A New Kind of Recession — with Decades of Impact Yet to Come

Editor’s Comment: It’s too late to cure the problem entirely. We can’t unbreak the glass and we’ll never be done cleaning up the mess. But we can start somewhere. It is obvious to all economists of every persuasion that this is a recession of a different kind than anything else we have experienced. That’s because it was tripped off not by the boom and bust cycles we have historically endured, but because the private sector has taken over governmental functions in the most basic of ways: issuing money.
It is still possible though unlikely, that through legislative financial reform, our government and our society will see this development for what it is, in REALITY. The coup achieved by Wall Street can still be undone and the path to recovery lies directly with that paradigm shift.
Proprietary currency now outpaces government currency by a ratio of more than 10 to 1. It doesn’t have to stay that way. All the proprietary currency rests on faulty presumptions about the values of the “underlying” assets backing them up. In the mortgage backed securities market, the mortgage notes are not worth anywhere near what the price they were sold to investors.  The mortgage terms sold to borrowers were unfaithful representations of a reality known only to highly sophisticated quants and titans.
There is a LOSS in there but it shouldn’t fall upon the investors and borrowers used as pawns in this scheme — at least it shouldn’t fall entirely on them. The mere official recognition of the fair market value of these isntruments now and when they were sold will produce a market correction in what amount to fictitious currency. And the transfer of wealth back to investors and homeowners can commence without the government spending a dime.
Moving money back to the the government and moving wealth back tot he people is the solution to our problem. But we can’t do that if we the citizens of this nation simply accept the hand that was dealt to us as taxpayers, as investors as borrowers and as homeowners.
February 21, 2010
The New Poor

Millions of Unemployed Face Years Without Jobs

BUENA PARK, Calif. — Even as the American economy shows tentative signs of a rebound, the human toll of the recession continues to mount, with millions of Americans remaining out of work, out of savings and nearing the end of their unemployment benefits.

Economists fear that the nascent recovery will leave more people behind than in past recessions, failing to create jobs in sufficient numbers to absorb the record-setting ranks of the long-term unemployed.

Call them the new poor: people long accustomed to the comforts of middle-class life who are now relying on public assistance for the first time in their lives — potentially for years to come.

Yet the social safety net is already showing severe strains. Roughly 2.7 million jobless people will lose their unemployment check before the end of April unless Congress approves the Obama administration’s proposal to extend the payments, according to the Labor Department.

Here in Southern California, Jean Eisen has been without work since she lost her job selling beauty salon equipment more than two years ago. In the several months she has endured with neither a paycheck nor an unemployment check, she has relied on local food banks for her groceries.

She has learned to live without the prescription medications she is supposed to take for high blood pressure and cholesterol. She has become effusively religious — an unexpected turn for this onetime standup comic with X-rated material — finding in Christianity her only form of health insurance.

“I pray for healing,” says Ms. Eisen, 57. “When you’ve got nothing, you’ve got to go with what you know.”

Warm, outgoing and prone to the positive, Ms. Eisen has worked much of her life. Now, she is one of 6.3 million Americans who have been unemployed for six months or longer, the largest number since the government began keeping track in 1948. That is more than double the toll in the next-worst period, in the early 1980s.

Men have suffered the largest numbers of job losses in this recession. But Ms. Eisen has the unfortunate distinction of being among a group — women from 45 to 64 years of age — whose long-term unemployment rate has grown rapidly.

In 1983, after a deep recession, women in that range made up only 7 percent of those who had been out of work for six months or longer, according to the Labor Department. Last year, they made up 14 percent.

Twice, Ms. Eisen exhausted her unemployment benefits before her check was restored by a federal extension. Last week, her check ran out again. She and her husband now settle their bills with only his $1,595 monthly disability check. The rent on their apartment is $1,380.

“We’re looking at the very real possibility of being homeless,” she said.

Every downturn pushes some people out of the middle class before the economy resumes expanding. Most recover. Many prosper. But some economists worry that this time could be different. An unusual constellation of forces — some embedded in the modern-day economy, others unique to this wrenching recession — might make it especially difficult for those out of work to find their way back to their middle-class lives.

Labor experts say the economy needs 100,000 new jobs a month just to absorb entrants to the labor force. With more than 15 million people officially jobless, even a vigorous recovery is likely to leave an enormous number out of work for years.

