foia request - crew: department of the treasury: regarding the goals of hamp: 10/20/2011

8/3/2019 FOIA Request - CREW: Department of the Treasury: Regarding the Goals of HAMP: 10/20/2011

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CREW I jbgOctober 20, 2011

By facsimile: 202-622-3895FOIA RequestDepartmental OfficesDisclosure ServicesDepartment of the TreasuryWashington, D.C. 20220

Re: Freedom of Information Act RequestDear S ir o r Madam:

Citizens for Responsibility and Ethics in Washington (CREW) makes this request forrecords, regardless of format, medium, or physical characteristics, and including electronicrecords and information, audiotapes, videotapes and photographs, pursuant to the Freedom ofInformation Act (FOIA), 5 U.S.C. 552 , e t seq., and U.S . Department of the Treasury(Treasury) FOIA Regulation 31 C.F.R. Part 1.Specifically, CREW requests all records f rom October 3, 2008 to the present related toTreasurys projections of the number of homeowners the Home Affordable ModificationProgram (RAMP) would help avoid foreclosure. This request includes, bu t is not limited to,projections of the total number of permanent modifications Treasury expects to be completed andmaintained under RAMP, the total number of trial modifications Treasury expects to be offeredto homeowners, and the total number of trial modifications Treasury expects to be initiated. Thisrequest also includes, bu t is no t limited to, records relied on by Treasury to make theseprojections, and records reflecting communications about them.Please search for responsive records regardless of format, medium, or physical

characteristics. Where possible, please produce records electronically, in PDF or hF format on aCD-ROM. We seek records of any kind, including electronic records, audiotapes, videotapes,and photographs. Ou r request includes any letters , emails, facsimiles, telephone messages, voicemail messages, and transcripts, notes, or minutes of any meetings, telephone conversations, ordiscussions. Ou r request also includes any attachments to these records.For any email, please produce metadata and/or headers that show the email address of thesender and any recipient in addition to their display name, the names and email addresses of anybcc: recipients, and any data regarding the time and date the email was sent, received, and/oropened.

1400 Eye Street, NW., Suite 450, Washington, DC. 20005 I 202.408.5565 phone I 202.588.5020 fax I www.citizensforethics.org


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Department of the TreasuryOctober 20, 2011Page 5regarding CREWs activities and information the organization has received from governmententities. A complete archive of past CREWCuts is available athttp://www.citizensforethics.org/newsletter.

Third, CREW publishes a blog, Citizens bloggingfor responsibility and ethics inWashington, that reports on and ana lyzes newsworthy developments regarding government ethicsand corruption. The blog, located at http://www.citiznesforethics.org/blog, also provides linksthat direct readers to other news art ic les and commentary on t he se is sues. CREWs b log had3,857 page views in September 2011.

Finally, CREW ha s published numerous reports to educate the public about governmentethics and corruption. See Record Chaos, which examines agency compliance with electronicrecord keeping responsibilities; The Revolving Door, a comprehensive look into the post-government activities of 24 former members of President Bushs cabinet; and Those Who Dared:30 Officials Who Stood Up For Our Country . The se and all other CREWs reports are availableat http://www.citizensforethics.org/reports.

Based on these extensive publication activities, CREW qualifies for a fee waiver as arepresentative of the news media under the FOIA and agency regulations.Conclusion

If you have any questions about this request or foresee any problems in releasing fully therequested records please contact me at (202) 408-5565. Also, if CREWs request for a feewaiver is not granted in ful l, please contact our office immediately upon making such adetermination. Please send the requested records to Adam J. Rappaport, Citizens forResponsibility and Ethics in Washington, 1400 Eye Street, N.W., Suite 450, Washington, D.C.20005.

Sincerely,

4Adam J. RappapoSenior CounselEnclosures


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Treasury Details Its Plan to Modify Home Loans - NYTimes.com http://www.nytimes.com/2009/03/05/business/economy!O5Ioan.html?..

that adds up total monthly debt obligations and compares them with total income. The back-end ratiowould include car payments, credit card debt , second mortgages on the same house and other obligationslike child-support payments. Any borrower whose total monthly obligations come to more than 55 percentof monthly income would need to sign up fo r deb t counseling. But even if they did so, many lenders arelikely to balk at offering a loan deal even if the government is sharing the cost.In theory, there is no limit on the so-called loan-to-value ratio for a modified mortgage. In other words,people are eligible for help even if the value of their house is far less than the outstanding amount of themortgage, as is the case for about 14 million people who bought houses at the very peak of the market andoften put no money down. Administration officials have said, however, that people who owe more than 150percent of the current market value of their homes will probably have a harder time persuading theirlenders to modify the mortgage.Some people will not qualify, one administration official said. And some people who do qualify will notsucceed.

