Subject: reality Paul Fanaika Jersey
Author: xiaoming
Posted on: 11/17/2015 01:17:41 AM
substantial part because the FDIC's tougher regulation and supervision ant that the opportunistic frauds entered the S&L industry in 1982-84 rather than the FDIC-regulated savings bank industry.In 1990-91 the West Region of the Office of Thrift Supervision crked down on liar's loans Kareem Martin Jersey , which were being significant among a number of California S&Ls. We recognized that such loans were often fraudulent and inherently unsafe and unsound. Long Beh Savings responded to this supervisory crk down by giving up its S&L charter and being a morgage banker to escape our jurisdiction. It changed its na to Ariquest and beca an infamous predatory lender specializing in nonpri lending. One of its leading nonpri petitors was owned and managed by a family that we had forced out of the S&L industry.Redirection may be part of the explanation of why Canada had fewer problems with its mortgage lenders than the U.S. did during the recent crisis. Mortgage fraud beca endemic in the United States due to the operation of the aounting control frauds, but mortgage fraud and aounting control fraud among Canadian banks are reported to be unusual. Two cautions are in order. First, supervision can be so weak that the regulators routinely cover up the control frauds. I do not think that is the case in Canada. Second, Canada did not engage in the radical deregulation and desupervision that the U.S. did. A Canadian of poor integrity and modest wealth could found a loan brokerage firm in Canada or 50 miles away in the United States. Canada may have redirected many of its wannabe banking frauds to the United States.Our challenge as regulators ould be to reduce the frequency and severity of epidemics of aounting control fraud rather than rely redirecting them to another industry or region. In the context of residential mortgage lending, that ans that all residential mortgage lenders ould be subject to federal regulation for safety and soundness.A Recipe for Regulatory and Industry SuessLiar's loans were bad for mortgage lenders Troy Niklas Jersey , borrowers, and the nation. Effective regulation would have been aided all three groups. Fortunately, we have known for at least a century how to make safe residential ho loans. The following rules and laws ould be mandatory for residential ho lenders: Ho loans must be fully underwritten The minimum requirents of full underwriting - verification of ine, employnt, credit history Jonathan Dwyer Cardinals Jersey , down paynt, etc are specified The verified underwriting must be contemporaneously docunted and the lender must maintain that docuntation Ho loans must be made on the basis of full appraisals It is unlawful for any person to inform the appraiser of the loan amount prior to finalizing the appraisal It is unlawful for any person to intimidate or bribe or attempt to intimidate or bribe an appraiser in the regard to a real estate appraisal It is unlawful to for any private entity to base any aspect of a loan officer or agent's pensation on the basis of the volu of loans presented, originated, or approved rather than on the quality of the loans All residential ho lenders are made subject to the regulations that currently mandate that federally-insured institutions file criminal referrals (Suspicious Activity Reports (SARs)) in the circumstances described in those regulations The residential ho lender must review eh outside appraisal for pliance with appraisal standards Teaser rates are prohibited#8232; All borrowers must be underwritten to establi their ability to repay the loan fully at the fully indexed rate without refinancing the loan and without assuming any appreciation of the ho All ho lenders will take steps to check, prior to lending Paul Fanaika Cardinals Jersey , whether the borrower owns multiple hos and is representing that more than one ho will be his principal dwelling I will address in future columns docuntation maintenance necessary to end the pervasive problems with fraudulent foreclosures and lost or non-existent docuntsIn addition to these underwriting and docuntation reforms, the regulators need to take broader approhes to be effective. First, the staff and leaderip need to be trained in aounting control fraud techniques. For example, only fraudulent lenders deliberately inflate appraised values (or permit them to be inflated). Regulators need to understand that when they identify that prtice they have identified a fraud that must be stopped urgently. I asked the question years ago in an ademic article - why doesn't the SEC have a "Chief Criminologist"? I made clear that I was only using the SEC as an example of the many agencies whose duties include civil law enforcent. We have seen the catastrophic cost of regulatory ignorance of fraud techniques.Second, the entire regulatory and law enforcent partnerip that proved so suessful in responding to the S&L deble must be reestablied and it must reple the FBI's "partnerip" with the Mortgage Bankers Association - the trade association of the perps. The regulators need to play a critical role in training the FBI agents and Assistant U.S. Attorneys (AUSAs) to identify and investigate aounting control frauds (a capity that as I've just described the agencies will have to rebuild). I've described in prior articles how only the regulators can fill the vital role as "Sherpas" Alex Okafor Cardinals Jersey , the virtual cessation of the regulators making criminal referrals, and the failure to create any analog to the "Top 100" prioritization effort, so I will not repeat the details in this column.Third, the agencies must end the "Reinventing Governnt" mantra that the industry is the regulators' "custor." Our only custor is the people of the United States of Arica. We provide unique benefits to honest banks precisely because our function is not to make bankers happy. Our function is to be skeptical, to speak truth to power Corey Peters Cardinals Jersey , and to be courageous and vigorous against the frauds. To be suessful the regulators must think of themselves as the regulatory cops on the beat whose primary function is to see that cheaters don't prosper. By crking down. Wholesale NFL Jerseys Wholesale Jerseys Cheap Jerseys From China Cheap NFL Jerseys Cheap Jerseys Cheap NFL Jerseys Cheap Jerseys
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