize them;
  houses, and take them away;
they oppress householder and house,
  people and their inheritance.

Rev. Clyde Ellis came from Virginians Organized for Interfaith Community Engagement (VOICE) came to speak about the disaster of foreclosures in Prince William County, VA.   Peter Skillern of Community Reinvestment Association-NC (CRA-NC) and Josh Zinner of Neighborhood Economic Development Advocacy Project (NEDAP) in New York City addressed the slow pace of improvement made by Bank of America in dealing with the enormous number of troubled mortgages they service.

Iraq Veteran Blackmon of the Harry Veterans Community Outreach Service in Winston-Salem addressed B of A's work with military families.  Rev. Spencer Bradford of Durham Mennonite Church spoke about bankers and homeowners sharing the same neighborhood, in the spirit of rejecting the utilitarian vision condemned by the Prophet Micah.  Rev. Dr. Greg Moss of HELP, Rev. Dr. Carlton Eversley of CHANGE, and many more from Durham CAN, Davidson County HOPE, Orange County Justice United, and the NC Latino Coalition, gave comments or stood to represent the continued efforts to bring change and justice to the foreclosure crisis.

The big news of the day came from information shared with us by the County Clerk of Court of Guilford County.  In our effort to slow down the railroading of foreclosures perpetrated through "robosigning" and other fraudulent practices of a hasty and careless banking industry, we have been meeting with County Clerks of Court in NC to promote the use of best practices in foreclosure procedings, especially in the determination of who holds the original promissory note on the mortgage.  We found that in Guilford County alone, the Clerk of Court had identified over 4500 fraudulent or forged documents presented to support foreclosures.  That is one county.  We had specific numbers for each bank, as well as the names of robosigners whom banks had employed.  We are calling for a county by county audit of foreclosure documents in NC to get to the bottom of this illegal practice.

Associate Press photo

The following is the speech I gave to open the witness outside the shareholders meeting.

Good morning.  I am Dr. Mike Broadway of Shaw University Divinity School and Mt. Level Missionary Baptist Church in Durham.

When theological educators in North and South Carolina issued a statement on this economic crisis, we identified key convictions about justice and the economy from our tradition of faith.  Among those convictions was that all people should share in the gifts of God's creation.  Another was that no society can allow a permanent debtor class to emerge, a kind of debt-sharecropping.  A third, among many more, was that the risks and benefits of the economy should be shared by all participants, not dumping all risks on the weak and paying bonuses to the elite.  It is with these kinds of convictions that we stand here today to address foreclosure fraud and mortgage modifications.

Some people say theologians and preachers should stay out of this business.  That's nothing new.  Long ago in the days of the Prophet Micah, the so-called leaders of the people  did not want to hear what he was sent to say.  The economy was in turmoil and people were suffering mightily.  But the leaders preferred a preacher who would gloss over it all and say, "Live it up!  Go have another drink!  Life is good!"  They wanted happy talk while people were losing their homes and livelihoods through fraud and injustice (Micah 2:6-7, 11; Isa. 1:15).

We don't want to be those kinds of preachers.  We don't want to be churches of the sort that Fannie Lou Hamer came to despise during her civil rights work.  She saw so many churches as hypocrites gathering "for the sake of paying the minister's way to hell and theirs, too."  No, we do not want to join the misleaders of the people.

Both the Prophets Micah and Isaiah challenged the financial and political elites of their day for being misleaders.  To the financial leaders they said, "you mislead and confuse the people," and "the spoils of the poor are in your houses" (Micah 2:1-2, 8-9; Isa. 3:12-14).  Back in those days, and now in our time, the financial elite manipulated the structures of the economy "because it is in their power" (Micah 2:1).  They preyed on the hard-earned livings of the working people.

The prophets said that the "add house to house" and "field to field," leaving "many houses desolate" (Isa. 5:8-9; Micah 2:2, 9).  In ancient Israel they foreclosed on the working class in massive numbers, transferring wealth from the producers to the predators, just as is happening in our day.  They turned from leadership to predation.  The prophets say the obvious:  the poor are losing their homes and livelihoods and widows and orphans are abandoned.

Why can this happen?  It seems patently unjust that some can ruin others simply "because it is in their power."  The prophets go on to say that the foreclosures and mass economic turmoil happen because political leaders "write oppressive statutes" and "turn aside the needy from justice" (Isa. 10:1-2).  Just yesterday, ten Attorneys General of the states met in Atlanta to oppose and try to derail a fair resolution of the mortgage crisis.  Recently, the Comptroller of the Currency suggested that the banks need not bear the weight of setting things right in this foreclosure crisis.  Then who will bear it?  If it is not a shared burden, then average homeowners will bear this burden that is too great for us.  We don't need this kind of misleader deciding our futures.