Copyright 2009 The New York Times CompanyPrivacy Policy Corrections RSS Firs t Look I tii I Contact Us Work for U s Site Map

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Understanding the Trial Period http://www.makinghomeaffordable.gov/learn-more/trial-period!Pages/...

En Espanol I HIt$t4 I !O l I Portugubs Vit I Hmoob Tagalog

Search PAn official program of the Departments of the Treasury & Housing and Urban Development

HOME PROGRAMS GET ASSISTANCE LEARN MORE NEWS FOR PARTNERS FAQS

Home a Learn More e Understasdtng The Trial PortedHomeowner Examples Understanding the Trial PeriodHomeowner Success Stories

The Home Affordable Modificstion Program SM requires borrowers to enter into a Trial Period Plan before receiving a permanent HomeLending Discriminalion Affordable Modification. During this period, borrowers mustsubmit trial payments and all required forms and documents. For more

information about documentation requirements, visit Request a Modification.Modification Evaluator

Important Notice for Borrowers Who Received a Trial Period PlanUnderstanding Net Present You must make sure that your mortgage servicer receives all of the forms and documents they need to veri fy your eligibility and o ff er y ou aValue permanent Making Home Affordable Modification before your Trial Pedod Plan expires. Your t da l period plan notice will indicate your

document due date. Double check the Request a Modification page and aend any miaaing documents to your mortgage servicer right away.Understanding The TrialPeriod If you believe that you have sent all of the required forma and documents, contact your mortgage servicer to confirm that they have

everything they need to make a decision.Understanding YourMortgage Statement If you have trouble reaching your mortgage servicer, o r y o u need help completing the necessary documentation, free help is available from aVideos HUD-approved housing counselor by calling 1-8S8-ggs-HOPE (4573) and asking for MHA HELP.

YOU MUST ACT NOW SO YOU DO NOT LOSE THE OPPORTUHITY FOR AN AFFORDASLE MORTGAGE PAYMENT

0 SHAPE mERL.Last Updated: 411912011 3:35 AM

Treasury.gov Related Sites Other Useful SItesHUD.gov FinancialStability.gov USA.govWhiteHoUae.gov MyMoney.gov USAJOBS.gov

OPM.gov

Site Index I Privacy I FAGs I Contact Us

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rCongressional Oversight Panel

DECEMBEROVERSIGHT REPORTA Review of Treasurys Foreclosure PreventionPrograms

December 14 ,2010

*

*Submfted under Section 125(b)(1) of Title 1 of the Emergency EconomicStabilization Act of 2008 , Pub. L. No. 110-343


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Executive Summary*

In April 2010, in its most recent report on Treasurys foreclosure prevention programs,the Panel raised ser ious concerns about the t imeliness , accountability, and sustainability ofTreasurys efforts. As the Panel not ed at the t ime, It now seems c lear that Treasurys programs,even when they are fully operational, w ill not r each the overwhelming majority of homeownersin trouble.... Treasury is still struggling to get its foreclosure programs off the ground as thecrisis continues unabated.

In the intervening eight months, Treasury has tweaked its main foreclosure preventioneffort, the Home Affordable Modification Program (HAMP) , but t he changes have not resolvedthe Panels core concerns. The Panel now est imates that, if current trends hold, HAMP willprevent only 700,000 to 800,000 foreclosures far fewer than the 3 to 4 million foreclosures thatTreasury init ial ly aimed to s top, and vast ly fewer than the 8 to 13 million foreclosures expectedby 2012. Because Treasurys authority to res tructure HAMP ended on October 3, 2010, theprograms prospects are unlikely to improve substantially in the future.

