May 5, 2024

Debate On Loan Modification Continues: Free Enterprise Vs Free Government

The debate seems to intensify on a daily basis regarding the merits and legitimacy of for profit loan modification companies.  Officials of HUD, Hope and the banking industry continue their criticisms of the loan modification industry by noting that they offer for free the service that many borrowers are now paying for.

Consider some recent comments from both sides debating the merits of for profit loan modification.  Daily Herald

“You don’t need to go out and hire someone to help you,” said Michael Gross, managing director of mortgage servicing for Bank of America. “It is very, at times, frustrating to find a homeowner who has paid a for-profit company $3,000 to $5,000 in an upfront fee, when they could have gotten the same or better assistance free.”

“Nonprofits are not as efficient as the regular market,” said Moose Scheib, head of Michigan-based LoanMod.com, a loan modification firm that charges homeowners $1,500 to help renegotiate their mortgages. “I think the difference is probably more attention you get from us.”

“Once a borrower pays an unscrupulous loss-mitigation consultant and time is wasted, the damage has been done,” said Sarah Bloom Raskin, Maryland’s commissioner of financial regulation. “While we may be able to recover fees, we can never recover the lost time — time that the borrower could have used to work out a bona fide loan modification.”

“We are extremely concerned about the huge proliferation of for-profit companies making a buck on these people,” said Laurie Maggiano, senior policy adviser at HUD’s Office of Housing.

Clayton Sampson, founder of U.S. Housing Assist of Nevada, which launched in July, said nonprofits provide a great service, but added, “We have a lot of clients that need us.”

Sampson said he spent five years at a mortgage brokerage and his contacts have enabled him to customize workout plans for a homeowner’s lender. His firm charges a minimum of $2,500, but he said he would return the money if he was unable to help the homeowner.

Some developments that I foresee in 2009 include the following:

As the number of mortgage delinquencies and foreclosures increase, the loan modification business will receive more scrutiny from state and federal regulators.  I would expect that many more states will introduce tough licensing and bonding requirements for any firm engaging in the loan mod business.

Companies involved in the loan mod business may be required by regulatory decree to provide full disclosure to a potential customer that loan mod services are offered for free by various agencies.

If the number of complaints about loan mod companies grows dramatically, strict federal regulations may be passed.  For example, it is possible that HUD would  require that banks and loan service providers deal only with third parties approved by HUD on any loan modification.

The loan mod companies that remain in business will have to give potential customers a compelling reason to deal with them, especially as consumers become aware of the free loan mod services available.

Few May Benefit From Lower Mortgage Rates

Rates Increase

Mortgage rates increased today on a sell off in the Treasury market. The benchmark 10 year treasury note increased in yield by 16 basis points (bps) to 2.244%. The 2008 low on the 10 year treasury yield was 2.038%.

Courtesy Yahoo Finance

The increased yield on the treasury bond has resulted in a mortgage rate increase of 3/8% over the past few weeks.   A 30 year fixed rate mortgage at par today is 4.875%, historically a super low rate.  So what if rates moved up a little bit – 4.875% still sounds almost too good to believe.

Low Rate Does Not Apply To All Borrowers

Before rushing out to refinance, be aware that the advertised low rate of 4.875% is available only to the most perfect borrowers and the 4.875% rate will cost around 1 point (1% of the loan amount) plus other closing costs.

Unless a borrower has perfect credit (at least a 720 FICO score), adequate income (debt ratio of 32% or less) and substantial equity in the home (loan to value of 75% or less), the rate will be higher due to adders.  Adders are fees imposed by Fannie and Freddie if the applicant does not fit into the little box of a perfect borrower.  Adders are imposed for higher loan to value, lower credit scores and cash out refinances.  The adders can easily amount to 2% of the loan amount, or $2,000 on a $100,000 loan.   If a borrower is applying for cash out with a FICO score below 680 many lenders will turn the loan down.

Here’s an example of what used to be considered a prime borrower in the recent past.  Borrower has a 680 FICO score, adequate income and wants $20,000 cash out with an 80% loan to value and a loan amount of $160,000.   The chart below shows the cost of not being a perfect borrower as defined today.

Interest Rate

6.750%

Price Adjustments

-1 FICO 680-699, LTV 75.01-80

-0.8750 C/O Refi. LTV 75.01-80, FICO 680-699

The best rate this borrower would get quoted today would be 6.75% and the mortgage company would need to charge an additional 1 to 2 points on the loan (up to $3200 based on a $160,000 loan amount).