Some labor experts note that severe economic downturns are generally followed by powerful expansions, suggesting that aggressive hiring will soon resume. But doubts remain about whether such hiring can last long enough to absorb anywhere close to the millions of unemployed.

A New Scarcity of Jobs

Some labor experts say the basic functioning of the American economy has changed in ways that make jobs scarce — particularly for older, less-educated people like Ms. Eisen, who has only a high school diploma.

Large companies are increasingly owned by institutional investors who crave swift profits, a feat often achieved by cutting payroll. The declining influence of unions has made it easier for employers to shift work to part-time and temporary employees. Factory work and even white-collar jobs have moved in recent years to low-cost countries in Asia and Latin America. Automation has helped manufacturing cut 5.6 million jobs since 2000 — the sort of jobs that once provided lower-skilled workers with middle-class paychecks.

“American business is about maximizing shareholder value,” said Allen Sinai, chief global economist at the research firm Decision Economics. “You basically don’t want workers. You hire less, and you try to find capital equipment to replace them.”

During periods of American economic expansion in the 1950s, ’60s and ’70s, the number of private-sector jobs increased about 3.5 percent a year, according to an analysis of Labor Department data by Lakshman Achuthan, managing director of the Economic Cycle Research Institute, a research firm. During expansions in the 1980s and ’90s, jobs grew just 2.4 percent annually. And during the last decade, job growth fell to 0.9 percent annually.

“The pace of job growth has been getting weaker in each expansion,” Mr. Achuthan said. “There is no indication that this pattern is about to change.”

Before 1990, it took an average of 21 months for the economy to regain the jobs shed during a recession, according to an analysis of Labor Department data by the National Employment Law Project and the Economic Policy Institute, a labor-oriented research group in Washington.

After the recessions in 1990 and in 2001, 31 and 46 months passed before employment returned to its previous peaks. The economy was growing, but companies remained conservative in their hiring.

Some 34 million people were hired into new and existing private-sector jobs in 2000, at the tail end of an expansion, according to Labor Department data. A year later, in the midst of recession, hiring had fallen off to 31.6 million. And as late as 2003, with the economy again growing, hiring in the private sector continued to slip, to 29.8 million.

It was a jobless recovery: Business was picking up, but it simply did not translate into more work. This time, hiring may be especially subdued, labor economists say.

Traditionally, three sectors have led the way out of recession: automobiles, home building and banking. But auto companies have been shrinking because strapped households have less buying power. Home building is limited by fears about a glut of foreclosed properties. Banking is expanding, but this seems largely a function of government support that is being withdrawn.

At the same time, the continued bite of the financial crisis has crimped the flow of money to small businesses and new ventures, which tend to be major sources of new jobs.

All of which helps explain why Ms. Eisen — who has never before struggled to find work — feels a familiar pain each time she scans job listings on her computer: There are positions in health care, most requiring experience she lacks. Office jobs demand familiarity with software she has never used. Jobs at fast food restaurants are mostly secured by young people and immigrants.

If, as Mr. Sinai expects, the economy again expands without adding many jobs, millions of people like Ms. Eisen will be dependent on an unemployment insurance already being severely tested.

“The system was ill prepared for the reality of long-term unemployment,” said Maurice Emsellem, a policy director for the National Employment Law Project. “Now, you add a severe recession, and you have created a crisis of historic proportions.”

Fewer Protections

Some poverty experts say the broader social safety net is not up to cushioning the impact of the worst downturn since the Great Depression. Social services are less extensive than during the last period of double-digit unemployment, in the early 1980s.

On average, only two-thirds of unemployed people received state-provided unemployment checks last year, according to the Labor Department. The rest either exhausted their benefits, fell short of requirements or did not apply.

“You have very large sets of people who have no social protections,” said Randy Albelda, an economist at the University of Massachusetts in Boston. “They are landing in this netherworld.”

When Ms. Eisen and her husband, Jeff, applied for food stamps, they were turned away for having too much monthly income. The cutoff was $1,570 a month — $25 less than her husband’s disability check.

Reforms in the mid-1990s imposed time limits on cash assistance for poor single mothers, a change predicated on the assumption that women would trade welfare checks for paychecks.

Yet as jobs have become harder to get, so has welfare: as of 2006, 44 states cut off anyone with a household income totaling 75 percent of the poverty level — then limited to $1,383 a month for a family of three — according to an analysis by Ms. Albelda.

