THE ESSENCE OF TILA: BORROWER’S BILL OF RIGHTS

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EDITOR’S ANALYSIS: There is a reason why TILA, RESPA and HOEPA were enacted into law. The central theme, as clearly stated in a recent seminar led by lawyers for the banks, is to provide the consumer with a credible and understandable method of deciding between two or more potential loan offerings. The reason for these Federal Laws is to make certain that the borrower is given the information he/she needs to decide whether they want Deal A or Deal B — or none of the above.

These laws worked fairly well until wall Street stepped into the lending scenario with the illusion of securitization. The result was that the “disclosure documents” lied to the borrower. These documents took away the possibility of deciding between one loan or another and one lender or another because they intentionally misstated the identity of the lender in table-funded loans, which are identified by TILA and Reg Z as presumptively predatory loans.

The reason they are predatory is because a table-funded loan (funds and terms coming from an unidentified third party) actually tricks the borrower into thinking he/she knows the lender, thus eliminating the possibility for the borrower to reject the real lender.

The disclosure statements are also supposed to tell the borrower who is getting paid in their loan transaction and how much they are getting paid. Once again, the “disclosure” documents straight out lie to the borrower, by withholding vital information about the securitization scheme, without which the “lender” at the table would never have offered the loan.

If the securitization scheme was not in place at the time of the loan, the lender identified at closing would have had to assume risk, putting the loan on its financial statements as an asset (loan receivable) along with an entry for “reserve for bad debt”on the liability side of the balance sheet.

Of course it is easy to see why this disclosure was not made. Promises were made to the creditor (investor who advanced funds for a bogus mortgage-backed bond) including insurance, servicer obligations to continue payments, credit default swaps, and cross collateralization would have informed the borrower that the creditor was not getting the note they were signing.

The investors (I.E., THE REAL LENDER/CREDITORS) were getting a bond that included multiple sources of revenue to reduce the risk of non-payment from any of the parties who promised to pay. The borrowers would have learned that even if they made their payments on time, they could still be part of a pool that a Master Servicer would declare was in default or was subject to write-down, thus triggering payments from third parties.

The investment banks of course need to hide this information from borrowers who might be more likely to stop paying if they knew there were third party sources from which payments could be made. Any lawyer who knew these facts would have told them that it would be pretty difficult to declare the borrower in default when so many other people were obligated to pay for varying reasons that were not necessarily ties to whether the borrower made payments.

The robo-signing frenzy that ensued was a cover-up for obviously defective notes and mortgages that did not describe the actual transaction that took place — a single transaction in which investors advanced the money and borrowers received part of it, with the rest going to a myriad of third party players who were trading hedges, insurance and bets on the value of the mortgage bonds. Whether the homeowner actually made payments was and is almost irrelevant to the obligation of others (AIG, servicers et al) to make payments to the creditor either against principal, interest or both.

Nobody wanted the borrower to know what was really going on. But that is exactly what TILA, RESPA and HOEPA were all about — requiring the real lenders to show themselves, identify themselves, and disclose the identities of all the intermediary parties who were making money as a result of the money transaction between the investor and the homeowner.

The effect of this line of reasoning on RESCISSION remedies both under TILA (or HOEPA) is huge. The three day window is a “buyer’s remorse” window of opportunity where the borrower can reverse the transaction, no questions asked. If they go beyond the three-day window they have three years to cite a material violation and then give notice of rescission. Lenders want the courts to construe it as a claim of rescission but congress specifically worded the statute leaving it entirely within the hands of the homeowner and shifting the burden of the challenge to the “lender” who would be required to file a lawsuit (declaratory action) pleading and proving why the borrower should not be allowed to rescind.

The importance of rescission under TILA is that it gives the borrower the power to disconnect the mortgage lien from the property leaving the obligation unsecured. If there is a balance due from homeowner to “lender”, after the “lender” has returned all documents, filed the satisfaction (although Reg Z  says that the mortgage is terminated by operation of law upon sending of the notice to rescind) then the homeowner is obligated to tender a payment plan.