This is the reality of the mortgage market today.  Many borrowers applying for a refinance with visions of a 4.875% rate and a payment reduction are finding out that they do not qualify.   There is much in the news about the “mortgage refinance boom”.   Expect to see stories in a month or two about how few borrowers actually benefited from the lower rates.

FHA Takes A Closer Look At Home Values On Refinances

HUD announced in Mortgagee Letter 2008-40 that effective January 1, 2009 that FHA will require a second appraisal for all cash-out refinances where the loan to value, exclusive of UFMIP,  exceeds 85% of the appraised value.  The new rule applies regardless of the loan amount or the location of the property.

The actual letter ruling reads as follows:

· Second Appraisal Requirements/Loan-to-Value Limits for Cash-Out Refinances: The instructions in ML 2008-09 regarding when a second appraisal is needed, and the requirements for that second appraisal, as well as the 85 percent limitation on cash-out refinances when the loan balance will exceed $417,000, remain in effect.

In addition, FHA will now require a second appraisal for all cash-out refinances where the LTV, exclusive of the UFMIP, will exceed 85 percent of the appraiser’s estimate of value. This second appraisal requirement applies regardless of the loan amount or the location of the property, i.e., whether the property is in a “declining area” or is not. This second appraisal requirement for cash-out refinances is effective for all case number assignments on or after January 1, 2009 and is to adhere to the instructions set forth in ML 2008-09. Please also note that cash-out refinances with LTVs exceeding 85 percent will be over-selected for post-endorsement technical reviews (PETR) to assure the quality of the underwriting.

Additional underwriting and eligibility criteria

· The subject property must have been owned by the borrower as his or her principal residence for at least 12 months preceding the date of the loan application.

· If said property is encumbered by a mortgage, the borrower must have made all of his/her mortgage payments within the month due for the previous 12 months, i.e., no payment may have been more than 30 days late and is current for the month due.

· The property that is security for the refinanced mortgage must be a 1- or 2-unit dwelling.

· Subordinate financing may remain in place, but subordinate to the FHA insured first mortgage, regardless of the total indebtedness or combined loan-to-value ratio, provided the homeowner qualifies for making scheduled payments on all liens.

· Any co-borrower or co-signer being added to the note must be an occupant of the property. Non-occupant owners may not be added in order to meet FHA’s credit underwriting guidelines for the mortgage.

The FHA has been gradually tightening various underwriting guidelines for some time now, probably due to a default rate of over 12%.

The  new regulation requiring 2 appraisals on cash out refinances will probably reduce the number of refinances done on higher LTV properties.  The customer typically pays for the appraisal when doing a refinance and the FHA appraisal usually costs $350.  A potential borrower will now have to come up with $700 just to find out if they have enough equity in the property.

Actually the rules could have been constructed to further restrict cash out lending.  Many lenders who have doubts about the value of an appraised property routinely require a second appraisal to be conducted by an appraiser of their choice.  Often times, the second appraisal will come in lower under this method.

The FHA has seen a large increase in loan applications in 2008 due to underwriting restrictions imposed by other lenders.  It will be interesting to see if these new guidelines reduce the number of FHA refinances in 2009.

Is A Loan Modification Worth The Cost?

With the large number of people in arrears on their mortgages, various governmental agencies have been attempting to provide solutions.   Loan modifications have been proposed as the answer for over a year now.  The FDIC has recently been pushing this as the solution to keeping people in their homes and  spearheaded the effort to formalize and streamline the mortgage modification procedure.

From a practical standpoint of the person who is behind on their mortgage, the most important questions to ask, assuming that you want to remain a homeowners, are as follows:

  1. Do I qualify to have my mortgage modified?
  2. Will a loan modification help me in the long run?
  3. Should I pay someone to get a loan modification?

1.  As far as qualification goes,  a good place to start is by reviewing the new SMP guidelines – see Streamlined Modification Program – Who is Eligible? If a review of the guidelines leads you to believe that you qualify for a loan modification, a good way to start is by calling your loan servicer directly, whose phone number is on your monthly statement.

