Distressed owners – the mha program – Querin Law, LLC | Phil Querin

Background – The Making Home Affordable (“MHA”) program, designed and implemented by the federal government, is intended to address the serious financial problems faced by many homeowners who are unable to meet their mortgage payments. Complete information about the program can be found at its website, http://makinghomeaffordable.gov/. The following discussion is important for owners wishing to remain in their home, but either have defaulted on their loan, default is imminent, or they simply find the mortgage payments too burdensome due to a change of circumstances or the high interest cost of the loan. The MHA program divides itself into two sections: refinance and loan modification.

Home Affordable Refinance Program (“HARP”) – The objective of this program is to provide creditworthy borrowers who have “shown a commitment to paying their mortgage,” the opportunity to get into a mortgage with payments that are affordable today and for the balance of the loan term. The program expires on June 10, 2010. All refinance transactions must be closed and funded on or before that date. Here are the main features of HARP:

The borrower must be current on the mortgage at the time of application. The term “current” means that the borrower hasn’t been more than 30-days late on their mortgage payment in the last 12 months or, if they have had the loan for less than 12 months, they’ve never missed a payment.
The refinance is only available if the mortgage or trust deed is held through Fannie Mae or Freddie Mac (or have been placed in mortgage-backed securities by these GSEs). To find out, contact: Fannie Mae, 1-800-7FANNIE (8am to 8pm EST), www.fanniemae.com/loanlookup; or Freddie Mac, 1-800-FREDDIE (8am to 8pm EST), www.freddiemac.com/mymortgage.
Applies to 1-4 unit family dwellings.
Must have income sufficient to support the new mortgage payments.
The refinance must improve the long term affordability or stability of the loan. The lender will provide a “Good Faith Estimate” that includes the new interest rate and mortgage payment that the borrower will pay over the life of the loan. This should be compared to the current loan terms. If it is not an improvement, refinancing may not be appropriate.
The amount owed on the first mortgage is about the same or slightly less than the current value of the home. (Eligible loans will include those where the first mortgage will not exceed 125% of the current market value of the property. The current value of the property will be determined after application for refinance.) As long as the amount due on the first mortgage is less than 125% of the value of the property, borrowers with more than one mortgage may be eligible for a Home Affordable Refinance. However, eligibility will depend, in part, on agreement by the lender that has the second mortgage remain in a second position, and on the borrower’s ability to meet the new payment terms on the first mortgage.
The interest rate will be based on market rates in effect at the time of the refinance and any associated points and fees quoted by the lender. Interest rates may vary among lenders and over time as market rates adjust. The refinanced loans will have no prepayment penalties or balloon payments.
The refinanced loans will not be written for a reduced principal amount owed on the original loan.
Cash is generally not available to pay other debts. However, borrowers whose loans are owned or securitized by Fannie Mae may be eligible to finance all closing costs and obtain a small amount of cash (2% of the mortgage amount not to exceed $2,000) through the refinance if there is sufficient equity. For borrowers whose loans are owned or securitized by Freddie Mac, transaction costs (not to exceed $2,500) such as the cost of an appraisal or title report, may be included in the refinanced amount.
To apply for a refinance, the borrower should call their mortgage servicer₂ or lender and ask about the Home Affordable Refinance application process. The telephone number is on the monthly mortgage bill or coupon book. However, the process can be slow, and it may take time before they are ready to process all applications. Nearly all major banks and mortgage brokers are approved to work with Fannie Mae. The lender selected should be asked if they are authorized to provide a Home Affordable Refinance.
Generally, borrowers seeking a refinance will need: (a) Information about their monthly gross (pre-tax) income of all the borrowers on their loan, including recent pay stubs and documentation of income received from other sources; (b) Most recent income tax return; (c) Information about any second mortgage on the home; (d) Account balances and minimum monthly payments due on all credit cards; (e) Account balances and monthly payments on all other debts such as student loans and car loans.
If the existing loan has private mortgage insurance, the borrower will need the same amount of insurance coverage for the refinanced loan. If the existing loan does not have private mortgage insurance it will not be required as part of the Home Affordable Refinance.
All existing subordinate financing must be re-subordinated by the current lienholder.

Home Affordable Modification Program (“HAMP”) This program can help even if the loan is not owned by Fannie Mae or Freddie Mac. It offers help to borrowers who are struggling to keep their loans current or who are already behind on their mortgage payments. The program expires on December 31, 2012. Trial modification (discussed below) must be in place by that date. While lenders are not required to participate, all of the major lending institutions have been encouraged to do so, and most have.

