"President Obama's budget projects hundreds of thousands of new job openings in government and for government contractors during his first term. How do you find and land one well suited to you?" is excerpted from a Kiplinger article by Marty Nemko who offers the interesting advice:

"Especially when aiming for a government job, I reject the standard career-counselor advice to use your network to gain access to people with the power to hire you. My clients increasingly find that it's more time-effective to search the best job Web sites regularly by keyword and zip code for on-target job openings and then craft a top-notch application for each."

Click here to read Marty Nemko's extremely helpful article on how to land a government job now.

FTC Alert on Federal and Postal Job Scams:

You never have to pay for information about job vacancies or employment opportunities with the U.S. government or U.S. Postal Service. But some fraudulent promoters are victimizing many Americans by selling information about federal job opportunities. These scam artists advertise in the classified sections of newspapers and offer – for a fee – to help job seekers find and apply for federal jobs. Some fraudulent companies even try to confuse consumers by using names that sound like those of federal agencies, like the "U.S. Agency for Career Advancement" or the "Postal Employment Service."

Fraudsters may lie about the availability of federal job openings in your area. For example, the Postal Service has few vacancies for career positions, and for many of the entry-level jobs, you must take a written examination. Postal Service hiring takes place at the local level through 85 district offices. If someone tells you that postal jobs are available, check with the Postal Service to determine if hiring is taking place and if an exam is required for eligibility. The tests usually are offered every few years in any particular district because of the high volume of applicants.

Federal agencies and the U.S. Postal Service never charge application fees or guarantee that an applicant will be hired. If positions require a competitive examination – and many do not – hiring agencies typically offer free sample questions to consumers who sign up for the exam.

It's deceptive for anyone to guarantee you a high score on the postal entrance examinations required for rural carrier associate, clerk, city carrier, mail handler, flat sorter machine operator, mail processor and markup clerk jobs. These exams test your general aptitude, something you can't necessarily increase by studying. Attending workshops, studying exam techniques and taking practice questions won't assure you of a top score on the exam – and even a top score doesn't guarantee that you'll be hired. You must meet other requirements, including passing a background check and a drug test. Some veterans receive hiring preferences.

The Federal Trade Commission (FTC) and the U.S. Office of Personnel Management urge job seekers to avoid falling for these tip-offs to federal and postal job rip-offs:

• Classified ads or verbal sales pitches that imply an affiliation with the federal government, guarantee high test scores or jobs or state that "no experience is necessary."
• Ads that offer information about "hidden" or unadvertised federal jobs.
• Ads that refer to a toll-free phone number. Often, in these cases, an operator encourages you to buy a "valuable" booklet containing job listings, practice test questions and tips for entrance exams.
• Toll-free numbers that direct you to other pay-per-call numbers for more information. Under federal law, any solicitations for pay-per-call numbers must contain full disclosures about cost. Also, the solicitation must make clear if there is an affiliation with the federal government. You must have a chance to hang up before you incur any charges.

If you have concerns about a company's advertisement for employment services, contact:

• Federal Trade Commission: 1-877-FTC-HELP (382-4357) or www.ftc.gov.
• U.S. Postal Inspection Service: Your local office is listed in the blue (Government) pages of your telephone directory.
• Your state attorney general or your local Better Business Bureau.

Federal job information is available through the U.S. Office of Personnel Management's USAJOBS at www.usajobs.opm.gov. Information on postal jobs is available at your local post office. In many areas, the Postal Service offers a job information hotline with current hiring announcements. Also, check the Postal Service website at www.usps.gov.

The FTC works for the consumer to prevent fraudulent, deceptive, and unfair business practices in the marketplace and to provide information to help consumers spot, stop, and avoid them. To file a complaint or to get free information on consumer issues, visit ftc.gov or call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 1-866-653-4261. The FTC enters consumer complaints into the Consumer Sentinel Network, a secure online database and investigative tool used by hundreds of civil and criminal law enforcement agencies in the U.S. and abroad.

"This paper takes a skeptical look at a leading argument about what is causing the foreclosure crisis and what should be done to stop it. We use an economic model to focus on two key decisions: the borrower's choice to default on a mortgage and the lender's subsequent choice whether to renegotiate or modify the loan. The theoretical model and econometric analysis illustrate that unaffordable loans, defined as those with high mortgage payments relative to income at origination, are unlikely to be the main reason that borrowers decide to default. In addition, this paper provides theoretical results and empirical evidence supporting the hypothesis that the efficiency of foreclosure for investors is a more plausible explanation for the low number of modifications to date than contract frictions related to securitization agreements between servicers and investors. While investors might be foreclosing when it would be socially efficient to modify, there is little evidence to suggest they are acting against their own interests when they do so. An important implication of our analysis is that policies designed to reduce foreclosures should focus on ameliorating the immediate effects of job loss and other adverse life events rather than modifying loans to make them more affordable on a long-term basis."

Click here to go to the Atlanta Federal Reserve Bank for the full details and to download and read the full report.

The Federal Reserve Board, the Office of Thrift Supervision, and the National Credit Union Administration today proposed clarifications to aspects of their December 2008 final rules under the Federal Trade Commission Act (FTC Act) prohibiting certain unfair credit card practices. The Federal Reserve Board also proposed clarifications to its December 2008 final rule under the Truth in Lending Act (TILA) amending Regulation Z to improve the disclosures consumers receive in connection with credit card accounts and other revolving credit plans.

The proposals are intended to facilitate compliance with the December 2008 final rules without reducing protections for consumers. They would resolve areas of uncertainty and make technical corrections to ensure that institutions are able to come into compliance with the rules on or before the July 1, 2010 effective date. In particular, the proposals would clarify that:

• The key protections in the final rules would continue to apply to balances on a consumer credit card account when the account is closed or acquired by a different institution or when the balances are transferred to another account issued by the same institution. For example, an institution would not be permitted to increase the rate on a credit card balance because the account has been closed.
• Institutions and retailers may continue to offer deferred interest and similar programs, but these programs are subject to all of the protections in the final rules. For example, if a consumer makes a purchase under this type of program, the terms governing interest charges on that purchase cannot be changed through a “hair trigger” or “universal default” rate increase. In addition, institutions and retailers must comply with enhanced disclosure requirements.

The Federal Register notices are attached. Comments on the proposals must be submitted within 30 days after publication in the Federal Register, which is expected shortly.

