It has been a remarkable year for any agency to accomplish anything except spending its budget. The fact that CFPB is still functional, and despite threats from Congress, carrying out its mandate, is all the proof needed to show that Mr. Cordray is a great Director. In this election year much is being said about the interests of business vs the consumer and business vs the Country, the second matter being kept to an undercurrent. That said, if anyone was of the understanding that CFPB COULD be a Regulator and not an Enforcer, their view became moot: both a Regulator and Enforcer is what CFPB has become, to complement with one if its peers, the OCC. The settlement with Capital One and the after-action comments by the Bank, illustrate how effective CFPB is at dealing with Unfair and Deceptive practices by the banking enterprises which constantly use "the small print" or no print to hook consumers as customers, often being charged excessive fees that were never agreed to by the card holder. HAPPY BIRTHDAY CFPB and Good Luck Mr. Cordray Richard Isacoff [email protected]

It doesn't take much imagination or awareness of the current political environment in this Country to realize that any idea of disturbing the RMBS markets further will not get through Congress. The market makers in RMBS issues have too much money invested to allow any further "hit" to their bottom lines. The idea that the loss would be spread is fine so long as it does not affect the value of the securities that own the mortgage notes. As I wrote 3 years ago, the only way to have dealt with this issue would have been to have Congress state that all of the contracts for RMBS, Pooling Agreements, Trust Agreements, Assignments etc were voidable upon audit and national need. Of course I realized that the one time this has happened was during the Depression years but the Supreme Court supported the legislation. Further, I knew that there was no possibility that anything like that would even be thought about again. Money ruled and continues to do so. The arguments about "they deserve to lose their home because they can't afford it" (ad nauseam) no longer resonates based on the significant jobs losses some very responsible people have suffered. We are in an election cycle, and one that appears to be one of the nastiest yet. We are still in a horrid financial crisis, both within and without the Country. No one will convince the financial community that they should take a loss for the national good. Profit first - that's capitalism, really a corruption of the model but the one that resonates with most people. From the start, none of the programs could work; none had mandates from the central government; everything was a recommendation or guideline. When companies handling the modification process did not do modifications, they were instructed to do better and that their progress would be made available to the public. Accordingly, anything that was sent from Treasury, the Fed, FDIC, OCC, was ignored at will. The President can do very little with a gridlocked Congress. He cannot order principal reductions, he cannot order anything. Look to Congress for leadership - there is none. There is no solution that is acceptable to all and yet viable. There are no easy answers - we are allowing the on-going failure of the economy determine the outcome of the housing debacle rather than the other way around. Richard Isacoff [email protected]