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Judicial Watch • CFPB NY Response 6162011

CFPB NY Response 6162011

CFPB NY Response 6162011

Page 1: CFPB NY Response 6162011


Number of Pages:151

Date Created:May 25, 2011

Date Uploaded to the Library:February 20, 2014

Tags:Madigan, Powell, banks, Consumer, elizabeth, house, protection, warren, bureau, cfpb, Department of the Treasury, GSA, jeffrey, Patrick, AGENCY, treasury, ATF, Obama, White House, federal, State, State Department, James, DOJ, office, EPA, IRS, ICE, CIA, financial

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May 23, 2011  
Mr. Justin McCarthy Judicial Watch 425 Third Street, SW, Suite 800 Washingto 20024  

Dear Mr. McCarthy: 
This letter responds your correspondence dated May 13, 2011, regarding the abovereferenced FOIL request. have received your check the amowit of$36.25. 

Enclosed are documents numbered 110200-1 through 110200-150 that respond your request. 
This FOIL request now closed. 
Joshua Pepper 
Assistant Attorney General 
Enclosures 4/11/2011) Jeffrey Powell -The War Warren Page 
From: Jennifer Peacock  
To: "Chambers, Joseph J." , "Lehman, Philip" , Ben Diehl , Kate Sears  Patrick Madigan , Greg Slemp , Jack Norris , Laura Daugherty<>, Scott Palmer , Trish Connors  Victoria Butler  Adam Hartzell , Kevin Anderson , Phil Lelunan , RichardBischoff , usan Choe , Andy McCaHin , Jan Zavislan , Jennifer Dethroers , Ian McConnel , Morgan Zum , OwenLefkon , Sherry Hoffman , Brian Crossland , DavidBleicken , Donald DeBastiani , James Keiser  Date: 411/20115:17PM Subject: RE: Judicial Watch Public Records Request CFPB and Warren received it. 
Deborah Hagan 
Chief, Consumer Protection Division 
Illinois Attorney General's Office 
From: James Daross [] 
sent: Friday, April 01, 2011 4:12PM 
To: Jeffrey Powell; Laura Levine; Mary Alestra; Jeff Loeser; Jeff Hill; Jennifer Peacock; John Baron.i; Abundis, 
FOIL 110200 000011 
file://C:Documents and SettingsjpowellLocal SettingsTempXPgrpwise409608BDNE... 4/11/2011 

Cecilia; Hagan, Deborah; Boggs, Elizabeth; Ellis, Susan; Wrone, Steve; James, Thomas P.; Velasco, Vivian; Dave Huey; James Sugarman; Carolyn Matthews; Jeremy Shorbe; Jane Azia; Joseph Chambers; Matt Budzik; Anne Norton; cara Stretch; Ben Diehl; Kate Sears; Patrick Madigan; Greg Slemp; Jack Norris; Laura Daugherty; Scott Palmer; Trish Connors; Victoria Butler; Adam Hartzell; Kevin Anderson; Phil Lehman; Richard Bischoff; Susan Choe; Andy McCallin; Jan Zavislan; Jennifer Dethmers; Ian McConnel; Morgan Zurn; Owen Lefkon; Sherry Hoffman; Brian Crossland; David Bleicken; Donald DeBastiani; James Keiser Subject: Re: Judicial Watch Public Records Request CFPB and Warren also received request from Judicial Watch, which believe identical the one sent Tennessee. Has 
anyone else gotten it? Here the text: 
RE: Records Meetings and Communications with Elizabeth Warren 
...Ms. Warren announced December 2010, the Consumer Federation Amercia (CFA) Financial 
Services Conference that earlier that week she had gone 'to Florida meet with the Attorney Generals from 
across the country.' Hence, pursuant the provisions the Texas Public Infomraiton Act, codified 
Chapter 552 the Texas Government Code, Judicial Watch requests that your office produce the following 
within ten {10) business days: 
Any and all communications, contacts, and correspondence concerning, referring to, relating any and all meetings with CFPB, including but not limited Elizabeth Warren and her staff; 
Any and all records communications, contacts, and correspondence -including but not limited phone 
logs -concerning, referring to, relating any and all meetings with CFPB, including but not limited 
Elizabeth Warren and her staff; 
Any and all notes, minutes, agendas, menus, programs, presentations-whether displayed, disseminated, 

distributed print electronic form -concerning, referring to, relating any and all meeting with CFPB,  including but not limited Elizabeth Warren and her staff; Any and all travel itineraries for trips transporation any kind concerning, referring to, relating any and all meetings with CFPB, including but not limited Elizabeth Warren and her staff; and, 
5.' Any and all expense reports any kind concerning, referring to, relating any and all meetings with 
CFPB, including but not limite9 Elizabeth Warren and her staff. 
The time frame for this request from August 2010 through the present." 
Lisette Garcia 
Judicial Watch 
425 Third St., SW, Ste. 800 
Washinton, 20024 
James Daross 
Assistant Attorney General 
Consumer Protection and Public Health Division 
Office the Attorney General Texas 
401 Franklin Ave., Suite 530 
FOIL 110200 000012 
file://C:Documents and SettingsjpowellLocal SettingsTempXPgrpwise4D9608BDNE... 4/1112011 Paso, Texas 79901 