We think that Bank of America wants to be a leader for the average consumer.  We think that Bank of American can be a leader in finding a resolution for the foreclosure crisis that will be good for all parties.  That is why we are here today.  We are calling for leadership toward a just, streamlined process for mortgage modification, foreclosures as a last resort, and a solution that makes the Bank more profitable while keeping people in their homes.

It may seem that we are just a few average, unimportant people standing here today calling out for justice in the tradition of Micah and Isaiah.  But to quote Marian Wright Edelman, "You just need to be a flea against injustice.  Enough committed fleas biting strategically can make even the biggest dog uncomfortable and transform even the biggest nation."  And enough fleas can transform the biggest bank, too.

Theology and Economy Update

For those of you who check in here now and then, you probably know that in 2009 a group of theological professors in North Carolina and South Carolina distributed a working paper, "Theological Reflection on the Economy."  It was an early step in a series of actions and campaigns through which faith communities have organized around economic justice in the current economic crisis.  Since that time, I have occasionally communicated with the group of professors about active campaigns, particularly the "10% Is Enough" work on usury pertaining to credit cards and other consumer interest.  This week, I sent a note to update them on the range of actions and campaigns in which North Carolina United Power has continued to organize in the past year and a half.  Here is an excerpt of the note I sent them.

Hey, folks,

A year and a half ago I was sending you lots of emails as we started work on a major organizing campaign dealing with economic justice issues.  As theological scholars and servants of the church, we recognize our responsibilities to follow Jesus in the task of serving the poor, offering ministry of relief, building ecclesial structures to reshape economic life in our neighborhoods, and seeking justice in the face of economic powers.  Thus, the theological reflection leading to the "Theological Reflection on the Economy" of 2009 was an exercise of our vocation which helped to provide grounding for faith-based people's movements which have gone many directions.  The document has been studied in churches, in minister's conferences, in seminary classes, and far beyond North and South Carolina. 

The paths of discipleship continue to open before us even now.  Let me highlight some of the work linked to our efforts of 2009.

1.  The "10% Is Enough" campaign in the Eastern US, London, and Berlin, has continued to bear fruit.  We did not convince banks to voluntarily cap credit card interest rates, nor did with convince Congress to cap consumer interest rates.  But we have built relationships with bank executives which are paying off in continued access and influence.  Moreover, leaders of the "10% Is Enough" campaign have met with Dr. Elizabeth Warren to help shape the Consumer Financial Protection Agency.  Caps on interest rates continue to be a lively topic, in part because of the strong work of MetroIAF, of which we have been a part.

2.  The "6% Is Enough" campaign to protect military families from predatory credit practices and foreclosure has been an overwhelming success.  This is a NC United Power campaign, and we have worked with Wachovia/Wells Fargo and Bank of America.  B of A held ongoing conversations with us for over a year.  Last summer they agreed to everything we were asking for, extending benefits beyond the legal requirements for nine months of protection from rising interest rates.  For several months, they were reluctant to admit publicly that they had changed their policies in response to negotiations with NCUP.  This month, in a surprise turn, CEO Brian Moynihan publicly thanked NCUP and Gerald Taylor for our work in this crucial area.  Our fellow signatory, Dan Rhodes, was present to meet personally with Moynihan, the first time he has met personally with members of our organization.

3.   The effort to bring justice to the foreclosure crisis has taken off in recent months, in part because of the attention that NC Attorney General Roy Cooper has given to foreclosure fraud as President of the National Association of Attorneys General.  For this work, NCUP (also going by the name IAF-SouthEast) has made partnership with People Improving Communities through Organizing (PICO), National People's Action (NPA-US), Alliance for a Just Society, and the Alliance of Californians for Community Empowerment (ACCE), all faith-based community organizing groups, stretching our organizing from the west coast to the east coast, from the Rocky Mountains to the midwest to the south.  We have met with key leaders, including Iowa AG Tom Miller and NC AG Roy Cooper, all the while keeping our efforts alive with Bank of America.  One summary of our proposals, "The Homeowner's Bottom Line," has gained significant interest, and most of its proposals remain on the table in the nationwide AG's investigation and potential settlement with the major banks to improve the foreclosure process.

4.  In conversation with a major funding organization (no funding yet) for theological education research, I have piloted a course at Shaw University Divinity School, "Pastoral Readiness for Economic Crises."  We covered financial literacy and financial freedom for pastors as well as a form of Christian formation for churches and their communities.  We looked at a wide range of theological sources on money, possessions, economics, and consumption from the earliest churches down to our times.  We looked at tools for churches to evaluate their relationships with banks that may or may not be serving poor communities.  We looked at models of community development, such as the Christian Community Development Association model of ecclesial politics of neighbor love.  Finally, we looked at faith-based community organizing.  With this trial run under our belt, I am hoping to work with some of you as partners in developing a proposal for adapting this sort of clergy training to other seminaries and to continuing education programs for current pastors.