Federal Register notice, Federal Trade Commission Act (413 KB PDF)

Federal Register notice, Regulation Z (246 KB PDF)

G-10 (A) Applications and solicitations model form (credit cards) (75 KB PDF)

G-18 (G) Periodic statement form (202 KB PDF)

The Federal Reserve Board announced Monday that the Consumer Advisory Council will hold its next meeting on Thursday, March 26.  The meeting will take place in Dining Room E, Terrace Level, in the Board's Martin Building.  The session will begin at 9:00 a.m. and is open to the public.  Anyone planning to attend the meeting should, for security purposes, register no later than Tuesday, March 24, by completing the form found online at:  https://www.federalreserve.gov/secure/forms/cacregistration.cfm Attendees must present photo identification to enter the building.

The Council's function is to advise the Board on the exercise of its responsibilities under various consumer financial services laws and on other matters on which the Board seeks its advice.  Time permitting, the Council will discuss the following topics:

• Foreclosures
• Neighborhood and community stabilization
• Access to credit
• Proposed rules regarding overdraft services

Reports by committees and other matters initiated by the Council members may also be discussed.  The Board invites comments from the public on any of these matters.

The Board's notice is attached.

Attachment (18 KB PDF)

Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
Office of the Comptroller of the Currency
Office of Thrift Supervision

The federal bank regulatory agencies announced today that they will start conducting forward-looking economic assessments of large U.S. banking organizations as the Capital Assistance Program (CAP) gets underway. These assessments will be done on an interagency basis as a coordinated supervisory exercise to ensure they are carried out in a timely and consistent manner. Supervisors will work with institutions to estimate the range of possible future losses and the resources to absorb such losses over a two-year period.

Currently, the major U.S. banking institutions have capital in excess of the amounts required to be considered well capitalized. The CAP is designed to ensure that major U.S. banking organizations have sufficient capital to perform their critical role in our financial system on an ongoing basis and can support economic recovery, even in more severe economic environments.

The assessments will be conducted at eligible U.S. bank holding companies with assets exceeding $100 billion under two economic scenarios: a baseline and a more adverse scenario. The baseline scenario reflects a consensus expectation among private forecasters and the more adverse scenario reflects a deeper and longer recession than in the baseline. The agencies expect to complete the assessment process as soon as possible, but no later than the end of April 2009.

The agencies are issuing a set of Frequently Asked Questions (FAQs) with additional details about the assessment process. The FAQs are attached.

# # #

(FDIC: PR-25-2009)

Attachment:
FAQs – Supervisory Capital Assessment Program – PDF (PDF Help)

Media Contacts:

Dollar Fell in December

The average monthly value for the trade-weighted dollar index of 15 major currencies tracked by the Federal Reserve Bank of Atlanta fell 1.3 percent in December from the previous month. The dollar posted the greatest decrease in the European subindex with a 3.7 percent decline. The Americas subindex rose 1.8 percent while the Pacific-excluding-Japan subindex fell 0.9 percent. The Pacific index declined 2.9 percent. The classic subindex, which is the analogue of the original Atlanta index, was down 1.9 percent. The overall index was 9.8 percent above its year-ago level in December. On a daily basis, the overall index rose 13.7 percent from the low reached on March 18 to the end of December. The daily index was 9.1 percent above its value at the end of December 2007.

The Atlanta Fed index is based on 1995–97 bilateral trade weights for 15 currencies. The European subindex includes the European Monetary Union, Switzerland and the United Kingdom. The Pacific subindex includes Australia, China, Hong Kong, Japan, Malaysia, Singapore, South Korea and Taiwan. The Americas subindex includes Brazil, Canada and Mexico. The overall dollar index includes the Saudi Arabian riyal along with the foregoing 14 currencies. The classic subindex includes the European Monetary Union, Switzerland, the United Kingdom, Australia, China, Hong Kong, Japan, Singapore, South Korea, Taiwan, Saudi Arabia and Canada. All figures are indexes and not actual exchange rates. A rise in the index or subindex reflects a strengthening of the dollar against currencies included.

Click here for more details and charts.

Release Date: January 7, 2009

For immediate release

The Federal Reserve Board named ten new members to its Consumer Advisory Council for three-year terms and designated a new Chair and Vice Chair of the Council for 2009.

The Council advises the Board on the exercise of its responsibilities under the Consumer Credit Protection Act and on other matters in the area of consumer financial services.  The Council meets three times a year in Washington, D.C.

Edna Sawady was designated Chair; her term runs through December 2009.  Ms. Sawady is an economic inclusion consultant in New York, New York.

Michael D. Calhoun was designated Vice Chair; his term on the Council ends in December 2010.  Mr. Calhoun is President of the Center for Responsible Lending in Durham, North Carolina.

The ten new members are:

Paula Bryant-Ellis
Tulsa, Oklahoma

Paula Bryant-Ellis is Senior Vice President and Manager of the Community Development Banking Group for the seven bank subsidiaries of BOK Financial Corp., a $22 billion regional financial services company based in Tulsa, Oklahoma.  She is also President of the BOKF Community Development Fund, a community development corporation and an equity subsidiary created to focus on supporting affordable housing, economic development, small business expansion, and the revitalization and stabilization of low- and moderate-income communities for the seven banks.  In her current role, Ms. Bryant-Ellis is responsible for overseeing the banks' lending, investments, and compliance with the Home Mortgage Disclosure Act and the Community Reinvestment Act.  Under her leadership, BOK Financial's largest bank subsidiary, Bank of Oklahoma, received its first "Outstanding" CRA performance rating in 2006.  Three other subsidiaries, Colorado State Bank and Trust, Bank of Arizona, and Bank of Albuquerque, received their first "Outstanding" CRA rating in 2008.  Ms. Bryant-Ellis previously served on the Tulsa Industrial Authority, where she was Chair of the Credit Committee.  In 2006, she served as President of the Tulsa Economic Development Corporation, and in 2008, she was appointed by the Mayor to serve as commissioner of the Tulsa Development Authority.

John P. Carey
Long Island City, New York

John Carey is Executive Vice President and Chief Administrative Officer for Citi Cards, the U.S. credit card division of Citigroup, Inc.  In this role, he is responsible for business practices, customer privacy, control and compliance, networks management, community relations, cards communications, and regulatory relationship management.  Previously, Mr. Carey worked at MBNA and Bank of America, where he held senior positions covering legal and regulatory matters and managing segments of the credit card business.  During the Bank of America/MBNA merger, he served as a transition executive and managed the integration of the agent bank credit card business and the team that developed Bank of America's new privacy policy for the newly combined organization.  Before joining MBNA, Mr. Carey served as the general counsel at the Federal Emergency Management Agency.  He also served in the Clinton White House as Chief Counsel to the Office of Presidential Personnel, managing the legal team that vetted candidates for presidential nominations to the U.S. Senate.  Prior to joining the Clinton Administration, Mr. Carey practiced law in Washington, D.C.