HAMP modifications can include one or more of the following approaches₃ : (a) Adding accrued arrearages, fees, costs, etc. to the principal balance of the loan; (b) Reducing the interest rate or setting an adjustable rate loan at a certain level. The floor is 2%₄ ; (c) Extending the term and re-amortizing the loan up to 480 months; (d) Principal forbearance, i.e. carving out a portion of the principal, interest free, and deferring its repayment until sale of the home, loan maturity, or payoff of the remaining interest-bearing portion of the loan. There is no requirement that the servicer agree to forgive any of the principal balance. However, lender late fees must be forgiven if the borrower successfully completes the 3-month trial period discussed below. During the 30-day period that the borrower has to accept the modification plan, the lender is required to suspend any foreclosure activity.

In order to evaluate whether a loan qualifies for modification, lenders are required to apply the “Net Present Value” or “NPV” Test. This test compares the expected economic outcome of the loan before and after the proposed modification. How the results are applied to a specific modification, depend upon whether it is a GSE or a non-GSE loan. If the NPV outcome is “positive” (i.e. the NPV of the proposed modified loan is greater than the NPV of the unmodified loan), then the servicer is required to proceed with the modification – regardless of whether it is a GSE or non-GSE loan. If the outcome is “negative”, (i.e. the NPV of the proposed modified loan is less than the NPV of the unmodified loan) and it is a GSE loan, the lender or servicer is still required to proceed with the modification – unless principal forbearance is required to achieve the target payment and the resulting mark-to-market LTV ratio falls below 100%. If the borrower is not eligible for a modification under HAMP, the lender (regardless of whether it is GSE or non-GSE) is to consider them for other options, such as a short sale, deed-in-lieu or alternative modification programs.₅

For non-GSE loans, if the NPV results after modification are negative, the servicer is not required to proceed, but they have the option to do so “at the investor’s discretion.”₆ Here are the main features of HAMP:

The borrower must be an owner-occupant in a one-to-four unit property.
Have an unpaid principal balance that is equal to or less than $729,750 for one-unit properties (there is a higher limit for two-to-four unit properties).
Have a loan that was originated on or before January 1, 2009.
Have a mortgage payment (including taxes, insurance and homeowner’s association dues) that is more than 31% of the borrower’s gross (pre-tax) monthly income, and have a mortgage payment that is not affordable, perhaps because of a significant change in income or expenses.
Only the loan servicer will be able to tell the borrower if they qualify for a modification.
The borrower does not need to be behind on their mortgage payments to be eligible for a Home Affordable Modification. However, borrowers who are struggling to remain current on their mortgage payments are eligible if they are at risk of imminent default (i.e. over 60 days delinquent); (a) Because their mortgage payment has recently increased to a level that is not affordable; (b) They have had or anticipate a significant increase in their mortgage payment; (c) Have had a significant reduction in income; or (d) Experienced some other hardship that makes them unable to pay the mortgage. The borrower will be required to document their income and expenses and provide evidence of the hardship or change in circumstances.
If they have a second mortgage, they are still eligible, but only if the first mortgage is eligible.
Servicer participation in the program is voluntary. However, the government is offering substantial incentives to servicers and investors in an effort to assure that most will participate. Participating servicers will sign a contract (“Servicer Participation Agreement”) with Treasury’s financial agent, through which they agree to review every potentially eligible borrower who calls or writes asking to be considered for the program. (As contracts are signed, a list of participating servicers will be available on the Internet at www.makinghomeaffordable.gov). If the borrower reports some financial hardship, their servicer will: (a) Determine whether their existing loan meets the minimum eligibility criteria (owner occupied, originated on or before January 1, 2009, unpaid principal balance equal to or less than $729,750)₇ ; (b) They will ask about current income, assets and expenses as well as the specific circumstances relating to the hardship to determine if the borrower will be unable to make their existing mortgage payment; (c) They will determine if the monthly first mortgage payment is more than 31% of the borrower’s pre-tax monthly income. If so, they will add past due charges (interest, taxes, insurance and costs that the lender paid to other parties on the borrower’s behalf – but not late fees, those must be waived) to the loan balance; (d) They will determine how much of an interest rate reduction will be required to get the first mortgage payment down to a point where it is no more than 31% of the borrower’s gross monthly income; (e) They will apply the NPV Test to determine if the cost of the modification (including the government’s incentive payments) is less costly for the investor than not modifying the loan;₈ (f) They will put the borrower on a trial modification for three months at the new interest rate and payment level.
If the borrower successfully makes the payments and is current at the end of the trial period, the servicer will execute a permanent modification agreement that will lower their interest rate to a fixed rate for five years, and then capped at a low rate for the remaining life of the loan.
Misrepresenting any information required for the Home Affordable Modification is a violation of Federal Law and has serious consequences.
If the modified interest rate is below the market rate, the modified rate will be fixed for a minimum of five years as specified in the modification agreement. Beginning in year six, the rate may increase no more than one percentage point per year until it reaches the Interest Rate Cap in the modification agreement. This Cap means that the rate can never be higher than the market rate on the day the loan was modified. If the modified rate is at or above the prevailing market rate, the modified rate will be fixed for the life of the loan.
The modified loan will include taxes and insurance. The modification payment will include a monthly amount to be escrowed to pay taxes and insurance when they become due. This escrow is required even if the prior loan did not include an escrow.
The Treasury Department is providing incentives to the investor to write the interest down to as low as 2%, if necessary to get to a payment that the borrower can afford based on their income.
If a 2% interest rate does not result in a payment that is affordable (no more than 31% of the borrower’s gross monthly income), the servicer will: (a) First try to extend the payment term – possibly as long as 40 years; (b) If that is still not sufficient, the servicer may defer repayment on a portion of the amount owed until a later time. This is called a “principal forbearance;” (c) A portion of the debt could be also be forgiven. This is optional on the part of the investor. There is no requirement for principal forgiveness, i.e. eliminating the amount of the loan balance. It is more likely that the servicer will use interest rate reductions in order to make the borrower’s payment affordable rather than principal forgiveness.
It is possible that the borrower could end up with a balloon payment. If the servicer determines that a principal forbearance is required to get the monthly payment to an affordable level, the amount of the forbearance. For example, (e.g. $20,000 would be subtracted from the amount used to calculate the monthly mortgage payment, but the borrower would still owe the money. That is, a $20,000 balloon payment that bears no interest and is not due until the loan is paid off, or the home is refinanced or sold.).
Borrowers who are unable to make three payments by the end of the 5-month trial period are not eligible for a Home Affordable Modification. However, they may be eligible for other foreclosure prevention options offered by the servicer.
Borrowers who are behind on payments or at risk of imminent default often do not have cash to pay for the expenses of a loan modification. Borrowers who qualify for an MHA modification are not required to pay a modification fee or pay past due late fees. If there are costs associated with the modification, such as payment of back taxes, the servicer will give the borrower the option of adding them to the principal amount owed on the mortgage or paying some or all of the expenses in advance. Paying these expenses in advance will reduce the new monthly payment and save interest costs over the life of the loan.
If the borrower would like assistance from a HUD-approved housing counseling agency, or is referred to a counselor as a condition of the modification, they will not be charged a counseling fee.₉
When they apply for a HAMP modification, the servicer will analyze the borrower’s monthly debts, including the amount they will owe on the new mortgage payment after it is modified, as well as payments on any second mortgage, car loans, credit cards or child support. If all of these recurring monthly expenses are equal to or more than 55% of gross monthly income, the borrower must agree to participate in housing counseling provided by a HUD-approved housing counselor as a condition of getting the modification.
Borrowers who make timely payments on their modified loans will receive success incentives. For every month they make a payment on time, the Treasury will pay a financial incentive that reduces the principal balance on the loan. The incentive will be applied directly to the loan balance annually and over five years the total principal reduction could add up to $5,000.
If the borrower owns a home used as a vacation home or one that is rented out to tenants, the mortgage on that house is not eligible for the modification program – this restriction applies even if it was formerly the borrower’s primary residence. Only the mortgage on the current primary residence is eligible. The mortgage servicer will verify this. Misrepresenting occupancy in order to qualify for this program is a violation of Federal law.
Most conventional loans, including prime, subprime and adjustable loans, loans owned by Fannie Mae, Freddie Mac and private lenders, and most loans in mortgage-backed securities are eligible for an MHA modification. On August 1, 2009, U.S. Department of Housing and Urban Development Secretary Shaun Donovan announced that the FHA had implemented changes to its loan modification program so that it would be consistent with HAMP. If a borrower meets the general eligibility criteria for HAMP they should gather the financial documentation that the servicer requires to determine if they qualify. This would include: (a) Information about monthly gross income; recent pay stubs; documentation of income received from any other sources; (b) Most recent income tax return; (c) The nature and extent of the borrower’s assets; (d) Information about any second or subsequent mortgages or other liens on the home; (e) Account balances and minimum monthly payments due on all credit cards; (f) Account balances and monthly payments on all other debts such as student loans and car loans; (g) A hardship letter describing why the current mortgage is unaffordable.
Once this information is accumulated, the borrower should call their mortgage servicer and ask to be considered for a Home Affordable Modification. (Note: if the loan is current, it may take more time before servicers are able to process the applications. Housing counselors can be reached at 1-888-995-HOPE (4673). HUD-approved housing counselors can help evaluate income and expenses, and explain the borrower’s options. This counseling is free.) Borrowers whose loans have been scheduled for foreclosure or any borrower that has missed one or more mortgage payments and have not yet spoken to their servicer should do so immediately. Borrowers may also contact a HUD-approved housing counselor by calling 1-888-995-HOPE (4673). There should never be a fee for assistance with or information about the Making Home Affordable Program.