Be advised, however, that nothing is simple when it comes to a loan modification.  The process is controlled by different parties with different interests.   If your mortgage is not owned by Fannie Mae or Freddie Mac, the SMP guidelines that they issued may not apply to you.  A large percentage of mortgages originated over the last five years were sold on a worldwide basis to many different investors.  Generally speaking, the loan servicer that you are dealing with is operating under the guidelines of the investors who own your mortgage.  Some of these investors are willing to do a loan mod and some are not.  The terms of a loan mod that each investor allows will differ depending on their guidelines.

2. Whether or not a loan modification will help in the long run is a complex topic and will be the subject of another post.  Each loan situation is unique but if we examine the data from the Comptroller of the Currency, Office of Thrift Supervision, the results of a loan mod after 6 months showed re-default rates of 50 to 60%.

Three Months After Modification (30+ Days Delinquent)

Six Months After Modification (30+ Days Delinquent)

On-book portfolio (loans held by servicers)

35.06%

50.86%

FHLMC (Freddie Mac)

39.09%

57.87%

FNMA (Fannie Mae)

38.34%

57.11%

Private Investors

42.28%

60.76%

3.  Assuming that questions number 1. and 2. were answered with a “yes”,  a potential loan mod applicant should assess whether or not it makes sense to pay someone to do the loan modification for him.  The loan mod business seems to growing larger every day with a large number of companies offering to provide  loan mod services.   Some factors to consider when deciding whether or not to engage a loan mod company to help you include the following.

-How difficult will it be to get my mortgage modified?  The best way to get a preliminary assessment of this is to call your loan servicer, whose number is on your mortgage statement.  Depending on your situation and who owns your loan, it may be relatively simple to provide the servicer with the documents that they are requesting.  Many servicers and investors consider getting your loan current again to be in their best interests so they should be willing to help you out.

-If for whatever reason you do not want to deal with the loan servicer directly a call to a non profit organization such as Hope Now cannot hurt.  I have heard some people say that they have helped, some say that they are a waste of time; either way, a free phone call is an easy way to find out.

-Keep in mind that if you do engage the services of a loan mod company, they do not have any special powers of persuasion over the the investor owning your mortgage.   The loan servicer is going to make the same modified payment offer regardless of who they deal with.

-The price of a loan mod varies depending on what company you engage to help you.  I have seen prices ranging from $700 to $3500.  The amount of fees charged upfront also varies as do the service guarantees.  Some companies want the entire fee upfront and sometimes the entire fee is nonrefundable.

-If a loan mod company has expertise in the mortgage modification business they should be able to give you an accurate idea of what they can accomplish for you.  For example, there are some servicers (due to restrictions by the investor) who essentially refuse to modify a mortgage.  Regardless of who owns your mortgage, the loan mod company should be able to tell you give you a good idea of how your mortgage will be modified and what your new monthly payment will be.

-A principal reduction is done by very few servicers so if the company you are speaking to guarantees that they can do this for you,  be very skeptical.

-Do not work with any loan mod company without first checking their references.  There are few state or federal licensing requirements or proof of expertise required to enter this business so it is “buyer beware”.     Do not pay more than a modest nonrefundable application fee ($300 to $400 is common).  I would also not recommend engaging a loan mod company whose fee is nonrefundable.   You are paying for their expertise and they should know if they can help you before they take your money

-If your mortgage is delinquent by 90 days, which is usually required before a loan can be modified, do you really have up to $3,500 to spend getting your loan modified, when the odds of re-defaulting are up to 60%?

Conclusion:

There are reputable loan mod companies willing and able to get your loan modified for you and save you the time and hassle of paperwork and phone calls.   Considering the cost that most loan mod companies charge, your best bet is to directly contact your loan servicer or a nonprofit help agency first.

Details Of Streamlined Mortgage Modification Released

The Federal Housing Finance Agency (FHFA), Fannie Mae and Freddie Mac announced the details for streamlining the mortgage modification process for homeowners in default.  The new guidelines are an effort to standardize the eligibility requirements, thereby allowing the modification process to be completed more quickly.   Currently, the loan modification procedure is bogged down due to understaffed loss mitigation departments and varying rules which have turned the process into a two to four month ordeal for a homeowner already under financial stress.

Fannie Mae President Herb Allison stated that the new guidelines had been established by working with the Federal Housing Finance Agency (FHFA) and numerous lenders and service providers.  Mr Allison also noted that “These efforts are helping more than 10,000 delinquent borrowers every month get back on track”.