Carolyn E. "Betsy" Flynn
Benton, Kentucky

Carolyn "Betsy" Flynn is President and Vice Chairman of Community Financial Services Bank, a $400 million institution that has served the local community for nearly 120 years and is one of the few community banks in the area.  She has been with the bank since 1976, and previous positions include Chief Operations Officer, Human Resources Director, and Compliance Officer.  She has been an instructor at the Barret School of Banking in Memphis, Tennessee. for 24 years.  In addition to her banking experience, Ms. Flynn has served in a variety of positions in the local community, including on the industrial development and regional economic development boards, tourist commission, Chamber of Commerce, and City Council.  She also participates extensively in banking trade associations at both the state and national level.

Patricia Garcia Duarte
Phoenix, Arizona

Patricia Garcia Duarte is the President and CEO of Neighborhood Housing Services (NHS) of Phoenix, a leading nonprofit affordable housing organization in its area.  She oversees NHS's financial literacy education, individual credit counseling, mortgage lending, affordable housing finance, and real estate developments.  Ms. Garcia Duarte is the Chair of the Arizona Foreclosure Prevention Task Force, which works to organize outreach and educational efforts to reduce the impact of foreclosures.  In this role, she has been a primary voice for the initiative and has been instrumental in bringing together various stakeholder groups.  Before joining NHS, she was the Arizona Manager of the Community Partnerships Office for JPMorgan Chase, where she led efforts to establish partnerships with local and national nonprofits.  She also was a housing developer for Mercy Housing Southwest and worked for Chicanos Por La Causa, where she managed more than 200 single-family properties in receivership of the Resolution Trust Corp. and implemented a lending program for rural small businesses.  Ms. Garcia Duarte is a member of the Phoenix Community Development Corporation.  Previously, she was a member of the Self Employment Loan Fund, the Phoenix Commission on Housing and Neighborhoods, and Housing for Mesa.  She was a founding member of the Arizona Microenterprise Alliance.

Ira Goldstein
Philadelphia, Pennsylvania

Ira Goldstein is the Director of Policy and Information Services at The Reinvestment Fund (TRF), a community development financial institution that manages $570 million in assets.  TRF provides financing in support of housing, commercial real estate, community facilities, and business.  Within TRF, the Policy and Information Services Group conducts research into a broad array of issues related to the organization's mission of building wealth and opportunity for low-wealth people and places.  Mr. Goldstein conducts housing market value analyses, which help governmental agencies and private (for- and not-for-profit) developers to make data-based decisions when allocating limited resources to distressed urban real estate markets.  His team also studies the dynamics related to foreclosures and predatory lending that undermine the value of home equity.  Before joining TRF, Mr. Goldstein was the Regional Director of HUD's Mid-Atlantic Office of Fair Housing and Equal Opportunity.  In that role, he was responsible for directing the investigation and resolution of fair housing cases.  Previously, he was the Associate Director of the Institute for Public Policy Studies at Temple University.  He is a member of the Research Advisory Board of the Center for Responsible Lending and the Governor of Pennsylvania's Housing Advisory Committee.

Kirsten Keefe
Albany, New York

Kirsten Keefe is a senior staff attorney in the Consumer, Housing, and Community Economic Development unit of the Empire Justice Center in Albany, New York.  She focuses on statewide policy and legislative work regarding subprime mortgage lending and other consumer issues, and assists victims of consumer fraud, specializing in predatory lending and scams related to homeownership.  Ms. Keefe regularly trains and advises lawyers and housing counselors throughout New York regarding foreclosure prevention.  She is a steering committee member for New Yorkers for Responsible Lending, a statewide advocacy coalition, and is part of HomeSave, a coalition of housing advocates in the Capital Region of New York.  Ms. Keefe is the founding director of Americans for Fairness in Lending, a national campaign created to raise awareness of abusive lending practices and push for regulation.  Previously, she was a staff attorney at Community Legal Services in Philadelphia, where she represented low-income homeowners in foreclosure, bankruptcy, and predatory lending cases.  Ms. Keefe has taught consumer law at Temple University's Beasley School of Law.  She is on the board of the Capital District Community Loan Fund, a nonprofit community development financial institution, and serves on their loan review committee.

Larry B. Litton, Jr.
Houston, Texas

Larry B. Litton, Jr. is President and CEO of Litton Loan Servicing LP, where he oversees the day-to-day operations of a mortgage servicing portfolio that exceeds $70 billion and reaches all 50 states.  He has developed a cross-departmental plan to increase outreach to customers who are delinquent or for whom default is imminent.  He has also sought to develop alliances with consumer advocacy and other groups that are focused on housing issues to raise awareness of foreclosure avoidance options.  His previous roles at Litton included Chief Operating Officer, Executive Vice President, and Vice President of Default Administration.  Mr. Litton developed RADAR, a proprietary default-resolution software.  Mr. Litton's leadership positions include the Mortgage Bankers Association's Residential Board of Governors and the Board of Directors of the Texas Mortgage Bankers Association.  He is also a member of the American Securitization Forum, the Ohio Foreclosure Prevention Task Force, and the HOPE NOW Alliance.

Andres L. Navarrete
McLean, Virginia

Andy Navarrete joined Capital One in 1999.  He currently serves as the company's Senior Vice President and Chief Counsel for National Lending and Regulatory matters.  His responsibilities include managing legal support for several major lines of business, including U.S. card, auto finance, small business, international, and mortgage.  Mr. Navarrete also manages the Legal Department's team of corporate and consumer bank regulatory experts.  This team provides comprehensive bank regulatory support for Capital One on an enterprise-wide basis.  Mr. Navarrete also managed the company's federal and state policy affairs functions on an interim basis.  Prior to joining Capital One, Mr. Navarrete was an attorney with the law firm of Morgan Lewis in Washington, D.C.  His practice focused on domestic and international financial services regulation, with specific responsibility for assisting banks in their efforts to enter into the insurance and securities markets.  During this period, Mr. Navarrete represented a bank/insurance trade association in its efforts relating to the Gramm-Leach-Bliley Financial Modernization Act.  Mr. Navarrete began his legal career in the International Section of the Legal Division of the Federal Reserve Board.  Prior to law school, he worked for the House Banking Committee and as a federal relations specialist for APCO Associates.