“We have a work-based safety net without any work,” said Timothy M. Smeeding, director of the Institute for Research on Poverty at the University of Wisconsin, Madison. “People with more education and skills will probably figure something out once the economy picks up. It’s the ones with less education and skills: that’s the new poor.”

Here in Orange County, the expanse of suburbia stretching south from Los Angeles, long-term unemployment reaches even those who once had six-figure salaries. A center of the national mortgage industry, the area prospered in the real estate boom and suffered with the bust.

Until she was laid off two years ago, Janine Booth, 41, brought home roughly $10,000 a month in commissions from her job selling electronics to retailers. A single mother of three, she has been living lately on $2,000 a month in child support and about $450 a week in unemployment insurance — a stream of checks that ran out last week.

For Ms. Booth, work has been a constant since her teenage years, when she cleaned houses under pressure from her mother to earn pocket money. Today, Ms. Booth pays her $1,500 monthly mortgage with help from her mother, who is herself living off savings after being laid off.

“I don’t want to take money from her,” Ms. Booth said. “I just want to find a job.”

Ms. Booth, with a résumé full of well-paid sales jobs, seems the sort of person who would have little difficulty getting work. Yet two years of looking have yielded little but anxiety.

She sends out dozens of résumés a week and rarely hears back. She responds to online ads, only to learn they are seeking operators for telephone sex lines or people willing to send mysterious packages from their homes.

She spends weekdays in a classroom in Anaheim, in a state-financed training program that is supposed to land her a job in medical administration. Even if she does find a job, she will be lucky if it pays $15 an hour.

“What is going to happen?” she asked plaintively. “I worry about my kids. I just don’t want them to think I’m a failure.”

On a recent weekend, she was running errands with her 18-year-old son when they stopped at an A.T.M. and he saw her checking account balance: $50.

“He says, ‘Is that all you have?’ ” she recalled. “ ‘Are we going to be O.K.?’ ”

Yes, she replied — and not only for his benefit.

“I have to keep telling myself it’s going to be O.K.,” she said. “Otherwise, I’d go into a deep depression.”

Last week, she made up fliers advertising her eagerness to clean houses — the same activity that provided her with spending money in high school, and now the only way she sees fit to provide for her kids. She plans to place the fliers on porches in some other neighborhood.

“I don’t want to clean my neighbors’ houses,” she said. “I know I’m going to come out of this. There’s no way I’m going to be homeless and poverty-stricken. But I am scared. I have a lot of sleepless nights.”

For the Eisens, poverty is already here. In the two years Ms. Eisen has been without work, they have exhausted their savings of about $24,000. Their credit card balances have grown to $15,000.

“I don’t know how we’re still indoors,” she said.

Her 1994 Dodge Caravan broke down in January, leaving her to ask for rides to an employment center.

She does not have the money to move to a cheaper apartment.

“You have to have money for first and last month’s rent, and to open utility accounts,” she said.

What she has is personality and presence — two traits that used to seem enough. She narrates her life in a stream of self-deprecating wisecracks, her punch lines tinged with desperation.

“See that,” she said, spotting a man dressed as the Statue of Liberty. Standing on a sidewalk, he waved at passing cars with a sign advertising a tax preparation business. “That will be me next week. Do you think this guy ever thought he’d be doing this?”

And yet, she would gladly do this. She would do nearly anything.

“There are no bad jobs now,” she says. “Any job is a good job.”

She has applied everywhere she can think of — at offices, at gas stations. Nothing.

“I’m being seen as a person who is no longer viable,” she said. “I’m chalking it up to my age and my weight. Blame it on your most prominent insecurity.”

Two Incomes, Then None

Ms. Eisen grew up poor, in Flatbush in Brooklyn. Her father was in maintenance. Her mother worked part time at a company that made window blinds.

She married Jeff when she was 19, and they soon moved to California, where he had grown up. He worked in sales for a chemical company. They rented an apartment in Buena Park, a growing spread of houses filling out former orange groves. She stayed home and took care of their daughter.

“I never asked him how much he earned,” Ms. Eisen said. “I was of the mentality that the husband took care of everything. But we never wanted.”

By the early 1980s, gas and rent strained their finances. So she took a job as a quality assurance clerk at a factory that made aircraft parts. It paid $13.50 an hour and had health insurance.

When the company moved to Mexico in the early 1990s, Ms. Eisen quickly found a job at a travel agency. When online booking killed that business, she got the job at the beauty salon equipment company. It paid $13.25 an hour, with an annual bonus — enough for presents under the Christmas tree.

