Office of the Comptroller of the Currency

Independent Foreclosure Review Fiasco: OCC and Fed Decided Not to Find Harm

The last few days have had more and more ugly revelations emerge about the botched OCC and Fed Independent Foreclosure Review settlement, with some particularly important ones coming out of the hearings in Robert Menendez’s Senate Banking subcommittee today. We’ll turn to that soon, but first wanted to cover some issues that have correctly stirred ire among the NC commentariat.

First was the embarrassing confirmation of complaints all over the web that paying agent Rust Consulting did not have sufficient funds in its account to cover the first batch of settlement checks sent out Friday. And this isn’t the first time that Rust has sent out checks that bounced in a settlement. And in some jurisdictions, passing bum checks is a crime. What gives?

Second is the fact that the envelopes themselves look like numerous scam letters, in particular debt collection letters and offers. Lisa Epstein kindly provided this example:


Screen shot 2013-04-18 at 3.21.01 AM

People who sent in letters to the IFR are waiting for payments and will presumably be on the lookout for the settlement letters. But what about the everyone else?