Jim Park
San Diego, California

Jim Park is President of the Asian Real Estate Association of America, a national nonprofit trade organization focused on expanding sustainable housing opportunities for Asian American and immigrant communities.  He is also the CEO and co-founder of New Vista Asset Management, which provides REO disposition services and works to generate awareness of foreclosures as affordable housing options for minorities as well as low- and moderate-income families.  Previously, he was Vice President for housing and industry relations at Freddie Mac, where he managed initiatives focused on supporting minority homeownership and education efforts.  As a Senior Advisor to the Federal Housing Administration Commissioner, he oversaw all legislative and policy issues impacting the FHA.  He also was Housing Policy Director at the National Community Development Association.  Mr. Park serves on the board of the Low Income Investment Fund, a national nonprofit community development financial institution (CDFI) focused on housing, child care, and charter school financing.   He also serves on the board of the Asian Pacific American Institute for Congressional Study, a nonpartisan organization focused on developing the future elected leadership within the Asian American community.  He is a past President and one of the founding board members of the National Coalition for Asian Pacific American Community Development.  He served for four years on the board of the National Association of Hispanic Real Estate Professionals and is a past board member and current trustee of the National Housing Conference.

Mary Tingerthal
St. Paul, Minnesota

As President of Capital Markets Companies for the Housing Partnership Network (HPN), Mary Tingerthal is responsible for several HPN-operated entities, including a community development financial institution, a financing partnership for charter schools, and a venture capital company.  Recently, she has had lead responsibility for the National Community Stabilization Trust, a joint effort of Enterprise Community Partners, HPN, Local Initiatives Support Corp. (LISC), and NeighborWorks.  Before joining HPN, Ms. Tingerthal was Senior Vice President of Capital Markets for the Community Reinvestment Fund in Minneapolis, where she was responsible for the purchase and sale of loan assets.  Previously, she was the President and CEO of the National Equity Fund, Inc., a wholly owned subsidiary of LISC that provided syndicated investments in affordable multi-family development projects for large institutional investors.  Other previous positions include Managing Director of home equity products for GMAC Residential Funding Corp. and Deputy Director for Housing for the City of Saint Paul.  Ms. Tingerthal is a board member of the National Housing Trust, CommonBond Communities, and NHT/Enterprise Preservation Corporation.  She is a trustee of the National Community Investment Fund and a member of the Calvert Foundation's Internal Investment Committee.

Council members whose terms continue through 2009 are:

Jason Engel
Vice President and Chief Regulatory Counsel
Experian
Costa Mesa, California

Joseph L. Falk
Consultant
Akerman Senterfitt
Miami, Florida

Louise J. Gissendaner
Senior Vice President, Director of Community Development
Fifth Third Bank
Cleveland, Ohio

Patricia Hasson
President
Consumer Credit Counseling Service of Delaware Valley, Inc.
Philadelphia, Pennsylvania

Thomas James
Senior Assistant Attorney General, Consumer Counsel
Consumer Fraud Bureau
Office of the Illinois Attorney General
Chicago, Illinois

H. Cooke Sunoo
Director
Asian Pacific Islander Small Business Program
Los Angeles, California

Stergios "Terry" Theologides
Executive Vice President, General Counsel
Saxon Mortgage
Irving, Texas

Linda Tinney
Vice President, Community Development
West Metro Region Manager
U.S. Bank
Denver, Colorado

Luz Urrutia
Chief Executive Officer and President
El Banco de Nuestra Comunidad
Roswell, Georgia

Council members whose terms continue through 2010 are:

Alan Cameron
President and Chief Executive Officer
Idaho Credit Union League
Boise, Idaho

Kathleen Engel
Associate Professor of Law
Cleveland-Marshall College of Law
Cleveland, Ohio

Greta Harris
Vice President–Southeast Region
Local Initiatives Support Corporation
Richmond, Virginia

Lorenzo Littles
Dallas Director
Enterprise Community Partners, Inc.
Dallas, Texas

Saurabh Narain
Chief Fund Advisor
National Community Investment Fund
Chicago, Illinois

Ronald Phillips
President
Coastal Enterprises, Inc.
Wiscasset, Maine

Kevin Rhein
Division President
Wells Fargo Card Services
Minneapolis, Minnesota

Shanna Smith
President and CEO
National Fair Housing Alliance
Washington, District of Columbia

Jennifer Tescher
Director
Center for Financial Services Innovation
Chicago, Illinois

Housing, Mortgage Markets, and Foreclosures

The U.S. financial system has been in turmoil during the past 16 months.  Credit conditions have tightened and asset values have declined, contributing substantially, in turn, to the weakening of economic activity.  As the participants in this conference are keenly aware, I am sure, housing and housing finance played a central role in precipitating the current crisis.  As the crisis has persisted, however, the relationships between housing and other parts of the economy have become more complex.  Declining house prices, delinquencies and foreclosures, and strains in mortgage markets are now symptoms as well as causes of our general financial and economic difficulties.  These interlinkages imply that policies aimed at improving broad financial and economic conditions and policies focused specifically on housing may be mutually reinforcing.  Indeed, the most effective approach very likely will involve a full range of coordinated measures aimed at different aspects of the problem.

I will begin this morning with some comments on developments in the housing sector and on the interactions among house prices, mortgage markets, foreclosures, and the broader economy.  I will then discuss both some steps taken to date and some additional measures that might be taken to support housing and the economy by reducing the number of avoidable foreclosures.  As we as a nation continue to fashion our policy responses in coming weeks and months, we must draw on the best thinking available.  I expect that the papers presented at this conference will add significantly to our understanding of these important issues.

Developments in Housing and Housing Finance
As you know, the current housing crisis is the culmination of a large boom and bust in house prices and residential construction that began earlier in this decade.  Home sales and single-family housing starts held unusually steady through the 2001 recession and then rose dramatically over the subsequent four years.  National indexes of home prices accelerated significantly over that period, with prices in some metropolitan areas more than doubling over the first half of the decade.¹ One unfortunate consequence of the rapid increases in house prices was that providers of mortgage credit came to view their loans as well-secured by the rising values of their collateral and thus paid less attention to borrowers' ability to repay.²

However, no real or financial asset can provide an above-normal market return indefinitely, and houses are no exception.  When home-price appreciation began to slow in many areas, the consequences of weak underwriting, such as little or no documentation and low required down payments, became apparent.  Delinquency rates for subprime mortgages–especially those with adjustable interest rates–began to climb steeply around the middle of 2006.  When house prices were rising, higher-risk borrowers who were struggling to make their payments could refinance into more-affordable mortgages.  But refinancing became increasingly difficult as many of these households found that they had accumulated little, if any, housing equity.  Moreover, lenders tightened standards on higher-risk mortgages as secondary markets for those loans ceased to function.