The failure to properly disclose the parties and terms and the outright lying that went on at nearly every closing, provides a window of opportunity to invoke the 3 day rule that starts from the date the disclosure is made. At this point, even with millions of foreclosures, the pretender lenders have still not identified the real lender or creditor and still have withheld the full accounting for the payments received by or on behalf of the real lenders or creditors. So, it would seem that the three-day right of rescission has not even begin to run in nearly all cases.

Now the new Consumer Financial Protection Bureau has inherited this problem and is charged withe responsibility of  making certain that at least future transactions comply with the law. But the future transactions include satisfactions, payoffs, foreclosures etc., all of which are predicated upon a false foundation of liens that were never perfected, defective and incurable. Politically it is a third rail to suggest that the banks be held tot he letter of the law. If the borrower showed up at closing by way of a straw-man the transaction would have been canceled or the “lender” would have cried “foul!” But now the shoe is on the other foot and what happens from this point forward is going to be interesting.

Sorting Through Lending Costs

The New York Times
By MARYANN HAGGERTY

PLENTY of people have ideas about what you should be told when you’re shopping for a mortgage, but for now, that may not be much help.

Even before it officially opened for business on July 21, the Consumer Financial Protection Bureau, the federal agency created to oversee mortgage lending, started looking at loan shopping. The bureau is legally required to propose by July 2012 a way to streamline mortgage disclosure. It is exploring avenues for combining the two forms that borrowers get now — the three-page Good Faith Estimate and the two-page Truth in Lending Act form.

These forms tell would-be borrowers the terms of their loan — for instance, how payments on an adjustable-rate mortgage change. They also lay out fees.

Although interest rates grab attention, fees can make a big difference, said Eileen Anderson, senior vice president of the Community Development Corporation of Long Island, which provides home buyer education. The easiest way to compare loans, she said, remains the Annual Percentage Rate, or A.P.R. That calculation rolls in fees as well as the stated interest rate. Because lenders are required to follow the same formula, useful comparisons can be made. “That’s the best way to shop for a loan, whether it’s 10 years ago, or now,” she said.

In May, the Consumer Financial Protection Bureau solicited reactions to two versions of a form that combines the current forms onto one double-sided sheet. It received more than 13,000 comments. According to a bureau summary, people praised the effort, but had specific suggestions on layout and phrasing.

On June 27 the bureau posted two more revised versions. The comment period on them closed July 5; among those responding was the Mortgage Bankers Association, which said in a three-page letter that the proposals didn’t mesh with current laws, and also criticized the mechanics and design. The bureau says forms are evolving.

All this comes less than two years after the Department of Housing and Urban Development overhauled the Good Faith Estimate — an effort that involved years of soliciting comments and was mightily resisted by some in the lending industry. That form not only changed the way information was presented, but also required brokers and lenders to commit to many parts of their estimates — a big change, as previous estimates sometimes had little relationship to actual closing costs.

But the forms themselves are longer and, for some borrowers, more confusing than the previous ones, Ms. Anderson said.

The form is still “horrible, just horrible,” said Mark Yecies, an owner of SunQuest Funding, a lender in Cranford, N.J. “The G.F.E. doesn’t actually itemize the closing costs in such a way that makes it easy for a borrower to understand what they are.”

Still, he advises people to get the form from every lender they approach. “If you receive approximate closing costs in an e-mail or a form that is not the G.F.E.,” he said, “it doesn’t mean squat.”

He added that some lenders had become adept at manipulating the estimates, by providing interest-rate quotations that expire almost instantaneously, or by low-balling fees in instances where they have legal flexibility. “If you get two or three different G.F.E.’s and there’s several thousand dollars’ difference,” he said, “you know someone is playing games.”