Problems/Issues with the MHA Programs. – Some experts believe that there are several shortfalls with the current MHA program:₁₀

Borrowers with negative equity in excess of 125% of FMV do not qualify for the refinancing alternative. Statistically, there are a significant number of areas in Oregon and other states where negative equity exceeds 125%, thus disqualifying a significant number of distressed homeowners.
Some believe that debt forgiveness is the most effective tool to avoid re-defaults among distressed homeowners. Yet debt forgiveness under the MHA modification program is not mandatory and is considered a “last resort.” However, based upon anecdotal reports and research, the incidence or re-defaults is much higher where the borrower has no equity in the home.₁₁ This is one of the major complaints by lenders who participate in loan modification programs, i.e. it simply prolongs the inevitable.
Both of the MHA programs are directed to owner-occupants, which ignore a significant part of the overall foreclosure problem, i.e. the investors. In the words of Jack Guttentag, aka “The Mortgage Professor,” the programs suffer from a mindset based upon “deservedness” rather than attacking the problem as a whole.₁₂
The programs do not effectively deal with the problem of second lienholders, many of whom are unlikely to step aside without demanding some payment from the borrower.₁₃ It was the seconds, usually in the form of HELOCs, which contributed to the “negative equity” problem many homeowners face today. It has been estimated that mortgage equity withdrawal via HELOCs was used for personal consumption (as opposed to paying down credit card debt, etc.) and that homeowners extracted 25¢ to 30¢ for every dollar increase in equity.
The modification program (as opposed to the refinance program) is generally limited to those borrowers in arrears and teetering on the verge of foreclosure. For those borrowers who are still current with their lenders, many are told that they must first go into default, in order to take advantage of the modification program.
Limiting the refinance program to those with existing Fannie and Freddie loans ignores perhaps half of the remaining subprime and Alt-A borrowers whose non-conforming loans were purchased and collateralized on the private side of the secondary mortgage market.₁₄

While MHA is certainly well intentioned, its mission has been limited by: (a) Certain philosophical considerations₁₅ ; (b) Some basic misconceptions about the mortgage law₁₆ ; (c) Unrealistic (some might say naïve) limitations on both programs₁₇ ; and (d) Inadequate and untrained personnel adequately prepared for the volume of inquiries and the program requirements. A recent story in the New York Times₁₈underscores another, equally significant problem: The demand for help far exceeds the skilled labor to provide it. Moreover, since the program is voluntary to the banks, they can decide on a case-by-case basis what they will offer each applicant. And in many cases, those still current on their loans, but teetering on default, get shunted to the back of the line. In other cases, the bank’s solution is rarely more attractive than the status quo – which accounts for a re-default rate in the 30% range.₁₉ ”

Initially, the government predicted that the MHA program would help 3 to 4 million distressed homeowners. However, on September 9, 2009, the Assistant Secretary for Financial Institutions, in his prepared statement before the House Financial Services Committee, reported that “…over 360,000 trial modifications are underway….” which would be, at best, approximately 10% of those estimated to be in need. He also noted that:

…even if HAMP is a total success, we should still expect millions of foreclosures, as President Obama noted when he launched the program in February. *** Some of these foreclosures will result from borrowers who, as investors, do not qualify for the program. Others will occur because borrowers do not respond to our outreach. Still other will be the product of borrowers who bought homes well beyond what they could afford and so would be unable to make the monthly payment even on a modified loan.