Higher-risk mortgages are not the only part of the mortgage market to have experienced stress.  For example, while some lenders continue to originate so-called jumbo prime mortgages and hold them on their own balance sheets, these loans have generally been available only on more restrictive terms and at much higher spreads relative to prime conforming mortgage rates than before the crisis.  Mortgage rates in the prime conforming market–although down somewhat from their peaks–remain high relative to yields on longer-term Treasury securities, and lending terms have tightened for this segment as well.

As house prices have declined, many borrowers now find themselves "under water" on their mortgages–perhaps as many as 15 to 20 percent by some estimates.  In addition, as the economy has slowed and unemployment has risen, more households are finding it difficult to make their mortgage payments.  About 4-1/2 percent of all first-lien mortgages are now more than 90 days past due or in foreclosure, and one in ten near-prime mortgages in alt-A pools and more than one in five subprime mortgages are seriously delinquent.³ Lenders appear to be on track to initiate 2-1/4 million foreclosures in 2008, up from an average annual pace of less than 1 million during the pre-crisis period.⁴

Predictably, home sales and construction have plummeted.  Sales of new homes and starts of single-family houses are now running at about one-third of their peak levels in the middle part of this decade.  Sales of existing homes, including foreclosure sales, are now about two-thirds of their earlier peak.  Notwithstanding the sharp adjustment in construction, inventories of unsold new homes, though down in absolute terms, are close to their record high when measured relative to monthly sales, suggesting that residential construction is likely to remain soft in the near term.

As I mentioned earlier, the problems in housing and mortgage markets have become inextricably intertwined with broader financial and economic developments.  For example, mortgage-related losses have eroded the capital of many financial institutions, leading them to become more reluctant to make not only mortgage loans, but other types of loans to consumers and businesses as well.  Likewise, some homeowners have responded to declining home values by cutting back their spending, and residential construction remains subdued.  Thus, weakness in the housing market has proved a serious drag on overall economic activity.  A slowing economy has in turn reduced the demand for houses, implying a further weakening of conditions in the mortgage and housing markets.

Reducing Preventable Foreclosures
Because developments in the housing sector have become so interlinked with the evolution of the financial markets and the economy as a whole, both macro and micro policies have a role in addressing the strains in housing.  At the macro level, the Federal Reserve has taken a number of steps, beginning with the easing of monetary policy.  To the extent that more accommodative monetary policies make credit conditions easier and incomes higher than they otherwise would have been, they support the housing market.

The Federal Reserve has also implemented a series of actions aimed at restoring the normal functioning of financial markets and restarting the flow of credit, including providing liquidity to a range of financial institutions, working with the Treasury and the Federal Deposit Insurance Corporation (FDIC) to help stabilize the banking system, and providing backstop liquidity to the commercial paper market.  The Federal Reserve supported the actions by the Federal Housing Finance Agency (FHFA) and the Treasury to put the housing-related government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, into conservatorship, thereby stabilizing a critical source of mortgage credit.  The Federal Reserve has also recently announced that it will purchase up to $100 billion of the debt issued by Fannie Mae, Freddie Mac, and the Federal Home Loan Banks and up to $500 billion in mortgage-backed securities issued by the GSEs.

Although broad-based macroeconomic policies help to create an economic and financial environment in which a housing recovery can occur, policies aimed more narrowly at the housing market are important, too.  In the remainder of my remarks, I will focus on policy options for reducing preventable foreclosures.

Foreclosures impose large costs on families who face the loss of their homes and reduced future access to credit.  But the public policy case for reducing preventable foreclosures does not rely solely on the desire to help people who are in trouble.  Foreclosures create substantial social costs.  Communities suffer when foreclosures are clustered, adding further to the downward pressure on property values.  Lower property values in turn translate to lower tax revenues for local governments, and increases in the number of vacant homes can foster vandalism and crime.⁵ At the national level, the declines in house prices that result from the addition of foreclosed properties to the supply of homes for sale create broader economic and financial stress, as I have already noted.⁶

On the surface, private economic incentives to avoid foreclosure would appear to be strong for the lender as well as the borrower.  Foreclosure dissipates much of the value of the property:  Indeed, recent losses on defaulted subprime mortgages have averaged around 50 to 60 percent of the loan balance.⁷ Besides the general decline in property values and foregone payments, fees related to foreclosure, such as court costs, maintenance expenses, and others, can amount to 10 to 15 percent of the loan balance; furthermore, the discount in value due to foreclosure status can be an additional 5 to 15 percent.⁸

However, despite the substantial costs imposed by foreclosure, anecdotal evidence suggests that some foreclosures are continuing to occur even in cases in which the narrow economic interests of the lender would appear to be better served through modification of the mortgage.  This apparent market failure owes in part to the widespread practice of securitizing mortgages, which typically results in their being put into the hands of third-party servicers rather than those of a single owner or lender.  The rules under which servicers operate do not always provide them with clear guidance or the appropriate incentives to undertake economically sensible modifications.⁹ The problem is exacerbated because some modifications may benefit some tranches of the securities more than others, raising the risk of investor lawsuits.  More generally, the sheer volume of delinquent loans has overwhelmed the capacity of many servicers, including portfolio lenders, to undertake effective modifications.

During more normal times, mortgage delinquencies typically were triggered by life events, such as unemployment, illness, or divorce, and servicers became accustomed to addressing these problems on a case-by-case basis.  Although taking account of the specific circumstances of each case remains important, the scale of the current problem calls for greater standardization and efficiency.  Loan modification programs with clearly defined protocols can both help reduce modification costs and protect servicers from the charge that they have acted arbitrarily.  The federal banking regulators have urged lenders and servicers to work with borrowers to avoid preventable foreclosures.  The regulators recently reiterated that position in a joint statement that encouraged banks to make the necessary investments in staff and capacity to meet the escalating workload and to adopt systematic, proactive, and streamlined modification protocols to put borrowers in sustainable mortgages.¹⁰

A number of initiatives have attempted to address the problem of unnecessary foreclosures.  Working in collaboration with the Treasury Department, the Hope Now Alliance, a coalition of mortgage servicers, lenders, housing counselors, and investors–led by Faith Schwartz, a member of the Fed's Consumer Advisory Council–has produced a set of guidelines that participating servicers have agreed to use as they work to prevent foreclosures.  In addition, servicers in the Alliance agreed to delay foreclosure proceedings if an alternative approach might allow the homeowners to stay in their home.  Recently, in conjunction with the FHFA, the coalition announced that its members will adopt a streamlined modification program for certain loans that they service for the GSEs.  This program will closely follow the one that the FDIC has introduced for modifying the loans in the portfolio that it took over from IndyMac.¹¹

