Not only did the FBI accept the MBA's definitions, it ignored a mail campaign by a coalition of appraisal organizations which charged that lenders were pressuring appraisers to place artificially high prices on properties [and] “blacklisting honest appraisers” and instead assigning business only to appraisers who would hit the desired price targets. This campaign lasted from 2000 to 2007 and was signed by 11,000 appraisers.
In 2006 the MBA was invited to comment on proposals by the government to better regulate the mortgage market. The association argued that the proposals would stunt innovation and limit borrower’s access to credit.
Not being shy, Black concludes with this:
The FBI’s 2010 report is a Tea Party fantasy due to the MBA’s con. It reports only on the vastly smaller and less damaging mortgage frauds by lower social status individuals who exploited the fraud vulnerabilities that the officers controlling the lenders created when they gutted their underwriting and suborned their internal controls to make it possible to make hundreds of thousands of bad loans pursuant to the accounting control fraud “recipe” for a lender. The FBI report ignores the twin massive control frauds by mortgage originators that drove the financial crisis and led to endemic fraud in the sale of fraudulently originated mortgages to the secondary market. The MBA has conned the FBI in 2007, and the FBI has remained conned. The result is that the FBI operates under a faux definition of “mortgage fraud” in which it is conceptually impossible for the banks and their controlling officers to be criminals. The FBI is treating even the Nation’s most fraudulent mortgage lenders as the innocent “victims” of fraud by primarily low social status customers who often lack any financial sophistication.
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