But six years ago, her husband took a fall at work and then succumbed to various ailments — diabetes, liver disease, high blood pressure — leaving him confined to the couch. Not until 2008 did he secure his disability check.

And now they find themselves in this desert of joblessness, her paycheck replaced by a $702 unemployment check every other week. She received 14 weeks of benefits after she lost her job, and then a seven-week extension.

For most of October through December 2008, she received nothing, as she waited for another extension. The checks came again, then ran out in September 2009. They were restored by an extension right before Christmas.

Their daughter has back problems and is living on disability checks, making the church their ultimate safety net.

“I never thought I’d be in the position where I had to go to a food bank,” Ms. Eisen said. But there she is, standing in the parking lot of the Calvary Chapel church, chatting with a half-dozen women, all waiting to enter the Bread of Life Food Pantry.

When her name is called, she steps into a windowless alcove, where a smiling woman hands her three bags of groceries: carrots, potatoes, bread, cheese and a hunk of frozen meat.

“Haven’t we got a lot to be thankful for?” Ms. Eisen asks.

For one thing, no pinto beans.

“I’ve got 10 bags of pinto beans,” she says. “And I have no clue how to cook a pinto bean.”

Local job listings are just as mysterious. On a bulletin board at the county-financed ProPath Business and Career Services Center, many are written in jargon hinting of accounting or computers.

“Nothing I’m qualified for,” Ms. Eisen says. “When you can’t define what it is, that’s a pretty good indication.”

Her counselor has a couple of possibilities — a cashier at a supermarket and a night desk job at a motel.

“I’ll e-mail them,” Ms. Eisen promises. “I’ll tell them what a shining example of humanity I am.”

5 Responses

  1. SIGTARP HOTLINE  to trigger a mortgage servicer audit.                                      
    If you are aware of fraud, waste, abuse, mismanagement or misrepresentations affiliated with the Troubled Asset Relief Program, please contact the SIGTARP Hotline!

    This may be a long shot, but a rash of complaints may spur some action. Send your mortgage servicing complaint to SIGTARP. Bury SIGTARP in complaints about your servicer to try to trigger an audit.

    If you are aware of fraud, waste, abuse, mismanagement or misrepresentations affiliated with the Troubled Asset Relief Program, please contact the SIGTARP Hotline!
    Please review the following details and submit the Hotline form below.

    What kinds of things should you report?
    Allegations of fraud, including false statements, false claims and misrepresentations affiliated with the TARP.
    Any activities that might impact the integrity of the Troubled Asset Relief Program including, but not limited to, allegations of fraud or misconduct by Federal employees and/or entities receiving TARP funds.
    Actions by persons or entities attempting to misrepresent their association with TARP by utilizing deceptive contracts or financial instruments; including, allegations of identity theft or misrepresentations.
    NOTE: The confidentiality of your contact information is assured when received via phone, mail or in person. Laws protect you from reprisals (any action taken against you because you filed a complaint).

    You can submit your complaint via these methods:
    By http://www.sigtarp.gov/contact_hotline.shtml#theform:
    By Phone:
                                        Call toll free: (877) SIG-2009
    By Fax:
                                        (202) 622-4559
    By Mail:
                                        Office of the Special Inspector General
                                        For The Troubled Asset Relief Program
                                        1500 Pennsylvania Ave., NW, Suite 1064
                                        Washington, D.C. 20220

    You should receive an email from the SIGTARP office similar to this one which was sent in response to a servicer complaint:

    Dear  XXXXX,

    The Office of the Special Inspector General for the Troubled Asset
    Relief Program (SIGTARP) is in receipt of your email dated June XX,
    2009, and your faxes dated June X and X, 2009.

    Thank you for your submission to the SIGTARP Hotline, the information
    you have provided is important to us.
    Tips and information we receive through our hotline result in audits,
    investigations, and case studies and we assure you the information you
    have provided will be analyzed carefully by our staff, and recommended
    for action as appropriate and in accordance with SIGTARP policies and

    Your issues will be forwarded to the appropriate personnel at the Home
    Affordable Modification Program.


    SIGTARP Hotline
    Special Inspector General
    for the Troubled Asset Relief Program
    1.877.SIG.2009 (1.877.774.2009)

  2. To PMB in VA. Will keep you and your family in my prayer’s.

    Living close to DC must really burn you, as living in NY is for me. The two diabolical epicenters of this “man made” disaster, with an emphasis on MAN!