FHFA director Jim Lockhart noted that “I am pleased that our program is being rolled out right on schedule and that servicers are already working at modifying delinquent loans with the goal of keeping people in their homes”.

Loan Service Providers who administer the actual mortgage processing will attempt to notify eligible borrowers by mail of the details of the new Streamlined Modification Program (SMP).

The eligibility requirements for the SMP are as follows:

  • the borrower must own and occupy the home
  • the borrower is not eligible if he is presently in bankruptcy
  • the borrower must be delinquent at least three months
  • the borrower must have a loan to value of over 90%
  • the borrower’s income must be verified

The mortgage loan will be modified so that the borrower’s total monthly payment including escrows does not exceed 38% of his gross income.  To bring the ratio to 38% or lower, the term of the loan may be extended to 40 years and/or  part of the principal will be allowed an interest forbearance.   The interest rate on the modified loan may not be lower than 3%.  Any second mortgage on the property will be left outstanding.

There has been much controversy over whether or not the loan modification programs will ultimately work out well for the borrower since the loan principal is not being reduced.  As noted above, the servicer can make the borrower’s payment smaller by making a part of the principal interest free for a period of time (principal forbearance).   The homeowner, however, will in many cases still owe more on his home than it is worth and the reduced mortgage payment usually only lasts for 5 years.  It is therefore interesting to note that the new streamlined modification program does not allow for any type of principal forgiveness.

The loan modification process has generated a lot of controversy and criticism lately since the redefault rate was approximately 50% after 3 to 6 months.   Each party involved in the process has different interests to protect and were promoting different eligibility standards.   It will be very interesting to see if this new streamlined and standardized loan modification program will result in a smaller redefault rate going forward.

Loan Modification Efforts Continue

Despite the recent news that many of the mortgage loans modified have gone back into default, the loan modification effort continues.  Until a better solution is found loan modification efforts will continue, especially given the full backing by the FDIC and other government leaders.  It is likely, however, that the approach and methods will change to ensure that future loan mod efforts are more successful.

Bank United Announces New Loan Mod Efforts

Bank United announced today that it will intensify its efforts to save troubled homeowners  by outsourcing much of the work involved in a loan modification.   To anyone familiar with the delays and inconsistent procedures being employed by many banks in their loan mod efforts, this new approach is a welcomed fresh approach.  Many loss mitigation departments are overwhelmed with work, causing many months of delays before the homeowner receives any type of loan mod offer.   In many cases, the rules as to which loan is modified and under what terms also seems to be inconsistently applied.

Many of the $1 billion in delinquent loans at Bank United apparently are due to the large number of pay option arm loans that were originated.   Given the large drop in property values and the negative amortization features of the pay option arms, many borrowers in this category  have a large negative equity position.   The most probable course of action that Bank United will take for this category of borrower is to reduce the principal balance.   Without principal reduction, the borrower would still be in a negative equity position which frequently leads to default.  Unless the homeowner is wildly bullish about housing prices, very few people will continue to make payments on a $400,000 mortgage when the house is valued at $200,000.

With Bank United stock selling at 33 cents and almost 10% of their loans in default, they would apparently have little to lose by offering to put their borrowers in a stronger position through principal reduction.  As previously discussed, long term housing stability is based on strong borrowers.

Ocwen Shows High Success Rate With Loan Mods

Ocwen Financial reported that results with their loan modification efforts far exceed the industry results.   Ocwen is experiencing less than a 25% delinquency rate 60 days after the loan mod, compared to the industry average of over 50%.

CEO William Erbey stated that “The salient issue is not the efficacy of loan modification as a loss mitigation tool, but whether mods are being properly designed.   Our loan approach achieves the twin objectives of keeping homeowners in their homes and maximizing the net present value of the mortgages to the investors who own the loans.”

Mr Erbey further stated that “the re-default problem lies with how some servicers are doing modifications, not with concept of modification. It’s possible to do modifications right. It’s challenging, but we’re doing it — and doing it in a way that’s scalable.”

Ocwen’s good results seem to reflect it’s use of high technology applied on an individual basis.  Rather than having a loan mod decision made by an individual, the characteristics of the loan and the borrower are assessed using artificial intelligence technology.

To date, Ocwen appears to be an industry example of the right way to do loan modifications.  This year alone, Ocwen has kept over 60,000 borrowers in their homes with the mortgages now being paid on time.

Long Term Housing Stability Based On Strong Borrowers

When will the housing market improve?  That seems to be the question of the day so I offer some observations.