But David Flores, a financial counselor with GreenPath Debt Solutions in New York, which provides home buyer education, says game playing is not as big a problem as it used to be. “We’re removed from the day when it was a 3 percent interest rate with a big asterisk,” with the asterisk leading to fine print about teaser rates, he said.

Borrowers seem to have learned a lot from the attention paid to shaky loans in the last few years, he said. “More people are asking the right questions when it comes to these adjustable rates and exotic loan types. More people are wise to them.”

20 Responses

  1. Cheryl,

    Modification without the Investor coming forward? The PSAs grant their servicers the authority to conduct modifications, based upon the terms of the PSA. So you seem to suggest that this is not valid? I would heartily disagree.

    If the permission of the investor was needed without the PSA, then there could never be a modification as you suggest. That is because there are thousands of investors for each Trust, and based upon the structured tier of payments, what would be in the best interests of one would not be in the best interests of another. So, all the modifications that have been done for securitized loans would then be unlawful.

    Is this what you really believe?

    Approximately 5% of the affected population have taken to litigation to fight foreclosure. Of this 5%, most only want to receive a modification that they can live with, and afford. Between them, and the homeowners who want mods, but will not resort to litigation, that is where I am now focusing energies.

    My goal is to develop systems and methods so that a similiar crisis does not happen again. That is why I first developed a new method in which Loan Default Risk can be more accurately determined.

    Of course, there will be plenty of “blowback” to the method. That is because there are entities that do not want people to be properly evaluated for default risk. This includes realtors, loan brokers, homeownership advocates, and government officials and agencies.

    (Unfortunately, there are people who will never have the income, nor the financial responsibility to buy a home. Programs should not be developed to allow these people to buy homes that they cannot afford, which was a large part of the problem. And government should not be in the business of promoting home ownership.)

    The reality is that my new method would likely have denied most of you here for a loan, based upon default risk. The question to be asked is whether you would have accepted denial, or gone elsewhere for approval. (Most people did go elsewhere.)

    My newest product is designed to help people get modifications. It is a complete financial restoration method, based upon concurrent actions. Used with the default risk evaluation, it will provide lenders a balanced way to evaluate whether a borrower will likely succeed in any modification effort.

  2. Pat: I have a full understanding of the situation. I have learned alot from Neil’s website and homeowners who walk in my shoes. Neil has already given us all the correct information to assess our own similar situations. We can all relate and share information to help each other. Modifications cannot be done without the real investor coming forward. And that doesn’t happen. I will not sign a modification with a servicer (debt collector). There are clouded titles issues also. I have done lots of research and have done my share of filing complaints to no avail. Unfortunately there are homeowners out there that “don’t get it” and will sign a modification with the servicers (debt collectors). That is their decision. I am not a new or random visitor. I have been here 3 years talking to homeowners like myself.

    I love Neil’s articles. He is right on and has such compassion for the homeowners who have been defrauded by the Big Banks.

  3. Usedkarguy,

    Thank you. I know that my comments are generally not well received by many, but I want to convey needed information for a full understanding of the situation.

    Unfortunately, the palpable anger of many here serve to dissuade against reasonable discussion. Even worse, to the new or random visitor, the anger will often put off those visitors from returning again. And this certainly does not serve the purpose of this site.

    By your name, I would think that if you ever worked for a dealership, you might be familiar with how the lending worked. There were certainly credit lines issued, and I would bet that until the car was officially purchased by the financing agency, and the funds returned to the credit line, the dealership would be responsible, and would be the “lender”. If so, would this not be the same as with housing?

    People may not believe it, by I have no “side” in this battle of homeowner against lender. I only want to take an unbiased approach in what I do, and let the chips fall where they may. No one was completely without blame, and what is important is how to resolve the problems, stabilize housing, and begin recovery. Even then, we are talking up to 10 years to stabilize housing.