The Federal Reserve has also been actively supporting efforts to prevent unnecessary foreclosures.  Through the System's Homeownership and Mortgage Initiative, we have conducted studies on housing and foreclosures, provided community leaders with detailed analyses to help them better target their borrower outreach and counseling efforts, and convened forums like this one to facilitate the exchange of ideas and the development of policy options.  Taking advantage of the Federal Reserve's nationwide presence, the twelve Reserve Banks have sponsored or co-sponsored more than 100 events related to foreclosures around the country since last summer, bringing together more than 10,000 lenders, counselors, community development specialists, and policymakers.  A particular focus of the Fed's efforts has been the mitigation of the costs to communities of high rates of foreclosure.  For example, we have partnered with NeighborWorks America on a neighborhood stabilization project and helped them develop responses to community needs as well as train local leaders.

Beyond these efforts, two government programs to facilitate loan modifications have been authorized, both through the Federal Housing Administration (FHA).  The FHASecure program has provided long-term fixed-rate mortgages to borrowers facing a rise in payments due to an interest rate reset.  Another, more recent program, dubbed Hope for Homeowners (H4H), allows lenders to refinance a delinquent borrower into a new, FHA-insured fixed-rate mortgage if the lender writes down the mortgage balance to create some home equity for the borrower and pays an up-front insurance premium.  In exchange for being put "above water" on the mortgage, the borrower is required to share any subsequent appreciation of the home with the government.

Although the basic structure of the H4H program is appealing, some lenders have expressed concerns about its complexity and cost, including the requirement in many cases to undertake substantial principal write-downs.  As a result, participation has thus far been low.  In response to these concerns, the board of the H4H program–on which Governor Duke represents the Federal Reserve–recently approved a number of changes, using the authority granted to it under the Emergency Economic Stabilization Act (EESA).  These changes would reduce the necessary write-down on some loans, address the complications caused by subordinate liens by permitting up-front payments to those lien holders, allow lenders to extend mortgage terms from 30 to 40 years to increase affordability, and eliminate the trial modification period to expedite loan closings.  It is still too early to know what the ultimate demand for H4H loans under this set of rules will be, but as I will discuss further momentarily, a case can be made for further adjusting the terms of the program to make it more attractive to both lenders and borrowers.

Despite good-faith efforts by both the private and public sectors, the foreclosure rate remains too high, with adverse consequences for both those directly involved and for the broader economy.  More needs to be done.  In the remainder of my remarks I will discuss, without ranking, a few promising options for reducing avoidable foreclosures.  These proposals are not mutually exclusive and could be used in combination.  Each would require some commitment of public funds.

To be effective, loan modifications should aim to put borrowers into mortgages that they can afford over the longer term.  During more normal times, many homeowners could be helped with a temporary repayment plan–for example, a deferral of interest payments for a period.  But under the current circumstances, with house prices declining and credit tight, permanent loan modifications will often be needed to create sustainable mortgages and keep people in their homes.  Most current proposals to reduce foreclosures incorporate this view and thus emphasize permanent modifications.

A more difficult design question turns on the extent to which the probability of default or redefault depends on the borrower's equity position in the home, as well as on the affordability of the monthly payment.  Although not conclusive, the available evidence suggests that the homeowner's equity position is, along with affordability, an important determinant of default rates, for owner-occupiers as well as investors.  If that evidence is correct, then principal write-downs may need to be part of the toolkit that servicers use to achieve sustainable mortgage modifications.¹²

If one accepts the view that principal write-downs may be needed in cases of badly underwater mortgages, then strengthening the H4H program is a promising strategy, as I have noted.  Beyond the steps already taken by the H4H board, the Congress might consider making the terms of H4H loans more attractive by reducing the up-front insurance premium paid by the lender, currently set in law at 3 percent of the principal value, as well as the annual premium paid by the borrower, currently set at 1-1/2 percent.  The Congress might also grant the FHA the flexibility to tailor these premiums to individual risk characteristics rather than forcing the FHA to charge the same premium to all borrowers.

In addition, consideration might be given to reducing the interest rate that borrowers would pay under the H4H program.  At present, this rate is expected to be quite high, roughly 8 percent, in part because it is tied to the demand for the relatively illiquid securities issued by Ginnie Mae to fund the program.  To bring down this rate, the Treasury could exercise its authority to purchase these securities, with the Congress providing the appropriate increase in the debt ceiling to accommodate those purchases.  Alternatively, the Congress could decide to subsidize the rate.

A second proposal, put forward by the FDIC, focuses on improving the affordability of monthly payments.  Under the FDIC plan, servicers would restructure delinquent mortgages using a streamlined process, modeled on the IndyMac protocol, and would aim to reduce monthly payments to 31 percent of the borrower's income.  As an inducement to lenders and servicers to undertake these modifications, the government would offer to share in any losses sustained in the event of redefaults on the modified mortgages and would also pay $1,000 to the servicer for each modification completed.¹³ The strengths of this plan include the standardization of the restructuring process and the fact that the restructured loans remain with the servicer, with the government being involved only when a redefault occurs.

As noted, the FDIC plan would induce lenders and servicers to modify loans by offering a form of insurance against downside house price risk.  A third approach would have the government share the cost when the servicer reduces the borrower's monthly payment.  For example, a servicer could initiate a modification and bear the costs of reducing the mortgage payment to 38 percent of income, after which the government could bear a portion of the incremental cost of reducing the mortgage payments beyond 38 percent, say to 31 percent, of income.  This approach would increase the incentive of servicers to be aggressive in reducing monthly payments, which would improve the prospects for sustainability.  Relative to the FDIC proposal, this plan would pose a greater operational burden on the government, which would be required to make payments to servicers for all modified loans, not just for loans that redefault.  However, this approach could leverage existing modification frameworks, such as the FDIC/IndyMac and Hope Now streamlined protocols, and in this respect would build on, rather than crowd out, private-sector initiatives.