When you hear that financing is hard to get for a home mortgage, what you are really hearing is that unqualified buyers are not being approved.

If you can verify adequate income, are able to make a down payment of at least 3% and have decent credit (at least a 580 FICO score), getting a mortgage approval at a low rate is not difficult.  You will not be approved for a mortgage if you cannot verify your income, if you have terrible credit or if your income is insufficient to support your mortgage and other debt payments.  This is a healthy change for housing long term since ultimately, weak buyers are not capable of sustained home ownership.

Buyer psychology is an important part of the home buying process.  Just as in the stock market,  where higher price trends will entice more buyers, the same is true of housing.   Everyone talks about the wisdom of buying when prices are down, but the fear of future price depreciation deters present buying; everyone wants to wait until they can see a bottom.

Most responsible borrowers need to feel financially secure before purchasing a home.   With a very weak economy, job losses and lack of confidence in the future, most prudent people will think twice before taking on the large financial commitment of owning a home.  The disappearance of 100% financing also means that a buyer faces the loss of his capital investment if the mortgage payments cannot be maintained.

Is it cheaper to rent equivalent housing?  If it is cheaper to rent, does that imply that housing is overpriced?   Have prices been adequately discounted to adjust for past purchases made with easy financing by speculators and unqualified buyers?

A buyer contemplating a home purchase today must consider whether the various government schemes to keep delinquent homeowners in their homes is artificially propping up the market and extending the decline of housing prices.  If a homeowner is unable to pay his mortgage today and with incomes and jobs disappearing, how likely is it that a delinquent homeowner’s income will increase?  Are the loan modification programs and foreclosure holidays making a home buying decision more difficult?  If these programs fail, will the future flood of foreclosed homes on the market cause further large home price decreases?

Is the average buyer today prepared to pay the large maintenance and repairs associated with home ownership?  If buyers today see little chance of future price appreciation, are they prepared to invest a large part of their free time maintaining a home?

Given the large transaction costs of buying or selling a home is it worth purchasing a home unless you know with certainty that you will remain in the home for an extended period of time?  Transaction costs including sales commissions, financing and moving can easily equal 10% of an average home’s value.

Am I really ready to own a home?  In the past, when people foolishly believed that housing values could only go up, this question was rarely asked.  Before considering the purchase of a home, a buyer should discuss in depth with other homeowners the pros and cons of home ownership.  The question of whether to buy or rent has never been more difficult.  A very uncertain housing future and lack of confidence breeds indecision and purchase deferral.

Many of the current problems in the housing market arose due to the easy credit offered to buyers who should have stayed renters.  Buyers should not consider the purchase of a home unless their total mortgage and other debt payments are easily affordable.  Buyers should not use their last dollar of savings when purchasing a home.  Many unexpected expenses will routinely come up.  If you don’t have at least 6 months of income in savings, after your down payment, consider postponing the purchase until your finances improve.   After years of  house buying mania and then a bust, how many confident and strong buyers are out there?

Most mortgage companies and home builders involved with first time home buyers offer advice on determining the affordability of a buyers mortgage payment but do not address many of the other issues discussed here.  Major companies such as KB Homes, for example, discuss the affordability question, but I think more needs to be done in this area.

In the long run an educated buyer with financial stability will be the bedrock of a stable housing market.   Hopefully, future regulations arising from the current housing crisis will address the issue of educating home buyers and make this a mandatory part of the home purchase process.

Refinancing Jumps By Record Pace?

Old story – if you just read the headlines, you don’t get the full story.

Applications to refinance home-mortgages jumped by a record amount, as borrowers flocked to take advantage of falling mortgage rates — which were driven down by the government’s announcement that it would step in to stabilize the mortgage market.

Later on in the same Journal story we learn more facts.

How many applications will wind up as actual mortgages remains to be seen. In southeastern Florida, about one-third or less of refinancing applications are leading to loans, says W.D. Acosta, executive vice president for residential lending at Seacoast National Bank, down from as much as 80% two years ago.

“Many of the people who need refinances don’t have the equity in their home or … their job situation isn’t what it was when the loan was originated,” he says. Nationwide, the “pull through” rate is about 55% for purchase applications and 65% for refinance applications submitted in the first half of this year, according to the Mortgage Bankers Association.