    While they are stealing the American Dream from people like you and our future generations, they are still wheeling and dealing on Wall Street celebrating their banner profits.

    I could mot agree more, we all can share our stories , but until there is a collective movement by the middle class things will go nowhere.

    Received a phone call from a friend that was flipping out about the proposed freeze on foreclosures announced last week, when I explained that at this point there was little left to do and why (how we all got here in the first place) they were speechless. I told them to read this blog! We will see!

    Indeed this all was a very well planned scheme, that enriched few and destroyed many. One has to ask just how many homes, car’s, planes and things one person need’s. In NY we refer to them as BSD’s, I will leave it at that.

    I can not help but see the common thread here 50 something people, being hit the hardest. Make’s one feel like Boxer in Orwell’s Animal Farm! But what happens when this class of hard working people are no longer working, generating TAXABLE income or creating job’s, as we are seeing now,where will we all go from here?

    In any-case hold your pride & love your family, with strength and a unified voice we will get through this. All may not be happy with the solutions that are coming down the road, and it is heartfelt that you and your family were one of the early victim’s of this all. We can thank people like Neil and all that post here with helping, educating and bringing that voice load and clear to the open.

    God bless you and everyone that has been suffering silently UNTIL NOW!

  3. I agree with PJ finally the real victims are being talked about. There is so much pain and shame behind closed doors in neighborhoods across this country. Hard working honest folks who have been brought to desperation and children whose lives have been changed forever.
    The story above could be about me…I am 55 and have worked since I was 16 years old. I have been self employed business owner for the past 20 years, Most would considered me middle class until now. My business has been destroyed in this economy like so many others. My eight wonderful staff members are gone, my income has dropped 60% and no unemployment available to self employed or UNDER EMPLOYED, I am not eligible for social services or food stamps because I earn too much. My husband is ill. My savings are depleted as is the 401K, my health insurance is gone, my cars are gone, and my home is in foreclosure. I could not sell the cars or home for what I owed the bank would not work with me. I filed Chapter 7 a year ago. I have cut back on everything and tried to work out a modification but we now know that is not going to happen. Then the bank took a partial payment put it in a suspense fund and denied any additional payments and the rest is history!

    My children are scared but coping I am terrified but must keep trying.

    I too have a positive outlook most days and look for the good in the day. If I crawl into bed in the middle of the day I may never get out. My relationship with my husband and family are strained from the stress. FEAR has become common and I would give anything to have something to help with the panic attacks but I have no money to get medical help.

    I have been applying for work for the past 18 months. I finally got a call to work for 4 days at $12.00 and hour I grabbed it would be food money!

    It was an enlightening day on the job in a small town just outside of D.C.

    Seven lucky people were called into work a seasonal short-term temp job. Over 70 had applied!

    All were professionals out of work.

    Two women in their late 60’s + and were just doing it to earn extra income. (I felt they needed to go home and let these jobs go to people who really needed them)

    One man was a father of three looking for anything he could find to support his family

    Another women in her 40’s had already lost her house and were living with a friend. She has never been unemployed in her life much less homeless. She has been looking for full time work for over a year. She has been the victim of blatant discrimation by a major firm but has no money or strength to do anything about it. She keeps looking trying not to get distracted she has two children at home and two in college. She does not recognize her life. I heard desperation in her voice. I gave her a hug and told her I see her and I hear her she is not alone.

    Another women in her late 50’s was grateful to earn a few dollars. You could tell she has hard a hard life she did not speak much except to say everyone has bad credit these days there is no way to get ahead.

    There was a young woman she was trying to take care of her two children, her husband left after they lost the house!

    I actually came away from that little job with a better perspective. I was not alone yet I feel that way daily. For some mother nature helped with a record snow last week which brought opportunity to so many contractors who were out of, work which is a blessing. The news keeps saying things are getting better but not here so close to D.C.

    Maybe we need to get everyone on Capital Hill to change places with an America out of work and let them live in each other’s shoes for one week. Similar to the new TV program Undercover Boss to truly understand you need to come down to our level. Let them feel the pain of not being able to get medical care or provide basic food or medicine for your family and realize we could be their neighboors or family members who are to proud to speak of the deperate place they have come to in this down turn. Let them feel afraid to answer the door or the phone out of fear for the first time in their lives.