Yet another promising proposal for foreclosure prevention would have the government purchase delinquent or at-risk mortgages in bulk and then refinance them into the H4H or another FHA program.  This approach could take advantage of the depressed market values of such mortgages, and buying in bulk might help avoid adverse selection problems.  In addition, scale efficiencies could be achieved by contracting with specialty firms (perhaps including the GSEs) capable of re-underwriting large volumes of loans to make them eligible for H4H or another program.  The Treasury has already considered how to undertake bulk purchases as part of its work under EESA, and the Federal Reserve has submitted to the Congress an analysis of bulk purchases per a legislative requirement in the H4H bill.  Even so, this program could take some time to get up and running, and the re-underwriting required for H4H loans would likely take more time and incur greater operational costs than other plans.  But such an approach could result in many homeowners being refinanced into sustainable mortgages.

Conclusion
The housing market remains central to the economic and financial challenges that we face.  Because housing and mortgage markets are tightly interlinked with the rest of the economy, actions to strengthen financial markets and the broader economy are important ways to address housing issues.  By the same token, steps that stabilize the housing market will help stabilize the economy as well.

In this regard, reducing the number of preventable foreclosures would not only help families stay in their homes, it would confer much wider benefits.  Significant efforts have been taken in this direction, but more can be done.  Today I have briefly discussed a few promising options, which are not necessarily mutually exclusive.  As we as a country consider ways to address our financial and economic challenges, policy initiatives to reduce the number of preventable foreclosures should be high on the agenda.

1. Estimates for specific metropolitan areas are based on Case-Shiller Home Price Indexes.  Return to text

2. See Kristopher Gerardi, Andreas Lehnert, Shane Sherlund, and Paul Willen (forthcoming), "Making Sense of the Subprime Crisis," Brookings Papers on Economic Activity (Washington:  Brookings Institution Press).  Also see Chris Mayer, Karen Pence, and Shane Sherlund (2008), "The Rise in Mortgage Defaults," Finance and Economics Discussion Series 2008-59 (Washington:  Board of Governors of the Federal Reserve System, November). Return to text

3. Estimates of delinquencies are based on data from the Mortgage Bankers Association and from First American LoanPerformance. Return to text

4. Foreclosure starts are based on data from the Mortgage Bankers Association, adjusted to reflect the limited coverage of their sample.  Historically, about half of foreclosure starts resulted in the borrower losing the home, but recent rates appear higher.  Return to text

5. For evidence that concentrations of foreclosures lead to lower house prices throughout the neighborhood, see, for example, William C. Apgar, Mark Duda, and Rochelle Nawrocki Gorey (2005),  "The Municipal Cost of Foreclosures:  A Chicago Case Study," Housing Finance Policy Research Paper 2005-1 (Minneapolis, Minn.:  Homeownership Preservation Foundation, February), www.995hope.org/content/pdf/Apgar_Duda_Study_Full_Version.pdf; and John P. Harding, Eric Rosenblatt, and Yao Vincent (2008), "The Contagion Effect of Foreclosed Properties,"  Social Science Research Network working paper 1160354 (July). Return to text

6. To be sure, policy should not attempt to keep house prices from falling sufficiently to stabilize the demand for housing.  But preventing avoidable foreclosures does not block necessary adjustments.  Indeed, failing to prevent such foreclosures may heighten the risk that house prices will move lower than they would otherwise need to go. Return to text

7. See J.P. Morgan (2008), "SOS–Summary of Subprime, Alt-A, Prime Jumbo," Global Structured Finance Research (November 2); and Credit Suisse (2008), "Deep Dive into Subprime Mortgage Severity," Fixed Income Research Report (June 19).  Return to text

8. See "Deep Dive," note 8.   Return to text

9. Servicers of mortgages in securitized pools must abide by the pooling and servicing agreements, which state what modifications may be prohibited but provide limited guidance about what types of modifications investors would consider to be appropriate.  See Larry Cordell, Karen Dynan, Andreas Lehnert, Nellie Liang, and Eileen Mauskopf (2008), "The Incentives of Mortgage Servicers:  Myths and Realities," Finance and Economics Discussion Series 2008-46 (Washington:  Board of Governors of the Federal Reserve System, November). Return to text

10. See Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and Office of Thrift Supervision (2008), "Interagency Statement on Meeting the Needs of Creditworthy Borrowers," joint press release, November 12. Return to text

11. In addition, Hope Now has been an important source of data on loss-mitigation activity.  The loan-level data that they plan to provide in the future will be useful for analyzing the relative effectiveness of alternative strategies for loan modifications. Return to text

12. Studies tend to find that equity positions matter most for default rates when they interact with other contributing factors; for example, numerous studies have found that borrowers are more likely to default when house prices have fallen and incomes decline.  At the household level, such "double triggers" may induce defaults because of cash flow constraints or because continuing to make payments on a mortgage whose balance significantly exceeds the value of the house is more difficult to justify when the family budget is strained.  See Shane Sherlund (forthcoming), "The Past, Present, and Future of Subprime Mortgages," Finance and Economics Discussion Series (Washington:  Board of Governors of the Federal Reserve System); Kristopher Gerardi, Christopher L. Foote, and Paul S. Willen (2008), "Negative Equity and Foreclosure: Theory and Evidence (354 KB PDF)," Public Policy Discussion Papers 08-3 (Boston:  Federal Reserve Bank of Boston, June); and Haughwout, Andrew, Richard Peach, and Joseph Tracy (forthcoming), "Juvenile Delinquent Mortgages:  Bad Credit or Bad Economy?" Journal of Urban Economics.   Return to text

13. The original plan would have had the government share half of any loss incurred by the lender, regardless of how far underwater the loan might have already been by the time of modification.  The latest version of the plan modifies this provision by offering lower loss-sharing rates for loans that have loan-to-value (LTV) ratios above 100 percent at the time of the modification. Under the modified plan, the loss-sharing rate declines from 50 percent on a loan with an LTV of 100 percent at the time of modification to 20 percent on a loan with a LTV of 150 percent.  Loans with LTVs of more than 150 percent at the time of modification do not qualify for loss-sharing.  An alternative way to address this concern would be to base the amount of the government insurance payment on the loss in value relative to the appraised value of the property at the time of the loan modification.

"The public policy case for reducing preventable foreclosures does not reply solely on the desire to help people who are in trouble," Bernanke said in a Dec. 4 speech. "Communities suffer when foreclosures are clustered, adding further to the downward pressure on property values."

New initiatives undertaken
Bernanke mentioned some organizations allied with the government that are working to reduce foreclosures. The Hope Now Alliance—a coalition of mortgage servicers, lenders, housing counselors, and investors—is working the U.S. Treasury and has produced guidelines that participating servicers have agreed to use as they work to prevent foreclosures.

