OCC Compounds Botched Foreclosure Review Process with Barmy Plan for Distributing Peanuts
The OCC is bravely trying to spin the horrorshow of its botched foreclosure reviews as some sort of positive outcome. It is apparently now trying to present its dereliction of duty in figuring out how to compensate borrowers as no big deal.
But the most amazing finesse, which a New York Times article tacitly accepts, is the OCC’s pretense that it got a good deal for homeowners in the settlement.
Just focus on the cash portion, which is $3.3 billion across the ten servicers in the settlement. The other forms of relief, paralleling the state attorney general/Federal settlement, either aren’t worth much (writing off deficiency judgments) or are for things the banks were inclined to do anyhow.
495,000 complaint letters were filed. The estimates of serious harm from the whistleblowers at the Bank of America site in Tampa Bay ranged from 10% to 80%. The average was 33%, and the estimates also clustered around 30% to 40%. So we’ll use 30%.
To make the math simpler, we’ll use 500,000 x 30% x the maximum award, which was $125,000, which would seem to be warranted with “serious harm” (the people on the modification test all described cases where people who were in mods of various sorts and were paying as the bank stipulated but were foreclosed on, so they seemed to have an adequately stringent notion of what “serious harm” amounted to. Basically, to get the maximum award, the bank had to have eaten your home while you were in a mod or it had to be a Servicemembers Civil Relief Act violation).
You get $18.75 billion.
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seriously considering filing a suit for lack of dilligence the way review was handled. They breached a contract of warranty with a fraud while implementing a review for the homeowners that were wrongfully foreclosed upon or damaged in the pursuit of a form of a settlement. In doing so they have claimed to have created a settlement of no wrong doing.