While some banks and other industry participants have stepped forward to increase the rate of modifications relative to foreclosures, many have not done enough. I would hope that both servicers and ultimate holders of the mortgages will take this occasion not just to correct documentation flaws and to contest who should bear the losses of mortgages gone bad, but to invigorate the modification process.
Next steps down the reform road I note that while last year’s conference was called “Regulatory Reform at the Crossroads,” this year’s event is entitled “The Dodd-Frank Act and the Road Ahead for Financial Regulatory Reform.” The metaphor of a long road ahead following key decisions in DoddFrank is an apt one for the Federal Reserve and other regulatory agencies that will, over the next 15 to 20 months, complete implementation of that bill through scores of regulations.