The Federal Reserve created the Homeownership and Mortgage Initiative, which focuses on reaching community leaders and convening lenders, community development specialists, and policymakers to discuss the social cost of foreclosure. Bernanke also mentioned the FHASecure program, which provides long-term, fixed-rate mortgages to borrowers facing a rise in payments if their interest rate is about to reset higher. The Hope for Homeowners program allows lenders to refinance a delinquent borrower into a new fixed-rate mortgage if the lender writes down the mortgage balance to create equity for the borrower.

Helping homeowners helps the economy
Bernanke noted how intertwined the housing market and the overall economy are. "Actions to strengthen financial markets and the broader economy are important ways to address housing issues," he said. "As we as a country consider ways to address our financial and economic challenges, policy initiatives to reduce the number of preventable foreclosures should be high on the agenda."

Related post:

Housing, Mortgage Markets and Foreclosures

What's weird is it goes into effect in 18 months instead of "as fast as possible", especially since the country is in the middle of such a huge economic crisis. I don't pretend to be an expert in high-finance, but I kind of do notice when companies in my city are closing down everyday and hundreds to thousands of people getting laid off in my city weekly.

Anyhow, here's the press release the Federal Reserve put out today, December 18, 2008:

For immediate release

The Federal Reserve Board on Thursday approved final rules that would better protect credit card users by prohibiting certain unfair acts or practices and improving the disclosures consumers receive in connection with credit card accounts and other revolving credit plans.

The final rules prohibiting certain credit card practices were adopted under the Federal Trade Commission Act, and are being issued concurrently with substantially similar final rules by the Office of Thrift Supervision and the National Credit Union Administration.  Among other things, the rules will:

• Protect consumers from unexpected interest charges, including increases in the rate during the first year after account opening and increases in the rate charged on pre-existing credit card balances.
• Forbid banks from imposing interest charges using the "two-cycle" billing method.
• Require that consumers receive a reasonable amount of time to make their credit card payments.
• Prohibit the use of payment allocation methods that unfairly maximize interest charges.
• Address subprime credit cards by limiting the fees that reduce the amount of available credit.

In finalizing the rules on unfair credit card practices, the Board carefully considered information obtained through consumer testing and more than 60,000 comment letters received during the comment period.

"The revised rules represent the most comprehensive and sweeping reforms ever adopted by the Board for credit card accounts," said Federal Reserve Chairman Ben S. Bernanke.  "These protections will allow consumers to access credit on terms that are fair and more easily understood."

The Board is also adopting final rules to revise the disclosures consumers receive in connection with credit card accounts and other revolving credit plans to ensure that information is provided in a timely manner and in a form that is readily understandable.  These rules amend Regulation Z (Truth in Lending) and conclude a comprehensive review of the open-end credit rules.  The final rules under Regulation Z require changes to the format, timing, and content requirements for credit card applications and solicitations and for the disclosures that consumers receive throughout the life of an open-end account.  Many of the changes reflect the result of consumer testing conducted on behalf of the Board during its review.

"Our intent is to increase transparency and fairness in how credit card and deposit accounts operate, thereby enhancing competition and empowering consumers to better manage their accounts and avoid unnecessary costs," said Federal Reserve Governor Randall S. Kroszner.  "The rules represent a significant step forward in consumer protection.  By ensuring fairness and making credit terms easier to understand, these safeguards should allow more consumers to benefit from using credit."

Both of the final rules addressing credit card accounts take effect on July 1, 2010.

The Board is separately proposing rules to protect consumers that use overdraft services offered by their bank.  The rule solicits public comment on proposed amendments to Regulation E (Electronic Fund Transfers) intended to provide consumers a choice regarding their institution's payment of overdrafts for automated teller machine withdrawals and one-time debit card transactions.  The Board is proposing two alternative approaches to providing consumer choice, including a proposed requirement that would require institutions to obtain consumers' affirmative consent (or opt-in) before any overdraft fees or charges may be imposed on consumers' accounts.  The comment period for the Regulation E proposal ends 60 days after publication in the Federal Register.

In a related move, the Board is adopting final amendments to Regulation DD (Truth in Savings) to address depository institutions' disclosure practices related to overdraft services.  The effective date for the final rules adopted under Regulation DD is January 1, 2010.

All four Federal Register notices are attached.  Publication of each of the rules is expected shortly.

Highlights of Final Rules Regarding Credit Card Accounts (27 KB PDF)

Statement by Chairman Ben S. Bernanke

Statement by Governor Randall S. Kroszner

Federal Register notice, Regulation AA (848 KB PDF)

Federal Register notice, Regulation DD (110 KB PDF)
B-10 (70 KB PDF) Aggregate fee model

Federal Register notice, Regulation E (367 KB PDF)
Model forms and samples:

1. A-9 (23 KB PDF) Model consent form for overdraft services
2. A-9 (A) (24 KB PDF) Model opt-out form for account opening
3. A-9 (B) (9 KB PDF) Model opt-out form for periodic statements

Review and Testing of Overdraft Notices (1.94 MB PDF)

Federal Register notice, Regulation Z (2.18 MB PDF)
Model forms and samples:

1. G-10 (A) (81 KB PDF) Applications and solicitations model form (credit cards)
2. G-10 (B) (77 KB PDF) Applications and solicitations sample (credit cards)
3. G-10 (C) (79 KB PDF) Applications and solicitations sample (credit cards)
4. G-10 (D) (32 KB PDF) Applications and solicitations model form (charge cards)
5. G-10 (E) (111 KB PDF) Applications and solicitations sample (charge cards)
6. G-17 (A) (83 KB PDF) Account-opening model form
7. G-17 (B) (77 KB PDF) Account-opening sample
8. G-17 (C) (79 KB PDF) Account-opening sample
9. G-17 (D) (79 KB PDF) Account-opening sample (line of credit)
10. G-18 (A) (158 KB PDF) Periodic statement transactions: interest charges; fees sample
11. G-18 (D-E) (29 KB PDF) Periodic statement new balance, due date, late payment, and minimum payment sample (credit cards) and periodic statement new balance, due date, and late payment sample (open-end plans (non-credit-card accounts))
12. G-18 (F) (170 KB PDF) Periodic statement form
13. G-18 (G) (197 KB PDF) Periodic statement form
14. G-19 (18 KB PDF) Checks accessing a credit card sample
15. G-20 (100 KB PDF) Change-in-terms sample
16. G-21 (149 KB PDF) Penalty rate increase sample

Design and Testing of Effective Truth in Lending Disclosures: Findings from Qualitiative Consumer Research (3.78 MB PDF)

Design and Testing of Effective Truth in Lending Disclosures: Findings from Experimental Study (3 MB PDF)