    In the next two weeks, I expect to introduce a new product for people hoping to achieve a reasonable modification. This is a completely different approach to modification efforts, and is a plan for “financial recovery” for homeowners. The plan will lower Default Risk significantly for all involved.

    So far, the people I have discussed it with have been very impressed with the approach. Initial contacts with small lenders, attorneys, and investors have been extremely positive.

    Of course, this product is only for people who desire modifications. It will not work for anything else.

  4. Cheryl,

    I am happy to hear that you have seen some of the related documents, and have at least read them and then articles about them. But, there is more to the situation than what you believe. (I have seen hundreds of the documents that you speak, from Mortgage Loan Purchase Agreements (MLPA), to the actual Notes securing such, Warehouse Credit Agreements and Notes, and other documents that you will never see. I have such documents for each major lender and most minor lenders in my files.)

    The documents must be correctly interpreted in accordance with all other factors and documents, and then statutes. This is where people fail in their understanding of the documents.

    Any Warehouse line consists of two major documents, the MLPA and the Note, though there are often other supporting documents. These documents cover the requirements of the Warehouse line. (A lender typically has several different lines, and not just one.)

    The funding lender will pay interest on the Credit Line for what amounts are used, just like homeowners do with LOEs. When the loan is finally “sold”, then the line is reimbursed, and no interest is due anymore. (If an amount is not used, then no interest is due.)

    When a funding lender does a loan, he selects which line to fund the loan through. Usually, dependent upon who the Warehouse Line is through, a lender may get pre-approval for the loan, or may elect to fund without pre-approval. The need for pre-approval or not, is often related to the previous “history” that the Warehouse lender has with the funding lender.

    A pre-approved funded loan may or may not require a full loan package prior to funding. Often, only limited documentation is required, or even just the underwriting approval. After the loan is funded, and all documents provided to the lender upon sale of the loan, full due diligence would be done by the “buyer”, but as we now know, this was not generally the practice.

    What all of this means is that the funding lender had complete liability until such time as the loan was sold. But the sale of the loan did not generally occur immediately upon closing. As a result, when payments were made, the difference between the interest due on the Credit Line and what the monthly interest payment was, belonged to the funding lender, until the sale of the loan.

    Furthermore, many loans were held by funding lenders for several months, before sale. Many different reasons exist for this that would take too long to go into, but it was a common occurrence.

    Actually, your situation would appear to suggest that what I had previously posted applied to your loan. And if you re-read what I had posted with an open mind, you would likely find that it was correct.

  5. Pat, that’s how things usually go here now. If your legal position does not line up with somebody else’s pipe-dream, you’re the one who must be wrong. I’ll give YOU credit (and thanks) for hanging around. And Neil, take no offense (I’m sure you don’t). There’s much to be considered at every turn. The competing arguments are welcomed. Just make sure they’re based in fact and not opinion.

  6. David,

    The Predatory Lending laws done by the states were undone by the Regulatory Agencies, and the Congress.

    Reckless Endangerment by Gretchen Morgensen was a very good attempt to explain how the process. She has some factual errors like when the first Securitization offerings occurred, and when Fannie began to do Subprime, but these errors do not detract from the overall read.

    Add to it the books like To Big To Fail, The Big Short, and others, one really sees a comprehensive picture of everything that happened.
    That said, I have not seen anyone address one other factor, and likely one of the most critical factors.

    From the 1968 beginning of Fannie Mae, there has been a complete change in the economy of the US. We transitioned from an Industrial Based Economy to a Service Based Economy. However, only Industrial Economies create true wealth. Service only transfers wealth.

    As the industrial base in the US decreased, it had to be replaced with another wealth creation device. What is easier for creating wealth than promoting home ownership, with the accompanying services, home building, infrastructure, furniture, appliances, schools, etc., being required?

    This is a major “unsung” motive to yet be introduced into the housing crisis matrix.