    Foreclosures are happening to good people who had good credit, good jobs, and stable work histories. Most homeowners are considered model citizens in their communities and work place. Those who were fortunate enough to buy or refinance homes in the past six years had little idea that they were a means to and end in a nasty, greedy scheme called securitization that has destroyed the American Dream by the very banks they thought they could trust!

    Why are all of our American Citizens not screaming about the unprecedented number of foreclosures and asking real questions WHERE IS THE OUTRAGE!

    As Neil has suggested over an over a FAIR MARKET adjustment could keep many , many homeowners in their homes and secure the real investors actual investment for the future. Is it ideal no but it would be a start on a correction. I am not holding my breath the banks are in control and our homes and the investors funds are FREE money to them since they have already been paid. We are just pawns in their scheme!

  4. Finally the “unspoken for” are getting coverage in the press, the real victims of this mess, when do they get a bail out! The people who lived within their means had rainy day savings that are now exhausted, and are jobless, or working 2 jobs just to stay above water.

    This is the real story, not the flipper’s and speculator’s of the housing debacle, who will walk away from properties. Many of these people have high equity to loan value and are fast becoming the targets of predatory mortgage servicers.
    That’s yet another story that needs to be told!

    They will not be happy until they strip the American middle class of everything they own. That has become quite evident! Perhaps everyone in this position should tear down their house’s like man in Ohio!

  5. To make matters worse, I have just been informed that HUD is about to restrict seller financing. This will cripple an already credit-tightened situation and cause more financial stress on homeowners that could do a mortgage wrap. Here is the crux of what I have discovered via a pdf file courtesy of the Kansas City Investment Group:

    HUD has proposed to eliminate ALL seller financing unless the seller lives in the home or becomes a licensed mortgage originator. The proposed HUD rules interpreting the federal SAFE mortgage act can be viewed at http://www.regulations.gov … use the search parameter HUD and the keyword SAFE. Please review and comment regarding the impact of this broad interpretation of the law.

    HUD is soliciting public comment through March 5, 2010. I just found out about this and I’ve already written my U.S. Rep. in DC about my opposition to this rule change. Once it’s codified, it will take an act of Congress to change it.

    Here’s what you can do:

    1. Log onto http://www.regulations.gov. You will see two white boxes for searching.
    2. On the left box labeled DOCUMENT TYPE, pull the menu down and select PROPOSED RULES.
    3. On the right box labeled ENTER KEYWORD OR ID, enter SAFE MORTGAGE, then press SEARCH.
    4. Locate the blue search result “FR-5271-P-1, Safe Mortgage Licensing Act: HUD Responsibilities Under …” To read the rules, click on this title. You will be taken to another page. You will see “views”. You can click on the PDF file or another symbol which will show you the rule document online.
    5. On the right of the screen, slcik on SUBMIT COMMENT.
    6. Complete the form providing required information and then your comments and then click SUBMIT.

    What to say … and please be polite … here are some examples:

    1. bank loans are not available on some types of properties.
    2. the tight lending climate has made bank financing “out of reach” for many.
    3. seller financing is an “age old” tradition based on private property rights.
    4. these rules would prohibit even partial seller financing, such as carrying a seller second mortgage.
    5. according to HUD’s own “Residential Finance Survey”, done in 2001, roughly 40% of all non-farm residential properties in the U.S. are owned free and clear.
    6. An estimated 6-million people own a property other than their primary residence.
    7. An estimated 4.5% of U.S. residents own three or more properties, some of them purchased solely as investment properties.
    8. 40% of non-owner occupied residences are mobile homes, which are difficult to sell with bank financing; as of late, there are no financing mechanisms for single-wide mobile homes … none!
    9. Approximately 5% of the housing inventory in the United States is available for sale or lease and seller financing may be the only key to liquidating this inventory; additionally, taxes and fees are paid when these transactions take place, which keep the local economies moving.
    10. By implementing this rule, HUD would interfere and negatively impact the economic right of every American to engage in a contractual relationship regarding the buying and selling of real estate.
    11. HUD is a federal agency. Those rules if implemented would place constraints on property that is not under the jurisdiction of the federal government.

    These proposed regulatory changes would economically disparage homeowners who are desperate to sell their homes prior to being foreclosed or short sold; by giving them the opportunity to sell their property to someone who can afford them, which would also save the courts the legal burden of having to hear and rule on foreclosure actions. The dockets for these types of cases are already burdened and these rule changes would further exacerbate an already strained justice system.

    Please do all you can to make your voice heard. We only have until March 5th! Thank you.

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