According to one observer, “Lenders appear to be rationing mortgage modifications and the small numbers of loan workouts that do get through are being swallowed by the foreclosure pandemic. Several lenders with 30,000 or more eligible mortgages have not changed one loan and large banks that received billions in federal bailout money lag behind government expectations.”₂₀ In a recently released public policy discussion paper by the Federal Reserve Bank of Boston, they made several findings: First, the authors concluded that mortgage renegotiation of seriously delinquent borrowers was “extremely rare” – on the order of 3%. Secondly, they give some credence to the theory that in actuality, many lenders (private label or pooled) actually believe that in the long run, foreclosure is less costly than renegotiation because of factors such as re-defaults (estimated at 30% to 40%) and those borrowers who don’t need assistance because they ultimately “self-cure” (estimated at 30%); and thirdly, loan servicer fear of investor lawsuits for making material modifications in mortgages that reduce investor returns.₂₁

Loan Modification Through Existing Lender or Loan Processor – Similar to the MHA program, this process entails a change to any of the terms of the note and mortgage such that the borrower can thereafter afford the payments. It could mean an adjustment to the interest rate, lengthening the term, adding the arrearages back to the principal amount, forbearance, or (least favored by the lenders) forgiving the principal balance. Due to the fear that this modification practice will be engaged in by those who do not truly need them, lenders are looking at each request on a case-by-case basis, and demand a significant amount of information from the borrower (including monthly expense worksheets and “hardship letters”). This has resulted in much delay and frustration to borrowers in need of help. Generally, these modifications are available only to borrowers in default, or in imminent danger of default from impending rate increases that will make the mortgage payment unaffordable to them. The purpose is to cure or avoid the default, thereby preventing a foreclosure and allowing the borrower to remain in the property. Setting aside government programs, many of the larger banks have their own loss mitigation departments, with on-line links for the consumer, providing information to assist in that bank’s modification requirements.

Refinancing – Like private loan modification programs, there are lender in-house programs, with many of the same characteristics, i.e. worksheets, hardship letters, and detailed monthly expense reports, etc. that must be completed before a refinancing can or will be considered. The problem with a refinance is that it replaces the original loan, and thus the borrower must qualify all over again, just the same as a new loan. Given the economic climate, the risks of future unemployment, the continued tightening of the credit markets, etc. refinancing is – unfortunately – reserved for those least in need of it.