5.  The predatory practices of payday lenders and car-title lenders will not die without a fight.  From Texas to North Carolina, from Mississippi to New Hampshire, strong lobbying efforts to open the door to astronomical interest rates on small dollar loans are alive and well in the state legislatures.  I've testified before legislative committees in Texas, mentioning you all and our work.  Just this past week, a bill was introduced in the NC legislature to reopen the door to usurious rates.  When there is the chance of ripping people off legally, there will always be people trying to do it.  Contact your legislator right away to stop the progress of HB 810.  South Carolina, having passed important reforms in 2009, seems not to have any pending legislation at this time.

On two matters I am seeking your response to moving forward with this work. 

First, . . . we are considering a clergy witness [at an upcoming event], with particular attention to dealing justly in the foreclosure crisis. 

The text of Micah 2:1-11 is directly relevant to this matter (not to ignore Isaiah 5:8-17).  The injustice of Samaria and Judah included coveting and seizing houses, ruining people financially (v2).  The powerful put people out of their homes (v9).  All the while they continue to practice the trappings of faith.  Predictably, they demand that anyone who might preach judgment against their greed should stop saying that stuff (v6).  The prophet says they only want a preacher who says, "Go on and get drunk.  Live it up!" (v11), while they "rise up against my people as an enemy" (v8). 

We hope we might gather 100 clergy and seminarians to speak a word of witness about the injustices of foreclosing on people whose financial security was destroyed by the greed, risks, and fraud of bankers, brokers, and insurers. . . . Details of when and where to meet will be forthcoming, depending on whether we believe we can gather an appropriate-sized group for witness.

Second, I will be trying to convene a meeting of some of you professors in late May.  If you would be interested in meeting for three or four hours to evaluate the course I put together and to brainstorm about expanding clergy training for economic life, let me know. . . .

For more information, see

News coverage of recent NCUP action:  here and here

Foreclosure Justice:  Homeowner's Bottom Line 

Broad Campaign for Financial Reforms:  Showdown in America

Against Usury:  10% Is Enough 

Military Families:  6% Is Enough 

Periodic updates on "earth as it is in heaven"

Banks Sucker Punch Military Families

As part of the work on resetting the economy, North Carolina United Power and the IAF-SE have been pressing for banks to obey the law in dealing with loans to military personnel.  The law, revised in the past decade, says that when soldiers are on active duty, all of their loans must be capped at 6%, and any existing interest above that level must be forgiven.  Moreover, when they are on active duty and three months beyond, a bank cannot start foreclosure proceedings or other debt recovery strong-arm tactics. 

We took up this cause because we were hearing many stories about how banks were not following these laws.  And that does not even take into account all of the predatory lenders, loan sharks, and such who open for business just outside the gates of military bases.

We made good progress in these negotiations with big banks and with NC government officials.  Bank of America was especially responsive, offering unilaterally to extend the grace period law demands from three months to nine months.  By doing so, they give room for the new shape of military deployment which relies heavily on National Guard and Reserves and which has led to numerous sequential tours of duty.  The law did not anticipate this change, and it has hurt many military personnel whose cases have not been handled correctly.

In case anyone wondered whether this is a real problem, a recent news article points out that at least one major bank, has admitted to breaking the law in dealing with military families.  J.P. Morgan Chase was foreclosing on military families while they were bearing the weight of active deployment.  The article names only a few cases.  I suspect that a committed investigative reporter would find many, many more at all major banks, in regional and local banks, and an explosion of cases among payday lenders, car title lenders, and other criminally conceived businesses trying to fly under the radar.

Let me again acknowledge Bank of America for its promises to improve services and go beyond the letter of the law in working with military families.  We have had some hopeful conversations with Wachovia-Wells Fargo who has had experience operating a specialized military bank out of San Antonio, TX, but they have not made any commitments in response to our requests.  Obviously, J.P. Morgan Chase has had to come clean on a few cases.  I hope some other groups working toward economic justice will raise these questions locally to stop the sucker punching on these families who already face stress and problems beyond what anyone should have to face.

Push the Reset Button on Housing

That's what Gerald Taylor of North Carolina United Power keeps saying:  "We need to push the reset button on the housing market."  The economy got thoroughly messed up by the speculative, reckless practices of the mortgage industry.  The government responded by bailing them out.  They got their derivative market reset.  They get to borrow money for virtually zero per cent interest.  AIG got to push the reset button.  GM got to push the reset button.