  7. Pat – Neil is right. The disclosure statements lie to the borrowers. I have been there and found out. I found a couple interesting articles on warehouseline and secondary market Money watch. Besides table funding there is warehouse lending. ‘Warehouse loan is secured by the mortgages closed by the mortgage co. Warehouse bank takes mortgage notes as collateral for its line. The collateral, i.e., the mortgage note, is secured by the real property. The risk to a bank is minimal because the mortgage servicing as collateral are usually pre-sold to a GSE that is obligated to purchase them pursuant to a commitment. Prior to closing the mortgage will be pre-sold with a written commitment in possession from an approved 3rd party investor. After closing the mortgage it is sold to the permanent investor and all monies from the sale will go directly to warehouse lender for dispersal. This means to me that instead of the trust holding the note, it was the warehouse lender. This is the secondary market. This was not disclosed to me at closing.

  8. Carie,

    I am referring to what Neil posted about TILA. You come in and try to change the subject. Why don’t you rebut what I say? That is, if you can find the arguments in statutes or case law?

  9. These anti-predatory laws are useless—–toohless—or this mess would not have happened

  10. Pat, do you know what “manufactured default” is?

  11. Pat, do you know what “manufactured default” means?

  12. People,

    Neil is trying to make arguments that have no legitimacy under TILA, RESPA and Federal Reserve Board Commentary. Here are relevant statutes and excerpts that show he is in error.

    Read the definition of Creditor under Consumer Credit Protection Act. (2) has it. This clearly identifies that the table funder/dealer is the entity in which the disclosures reveal.

    § 3500.5 Coverage of RESPA.

    “(D) Is made in whole or in part by a “creditor”, as defined in section 103(f) of the Consumer Credit Protection Act (15 U.S.C. 1602(f)), “that makes or invests in residential real estate loans aggregating more than $1,000,000 per year. For purposes of this definition, the term “creditor” does not include any agency or instrumentality of any State, and the term “residential real estate loan” means any loan secured by residential real property, including single-family and multifamily residential property; (7) Secondary market transactions. A bona fide transfer of a loan obligation in the secondary market is not covered by RESPA and this part, except as set forth in section 6 of RESPA (12 U.S.C. 2605) and § 3500.21. In determining what constitutes a bona fide transfer, HUD will consider the real source of funding and the real interest of the funding lender. “Mortgage broker transactions that are table-funded are not secondary market transactions. Neither the creation of a dealer loan or dealer consumer credit contract, nor the first assignment of such loan or contract to a lender, is a secondary market transaction” (see § 3500.2.)

    Consumer Credit Protection Act (15 U.S.C. 1602(f)),

    (f) The term “creditor” refers only to a person who both (1) regularly extends, whether in connection with loans, sales of property or services, or otherwise, consumer credit which is payable by agreement in more than four installments or for which the payment of a finance charge is or may be required, and ” (2) is the person to whom the debt arising from the consumer credit transaction” is initially payable on the face of the evidence of indebtedness or, if there is no such evidence of indebtedness, by agreement. Notwithstanding the preceding sentence, in the case of an open-end credit plan involving a credit card, the card issuer and any person who honors the credit card and offers a discount which is a finance charge are creditors. For the purpose of the requirements imposed under chapter 4 and sections 127(a)(5), 127(a)(6), 127(a)(7), 127(b)(1), 127(b)(2), 127(b)(3), 127(b)(8), and 127(b)(10) of chapter 2 of this title, the term “creditor” shall also include card issuers whether or not the amount due is payable by agreement in more than four installments or the payment of a finance charge is or may be required, and the Board shall, by regulation, apply these requirements to such card issuers, to the extent appropriate, even though the requirements are by their terms applicable only to creditors offering open-end credit plans. Any person who originates 2 or more mortgages referred to in subsection (aa) in any 12-month period or any person who originates 1 or more such mortgages through a mortgage broker shall be considered to be a creditor for purposes of this title. The term “creditor” includes a private educational lender (as that term is defined in section 140) for purposes of this title.