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Footnotes

Much of this summary information has been taken directly from the FNMA and MHA websites. However, some information has either been skipped or only briefly summarized here. As with all government programs, there are many exceptions, nuances, technicalities and updates, space does not permit reprinting it all here. For that reason, those interested in a complete explanation, are encouraged to go directly to the websites.
The loan servicer is the financial institution that collects the borrower’s monthly mortgage payments and has responsibility for the management and accounting of the loan. The servicer may be the lender, which means they own the loan. However, many loans are owned by groups of investors. Generally, there is a contract between the servicer and the investor that states what kind of actions the servicer is allowed to take. Most of these contracts, called pooling and servicing agreements (PSAs), give the servicer a lot of leeway to make modification decisions, so long as the modification provides a better financial outcome for the investor than not modifying the loan.
These alternatives are referred to in the HAMP vernacular as “the Standard Modification Waterfall.”
The maximum interest rate upon modification is “the Interest Rate Cap” which is “…the Freddie Mac Weekly Primary Mortgage Market Survey (PMMS) Rate for 30-year fixed rate conforming loans, rounded to the nearest 0.125 percent, as of the date that the (Modification) Agreement….”
See, https://www.hmpadmin.com/portal/docs/job_aids/npvtestresults.pdf
Remember, this is a non-GSE loan, i.e. neither Fannie or Freddie are involved. Thus, the loan was pooled and sold on the private (non-GSE) side of the secondary mortgage market.
Mortgages on two, three and four unit properties are eligible as long as the borrower lives in one unit as a primary residence. For two units the unpaid principal balance may be up to $934,200; three units $1,129,250; and four units $1,403,400.
Loans held by borrowers who have a lot of equity or whose incomes are very low in relation to the value of their homes probably will not pass this value test.
Borrowers should be careful when dealing with any organization that attempts to charge an upfront fee for housing counseling or modification of a delinquent loan, or one that claims to guarantee success. While the organization may be legitimate, borrowers should know that with work and patience, they might be able to maneuver through the maze without having to pay any up front costs. However, due to some of the technical aspects of these complex and sometimes frustrating federal programs, some special real estate/lending and legal expertise may be appropriate. It is for that reason that some Realtors® and attorneys are adopting business models (“fee for services”) that do charge to assist distressed owners in understanding, exploring, and pursuing various options to permit the borrower to remain in the home rather than sell it on a short sale. However, Oregon, like several other states, has enacted laws to protect consumers. Oregon borrowers should also be aware that non-exempt providers of such consulting services must first give them a statutorily mandated foreclosure consultant contract which includes rights of rescission, etc. See, HB 3630, which was enacted in the 2008 legislative session. (Discussed below.) Violation of this law is an unlawful trade practice. It is for this reason that Oregon consumers should be wary of companies from out-of-state, purporting to provide foreclosure consulting services in Oregon. Oregon attorneys and Oregon licensed real estate brokers (among others) are exempted from this law.
Source: The Mortgage Professor. http://www.mtgprofessor.com/
See, Loan Modification and Re-Default Risk. Roberto G. Quercia, Lei Ding, and Janneke Ratcliffe.http://www.ccc.unc.edu/ documents/LM_March3_%202009_final.pdf
Specifically, he states: “Investors — those who rent their properties rather than occupy them — are not eligible. In this mindset, investors don’t deserve help because they were implicated in the bubble that preceded the crash, they bought houses in the hope of turning a quick profit, and Government should allow them to take their well-deserved lumps without interference.” See website at footnote 1, above.
The Obama administration has announced that it is working on a program to deal with the issues, which appears to include some incentive payments to encourage the holder of the second to subordinate to the new modified first mortgage. Whether it will be timely (and sufficient) enough to render help now, remains to be seen.
This private side is a part of what has come to be known as the “Shadow Banking System,” because it was essentially a parallel, but unregulated banking system. For an interesting article on this topic, see:http://cafehayek.com/2009/01/the-shadow-banking-system.html
E.g. What appears to be an intentional effort to let all “investors,” e.g. those who perhaps used their HELOCs to buy rental property, or “flippers” (a pejorative term now used to describe those who sought to buy low, let the housing bubble increase their equity, then sell – exactly what stock investors had been doing with IPOs for years) fend for themselves. Yet if the investor segment constitutes 20%+ of the people in financial trouble on their mortgages – albeit perhaps of their own making – why has the government opted to help big banks, who engaged in far riskier practices – with the apparent blessing of regulators – and not the small-time investors? And wasn’t it the federal government that created IRS Section 121 which essentially allowed homeowners to “flip” their primary residences every 2 years and keep the capital gain profits up to $500,000 for married couples ($250,000 for single filers), tax free? It is little wonder so many people became real estate “investors,” albeit unsophisticated ones.
When it was first rolled out, the MHA loan modification and refinance programs focused on first mortgages, without factoring in the need in some cases for consent of the holders of the second or third mortgage holders. At the end of April, 2009, the government quickly rolled out an MHA Second Lien Program, to incentivize lenders to extinguish subordinate liens. If the subordinate lien was less than 180 days overdue at the time of modification, between $.04 to $.12 for every dollar of debt extinguished was paid based upon an Extinguishment Price Schedule.
Limiting refinancings to homeowners whose mortgage debt only exceeds value by 125% is unrealistic. In many areas of the country – as was 105%, which was its initial limit. In some areas the median home price is approximately 50% what it was just two years ago. How will MHA help these owners? And excluding non-GSE (i.e. non-Fannie and Freddie) loans from refinance addresses only half the problem, thus limiting the efficacy of any rescue program.
Promised Help is Elusive for Some Homeowners, by Peter Goodman, New York Times, June 2, 2009. See, http://www.nytimes.com/2009/06/03/business/03mortgage.html
See, http://www.calculatedriskblog.com/2009/06/modifications-and-re-default.html
“Meager Modifications Portend Prolonged Housing Crisis,” by Broderick Perkins, Examiner.com, September 10, 2009.
“Why Don’t Lenders Renegotiate More Home Mortgages?” No. 09-4, July 6, 2009