In some regards, the programs failure to make a dent in the foreclosure cri si s may seemsurprising. HAMPs premise was straightforward: Because the foreclosure process allowslenders to recover only a small fraction of the value of a mortgage loan, lenders should generallyprefer to avoid foreclosure by voluntarily reducing a borrowers monthly payments to affordablelevels. Through RAMP, Treasury attempted to sweeten this deal by offering incentive paymentsto all parties to a mortgage loan modif ication. Yet despite the apparent strength of HAMPseconomic logic , the program has failed to help the vast majority of homeowners facingforeclosure.

A major reason is that mortgages are, in practice , far more complicated than a one-to-onerelationship between borrower and lender. In particular, banks typically hire loan servicers tohandle the day-to-day management of a mortgage loan, and the servicers interes ts may at timessharply conflict with those of lenders and borrowers . For example, although lenders suffersignificant losses in foreclosures, servicers can turn a substantial profit from foreclosure-relatedfees. As such, it may be in the servicers interest to move a delinquent loan to foreclosure assoon as possibl e. HAMP att empted to correct this market distortion by offering incentivepayments to loan servicers , but the effort appears to have fallen short, in part because servicerswere not required to participate. Another major obstacle is that many borrowers have secondmortgages from l enders who may s tand to profit by blocking the modification of a firstmortgage. For these reasons among many others, RAMPs straightforward plan to encouragemodifications has proven ineffective in practice.

The Pane l adopted this report with a 5-0 vote on December 13, 2010,4


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who argue for keeping HAMP alive have an increasingly daunting task, and absent meaningfulaction from Treasury, SIGTARPs support of RAMPs continued existence is all bu texhausted.Chairman Biggert, Ranking Member Gutierrez, and members of the Committee, I want to thankyou again for this opportunity to appear before you, and I would be pleased to respond to anyquestions that you may have.

I I you ire aware ol Ira ci. a e, a base. m isma iagement or misrepreseota ions a lilt ia ted with the two bledasset relief program, piense contact the SICI\RP Iloti Inc.Onion. \ \ V\ dC I \[W C O\ i \I iii I lotion. Ofln. ol tin SIC I \IIP\ia IldI Irc Phon( $77_SI(,_200tt 1801 I St.,N.V\ia Ia: 2O2o22-4) Vrishingtun. D.t.. 20220


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FACTORS AFFECTING IMPLEMENTATIONOF THE HOME AFFORDABLEMODIFICATION PROGRAM

SIGTARP-1O-005MARCH 25 , 2010


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The Number of Permanent ModificationsEntered Into During HAMPs First Year HasBeen Below ExpectationsThis section addresses what Treasuiy s participation goalsfor HAMP are and examines whetherthose goals have been met during the program sfirst year. The next section will examine thechallenges that have confronted and continue to confront Treasuiy in implementing HAMP.

Treasury states that its goal for RAMP is that the program will offer trial modifications to 3 to 4million borrowers at risk from its inception through its expiration at the end of 2012. Thissection first examines how Treasury has articulated its goals for RAMP and notes that Treasurysinitial statements about the program indicated that RAMP was originally intended to result in 3to 4 million permanent modifications a level that simply will not be met absent anunanticipated and dramatic increase in participation. Irrespective of how the goal is defined,although Treasury has made progress in developing the administrative backbone of the programand in getting the program started rapidly meeting targets for servicer participation and a goalfor early trial modifications the rate of permanent modifications thus far has been s low. FromRAMPs inception through February 2010, only 168,708 mortgages have been permanentlymodified.

Treasurys HAMP Participation GoalIn its discussions with SIGTARP during the course of this audit, Treasury has insisted that itsparticipation goal for RAMP is and has been from the programs inception that 3 to 4million borrowers will be offered trial mortgage modifications over the four years of theprogram. In other words, Treasurys stated goal is not t ied to how many borrowers are actuallyhelped by entering permanent modifications, but rather how many had the opportunity to entertrial modifications by receiving offers.What the anticipated benefits of a program are and how a programs success or failure is definedare important to provide a reference point for discussions about whether a program is worth theresources devoted to it and whether the program is functioning as it should. An examination ofhow Treasury has articulated its RAMP participation goal over time demonstrates that Treasuryhas been less than consistent about how it has justified the programs costs or defined whatsuccess in the program would m ea n. M an y of Treasurys prior statements about the program6 Treasury reports 1,499 of the 170,207 permanent modifications started have been cancelled, resulting in 168,708

active permanent modifications as of February 2010.8


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foia request - crew: department of the treasury: regarding the goals of hamp: 10/20/2011

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