    Dealer loan or dealer consumer credit contract means, generally, any arrangement in which a dealer assists the borrower in obtaining a federally related mortgage loan from the funding lender
    and then assigns the dealer’s legal interests to the funding lender and receives the net proceeds of the loan.

    The funding lender is the lender for the purposes of the disclosure requirements of this part. If a dealer is a ‘‘creditor’’ as defined under the definition of ‘‘federally related mortgage loan’’ in this part, the dealer is the lender” for purposes of this part.” 3500.2

    Under the current RESPA regulations, table funding is defined as a settlement at which a loan is funded by a contemporaneous advance of loan funds and an assignment of the loan to the person advancing the funds. This RESPA definition is used to determine whether a transaction will be treated as a loan or as a secondary market transaction. The funding entity is responsible for meeting the disclosure requirements of RESPA if the transaction is a loan; the funding entity generally would have no responsibilities under RESPA if the transaction is a secondary market transaction. The purpose for which the RESPA standard was developed is therefore similar to the purpose for which the standard would be used in connection with the flood insurance regulations.

  13. “Recoupment” is not time barred by the statute of limitations applicable to TILA andhttp://www.amvona.com/latest-news/foreclosure/16453-new-jersey-denbeaux-tila-defense-deutsche-bank-vs-dominguez-and-status-of-boa-v-limato.html an attorney in NJ, Josh Denbeaux, has had success:

  14. Debt Collection Statute of Limitations – by State
    http://www.consumerfraudreporting.org/debtcollectionsol.php – CachedFind out what scams are being perpetrated in the name of debt collection; and your rights under the Fair Debt Collection Act on the useful free website.

    Debt problems: Statute of Limitations on Debt Collection
    http://www.bcsalliance.com/y_debt_sol.html – CachedFighting debt collectors: Statute of limitations on debt collection.
    California – Texas – Wage Garnishments — State Statutes

  15. Look up the statute of limitation to promissory note and written signed contract. It is Six years unless it is unsecured then it is three years in Washington State, Four years in Florida and Five years in Nevada. Tell the judge the alleged debt is timebarred.

  16. News for Investigative report on the Fed’s lending …

    International Business Times
    Fed audit: $16 trillion in loans to banks in less than three years
    Hot Air – 1 day ago
    The same firms also received trillions of dollars in Fed loans at near-zero … Federal Banks during the financial crisis, the authors of the report write, …
    73 related articles

  17. Type into your computer. Statutes of limitations for Debt Collection!
    Each state has a statutes of limitations for a promissory note and a written contract. [deed of trust] WA is 6 years. Florida is Four years and Na is I believe five years. Tell the judge the alleged debt is timebarred.

    Here is one article:Debt problems: Statute of Limitations on Debt Collection
    http://www.bcsalliance.com/y_debt_sol.html – Cached – Block all http://www.bcsalliance.com results
    State Statutes of Limitation on Debt Collection … See also: Debt Kit — Settle unsecured debts for less than half of amount owed …
    California – Texas – Wage Garnishments — State Statutes

    The Statute of Limitations Act – iinet.net.au

  18. I am a former Loan Originator from one of the largest (still standing strong) mortage brokerage companies in the US.

    When I was there, nearly every single loan was “closed” in the name of my employer and then was later assigned to the actual lender…usually very quickly (10 days max.) The borrower never knew the real lender until they got paperwork in the mail from them within two weeks of closing with my former employer.

    The company had a major wholesale line of credit…They would fund the loans and then sell them off to the banks when they had so many of them. It was not uncommon to close 300 million in a month, so it was easy for this company to do.

    Our broker compensation was never disclosed to the borrowers when loans were closed this way, because the company I worked for was set up as a “Correspondent Lender” with the banks they sold loans to (Citi, Chase, GMAC, TWB, etc.).