This isn’t 2005 again when everyone got approved and easy cash out refinances financed the good life.  Talking to various mortgage lenders, it seems that few of their previous customers can be refinanced due to high debt ratios, lack of equity, restrictions on amount of cash out (non FHA loans usually limited to 80-85% loan to value), very expensive and hard to obtain mortgage insurance for over 80% loan to value, minimum credit score requirements, absence of stated income, absence of “no doc” loans, and  numerous fees (adders) for anything but the best customer.

If you are self employed you probably need a “hard money” loan at crazy high rates.  Many underwriting guidelines are more strict than they were 10 years ago before the easy mortgage money era started.

So the good news headline isn’t really good news but the real news is really good since this is a small step on the path to sanity in the mortgage industry.

Loan Mods Just A Warmup For The Real Thing-A Mortgage Holiday

It has become increasingly obvious that the central banks of the world will engage in whatever desperate actions are necessary in order to sustain and increase our already unsustainable levels of debt.  The ridiculous idea of providing more credit to a financial system already imploding from oceans of debt seems to be the only solution that makes sense to our policy makers.

The alternative to keeping the credit engine going is to accept the economic pain necessary to restore sound finances.  Since the short term financial pain  would include very high unemployment, lower stock prices, frugal living standards, more credit write downs and  more asset destruction, it is a certainty which path the political and monetary authorities will chose.  Quantitative easing, bailouts and government borrowings are all certain to see immense increases.  The risk of inflation and debasement of the currency brought on by these techniques is apparently viewed as preferable to the pain of deleveraging.

The false prosperity of the past 25 years has come from a parabolic increase in the national debt.  One credit bubble after another in various asset classes have now burst leaving us with destroyed asset values and mountains of debt that can never be repaid.

Real national income has been stagnant for the last decade; attempting to address this problem by borrowing money to maintain living standards does not work long term since the interest costs eventually overwhelm a static income level as shown on the chart below.  With interests rate essentially at zero the Federal Reserve is now forced to employ the unconventional methods that Fed Chairman Bernanke has spoken about in the past.  The deflation we are now facing makes debt payments ever more onerous to the borrower.  Debts too large to be repaid by definition will not be repaid – the only two options are to default or attempt to reduce the debt through inflation of the currency.  The Fed has obviously chosen the later option.


Since the consumer represents roughly 80% of the economy,  there will be massive efforts to put cash into the American consumer’s pocket.   Additional income will not come from wage increases with the present high level of unemployment.   Additional cash  will not come from borrowing  since the banks have thus far largely refused to lend to poor credit risk consumers.   Additional cash will not come from lower rates since the Fed is out of bullets on rate decreases.   Those who are financially responsible do not want to borrow or spend since they are trying to save to make up for the huge wealth destruction they have sustained over the past two years.

What is the solution on how to put more money in the pockets of those consumers most likely to spend whatever cash they receive?  The proposed stimulus rebate program is presently the government’s only and preferred “solution” to over leverage and static incomes.   The next move beyond this point will be to simply provide a way for the consumer to simply stop paying his bills without technically defaulting on the debt.

Since the largest monthly payment most consumers have is the mortgage payment, it is increasing likely that as the economy continues its downward spiral, the government will allow a mortgage holiday, as I have previously predicted. This once unthinkable action was actually proposed today by Gordon Brown in Britain, where consumers have distinguished themselves by becoming the most indebted citizens of the world.

As reported by the Financial Times, “Gordon Brown on Wednesday granted homeowners in financial difficulty the right to demand a two-year mortgage holiday, guaranteed by taxpayers, in a dramatic bid to underpin the housing market.”    You can be certain that this program will eventually be applied to all mortgage holders in many countries.

According to the Federal Reserve, total home mortgage debt as of the second quarter of 2008 was $10.6 trillion, roughly equivalent to 80% of the GDP.    Assuming an average interest rate of 6.5% on this mortgage debt, the cost to the government (who would pick up the tab) would only be $700 billion per year, oddly enough the same size of the presently proposed rebate program.  Since we have already partly institutionalized the repudiation of debt through loan modification programs, this step is only a natural progression but applied to a wider number of people.

This program would no doubt be eagerly embraced and wildly popular with cash poor consumers. It would put cash into the pockets of those most likely to spend it, thereby helping the economy.  The minority of those without mortgages may be upset until they accept the wisdom of “wealth redistribution” now being preached as a method of helping those in need.

My view is that we will all end up equally poor.