TopMortgage Compliance Update (1)
  July 23, 2010
                                             HAMP: "Continues to struggle"

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Yesterday, we provided an outline of the continuing downward trend of the Home Affordable Modification Program (HAMP) program, as reported in the most recent June Report, issued on July 20, 2010.

On July 21, 2010, the Special Inspector General for the Troubled Asset Relief Program (SIGTARP), stated in its Quarterly Report to Congress (Report), that HAMP "continues to struggle to achieve its original stated objective to help millions of homeowners avoid foreclosure 'by reducing monthly payments to sustainable levels.'"

It would be helpful to refer to our compliance update, "HAMP: Continues Downward Trend," issued on July 22, 2010, for comparative analysis.

The Report states that the number of homeowners being helped through permanent modifications "remains anemic," with fewer than 400,000 ongoing permanent modifications and HAMP has not put an "appreciable dent" in foreclosure filings. Furthermore, according to the Report and as we also indicated in yesterday's compliance update, the number of trial and permanent modifications that have been canceled substantially "exceeds the number of homeowners helped through permanent modifications."

In a telling statement of fact, the Report unequivocally finds that the Treasury "clings to its prior statements that it plans to offer trial modifications to three to four million homeowners, a measure that the SIGTARP has previously shown to be essentially meaningless," and that its refusal to provide meaningful goals is a "fundamental failure of transparency and accountability."

Finally, the SIGTARP takes the position that the "American people are essentially being asked to shoulder an additional $50 billion of national debt without being told, more than 16 months after the program's announcement, how many people Treasury hopes to actually help stay in their homes as a result of these expenditures, how many people are intended to be helped through other subprograms, and how the program is performing against those expectations and goals."

Without clearly defined standards, opines the SIGTARP, positive comments about HAMP's success are "simply not credible," and leads to a growing "public suspicion" that HAMP is an "outright failure."

It should be noted that of the anticipated $75 billion dollar cost of the Making Home Affordable (MHA) program that commenced on February 18, 2009, $50 billion will be funded through TARP. HAMP is one of the MHA programs.

If you have any questions about this matter or would like assistance with mortgage compliance, ple
ase contact Jonathan Foxx, Managing Director or call 516-442-3456 x 100.

HAMP Snapshot-Chart-1
As of June 30, 2010, a total of 753,275 mortgages are currently being modified, either permanently or on a trial basis. Of those, 389,198 were active permanent modifications and 364,077 were active trial modifications.

SIGTARP uses statements from the June reviews provided by HUD and Treasury to explain why the number of cancellations of mortgage modifications has increased, as decisions on aged trials are being reached, such as:
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Office of the Special Inspector General of the Troubled Asset Relief Program, Quarterly Report to Congress, July 21, 2010

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Mortgage Compliance                 Compliance Administration

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Mortgage Due Diligence     FNMA|FHLMC|GNMA Applications

Legal Reviews & Remedies          Loss Mitigation Compliance

Sarbanes-Oxley Compliance           HMDA & CRA Processing

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CORE Compliance Matrix                         Statutory Licensing

Business Development                Information Security Plans

IT & IS Compliance                                     RESPA-AfBAs

Lenders Compliance Group is the first full-service, mortgage risk management firm in the country, specializing exclusively in mortgage compliance and offering a full suite of hands-on and automated services in residential mortgage banking.

We are pioneers in outsourcing solutions for mortgage compliance.

This communication is sent to our valued clients and colleagues, who regularly receive our Advisory Bulletins, Mortgage Compliance Updates,  Compliance Alerts, and News and Views.

These publications are free to subscribers. Information contained herein is not intended to be and is not a source of legal advice.

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