    I was explicity taught that correspondent lenders did NOT have to divulge what the compensation was on any loan — and our being correspondent lenders was a competitive advantage as a result of this lack of the need to disclose. [That said, the company is so big because their rates were always extremely low and their costs were low…so even if we HAD disclosed compensation, it would have showed we were earning less and were just very competitive – so I’m not sure if hiding the compensation really was that valuable on good clean loans.]

    Many of the larger brokerages were set up this way as “Correspondents”.

    I’m wondering if they just plain lied about the need to disclose compensation to the borrower or if it was legit that a “correspondent [wholesale] lender” closing the loan in their own name had a TILA loophole?

    I’ve seen many times on this blog, the idea that the loans are improper because of the failure to disclose compensation — but having worked on the front lines, I was often told that we had absolutely no requirement to disclose our compensation on a loan — UNLESS we were sending the loan to a bank with whom we did NOT have a “correspondent lender” arrangement and we were acting as a broker only — and the loan was actually closed by that lender (investor as we would call them.)

    Any clarity on this anyone?

  19. […] Livinglies’s Weblog Filed Under: Foreclosure Law News, Foreclosure News Tagged With: crisis, foreclosure, […]

  20. Don’t be expecting the CFPB to come riding into D.C. on a white horse to save the day. While Amerika slept, the House passed a bill essentially neutering the new agency even before the Grand Opening paint had dried.

    In times passed, the oligarchy hid behind shuttered doors, doing their nasties out of sight. Now days, they’re in your face and even daring the populace to do anything about their over-reach. Obama has said that he’d veto any such bill. However, what he’s said he would do and what he has actually done has differed in every case to date. In the mean time, the only change Obama and crew have offered the average Amerikan is a change of address, as their home is sold out from under them.

    We’d better start reaching back people, before it’s too late. Matt Stoller:

    Two years ago at this time we were in the midst of a major battle about whether and to what extent Congress would stand up to Wall Street and financial industry special interests and change the failed program of deregulation that led to the financial crisis. One year ago we applauded the progress made with the passage of the Dodd Frank Wall Street Reform and Consumer Protection Act. Today we are celebrating the new Consumer Protection Bureau officially opening its doors– so that for the first time there is a cop on the beat ensuring fair play for consumers in the financial marketplace.

    But the battle for accountability and transparency is anything but over. Today the House has passed H.R. 1315 the ‘Consumer Financial Protection Safety and Soundness Improvement Act’– a bill title that would make George Orwell blush. In fact, HR 1315 would cut the CFPB off at the knees, and make it impossible for it to do the job we need it to: standing up for Main Street, even when Wall Street doesn’t want it to.

    Earlier this week, we released a poll with AARP and the Center for Responsible Lending that demonstrates widespread support for the CFPB and Wall Street reform. By a 3 to 1 margin Americans want financial firms held accountable and financial reforms to take effect. And they want the CFPB– created by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010– to be up and running. By overwhelming margins and across the political spectrum they want the CFPB to make credit offers clearer, they want rules of the road for all kinds of financial companies, and they want an end to tricks and traps.

    Public Citizen was even more brutal in its assessment– and even more on target. Bartlett Naylor, Public Citizen’s Financial Policy Counsel:

    Public Citizen deplores the shameful vote in the House of Representatives today to emasculate the new Consumer Financial Protection Bureau. A House majority that votes against the interests of its own constituents who continue to suffer massive unemployment from the bank-caused recession has clearly lost its moral compass.

    There’s only one constituency that favors gutting the CFPB– abusive bankers. Unfortunately, the banking industry continues to funnel some of its profits into a lobby offensive to dismantle the new consumer agency so as to shield itself from the new cop on the beat enacted in the year-old Dodd-Frank law. And it paid off today.

    http://downwithtyranny.blogspot.com/2011/07/hr-1315-wall-streets-revenge.html

    Call your reps and tell them that you will not stand for this treasonous behavior. And then vote them all out next year, each and every one of them.

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