But the banks don't want to give the rest of us a chance.  In a mess they willingly helped to make, they got off the hook.  The winners got to buy up their competitors for cents on the dollar.  They were allowed to voluntarily find ways to help homeowners, unemployed workers, pensioners whose incomes evaporated, and other victims of the economic crisis.  But they don't want to do it.

They string families along with delays and lost paperwork, offering loan modifications while simultaneously working full steam, even fraudulently, to move the foreclosure process forward.  Attorney General Tom Miller of Iowa says that this dual-track process of promising modifications while fast-tracking foreclosure is "insane."  What sense does it make for a family to get a loan modification proposal from the bank on the same day that the bank sold their house?

Give homeowners the same chance.  Reduce mortgage principal across the board to current market values.  That's right--we need across-the-board principal reductions for homeowners underwater, whether they are behind in their payments or not.  Push the reset button.  Make a market correction.  Why?

1.  Unemployed and laid-off workers, retirees depending on pensions, and many homeowners who bought market-rate homes with the assurance that the market was operating in a rational manner (when almost no one--not even the revered Alan Greenspan--recognized the housing bubble) did not come into financial misfortune because of carelessness, greed, or risky behavior.  They were overwhelmed by the economic tsunami from the collapse of the derivative house of cards.  Getting them on their feet and keeping them in their homes will help stabilize the economy.

2.  Foreclosing on one family, then selling the same house for half-price to another family is pure stupidity.  Without all the human trauma and with less paperwork and financial loss, banks could renegotiate reasonable mortgages for the people who are at risk of foreclosure. 

3.  Neighborhoods and communities where many foreclosures have happened become depressed, forcing down the value of other homes.  This puts more homeowners underwater and creates new risks for foreclosures.  Stabilizing neighborhoods by keeping families in their homes and paying modified mortgages is good for all of us.

4.  The so-called moral hazard of adjusting loans in a way that is beneficial to the borrower is a smoke screen.  If banks were being swindled into letting people off the hook who never intended to pay their mortgages, that would be a moral hazard.  But the true moral hazard came when the mortgage industry turned into the anything-goes-mortgage-derivatives orgy.  Even admitting that some homeowners took stupid risks or failed to do due diligence before borrowing, the risks and benefits of mortgage finance have to be shared.  Letting the banks off the hook for their bad debts while holding small borrowers accountable for their debts is an unjust financial system.

So set the reset button for homeowners.

Pillars of the Home Mortgage Business: Fraud, Lies, Theft, and Greed

I know everyone in the home mortgage business is not a thief and liar.  Let me make that plain.

Yet it is clearly the case that the ongoing foreclosure explosion has become a money-and-power-grab by banking executives and major shareholders who will stop at nothing to make sure they don't lose a dime on their crappy mortgages, no matter how many families they have to put out on the street.  First it seemed they were simply unprepared for such a large number of mortgages going underwater.  Then it seemed they were disorganized and careless about people's paperwork.  Of course there was the disingenuous worry about "moral hazard," as if the real moral hazard had not been perpetrated by the financial system that speculated and cast away all standards in order to create more and more billions of mortgage backed securities.  Eventually it became clear that even the mortgage foreclosure cases that were progressing were not undergoing due diligence.  Then cases of "mistaken" foreclosures began to pop up more and more.  Finally, banks began to admit the ways they have been breaking the law in order to prevent loan modifications and recourse against foreclosure proceedings.  What is emerging is a coordinated and willful theft of homes from average homeowners.

So this week organizers from all over the country have converged in Des Moines, Iowa, for a summit on ending the ongoing bank misconduct and lawlessness in home foreclosures.  Gerald Taylor and I represent North Carolina United Power at this meeting, along with people from coast to coast who are fed up with the impunity of banks in the current financial crisis.  Like me, you may wonder, "Why Iowa?"

There are two reasons to meet in Des Moines.  First, Iowa Citizens for Community Improvement have a long history of making a difference for working people who are being abused by the powerful.  They are hosting our gathering.  Second, Iowa Attorney General Tom Miller is the lead lawyer for the national investigation into illegal banking activity in the foreclosure crisis.  He will meet with our group to discuss the ongoing investigation and the possibilities for working together toward a just resolution of this crisis for all parties.

We want three major elements for a just solution. 

1. Hold banks accountable for real, transparent loan modifications with borrowers before any foreclosure proceedings, including lowering rates, to keep families in their homes.
2. Mandate principal reduction for owner-occupied homes as a first-line modification tool.
3. Include remedies for homeowners who have lost their homes to be reinstated as homeowners or financially compensated for the effects of this unlawful, corrupt system.

 We will not solve it with one meeting, but we hope to see another vital step this week.