542-1546 FAX 

This memorandum may confidential and/or privileged pursuant Texas Government Code Sections 552.101, 
552.103, 552.107 552.111, and should not disclosed without the express authorization the Attorney 
General. >>>Jennifer Peacock  4/1/20111:06 >>> 
Heads -our front office received the attached public records request from Judicial Watch regarding CFPB and 
Elizabeth Warren. 

Jenni Peacock 
Assistant Attorney General 
Consumer Advocate and Protection Division 
Office the Tennessee Attorney General 
425 Fifth Avenue North (37243-3400) 

P.O. Box 20207 Nashville, Tennessee 37202-0207 Telephone: 615.741.3108 Facsimile: 615.532.2910 
The information contained this E-mail message intended only for the use the individual entity named above. the reader not the intended recipient, the employee agent responsible deliver the intended recipient, you are hereby notified that any dissemination, distribution, copying this communication strictly prohibited. you have received this communication error, please immediately notify telephone 615-741-1671 and permanently delete the message from your system. Receipt anyone other than the intended recipient not waiver any joint prosecution investigation privilege, attorney-client privilege, work product immunity any other privilege immunity. 
FOIL 110200 000013 

Jeffrey Powell -Re: FW: Judicial Watch PutJiic Records Request CFPB andWarren 
From: "James Daross"  To: "Jeffrey Powell" , "Laura Levine" , "Mary Alestra" , "Jeff Loeser" , "Jeff Hill" , "Jennifer Peacock" , "John Baroni" , "Cecelia Abundis" , "Deborah Hagan" , "Paige Boggs" , "Susan Ellis" , "Steve Wrone" , "Tom James" , "Vivian Velasco" , "Dave Huey" , "James Sugarman" , "Carolyn Matthews" , "Jeremy Shorbe" , "Jane Azia" , "Joseph Chambers" , "Matt Budzik" , "Anne Norton" , "Cara Stretch" , "Ben Diehl" , "Kate Sears" , "Patrick Madigan" , "Greg Slemp" , "Jack Norris" , "Laura Daugherty" , "Scott Palmer" , ''Trish Connors" ec Open Records Law TCA-10~7 503-505, Judicial Watch requests that your offir;e produce the following within seven (7) business days: 	
An~ and all co:trummications, contacts, and correspondence concerning, referring to, relating any and all meetings with CFPB, including but not limited Elizabeth Warren and her staff;  	
Ally and a.ll records communicutions, contacts, an.d correspondence-including but not limited phone logs concerning, referring to, relating any and. all meeting~ with CFPB, including but not limited Elizabeth WalTet'l. and her staff; 	
Any and all notes, minutes, agendas, menus, programs, presentations-whether displayed, dis!lcminated, distributed print electronic form concerning, referring to, relating any and all meetings wlth CFPB, including hut not limited Elizabeth Warren and her stafl;  	
AI~Y 0.11d all travel itin~raries for !rips transportation any kind co-uceming, 1eferring to, relating any IUld all meetings with C!PB, including but not limited Elizabeth Warren and her staff; and, 	
Any and all expense reports any kind concerning, referring to, relating any and all meetings with CFPB, including btJt not limited Elizabeth Warren and her staff 

425 Third SL., SW, Suite 800, WtLShington, 20024 Tel: (202) fi46-5l12 O'i' I-HK8-S93-8442 L~AX: ;:202) 646-S 199 E1t11il: info@Judicial www,JudiciolWnrch,Cll'g 
FOIL 110200 000017
E0/60 391'd 
H011'M 	l1'roranr Hl9P9606 :91 H0Z/GZ/EI3 

State Tennessee 
Ot'fict: ofthe Attorney General March 29,201.1 
The time frame for this request from August 2010 through ~epresent. 
Public records iilre defined all doctunents, papers, letters, maps, boolcs, photographs, microfilms, electronic data processing files and omput, films, sound recordings, other  material, regardless physical fom1 characteristics made received pursuant law ordillance connection with the transaction official business any governmental agency. TCA:-1 0-7-503(a)(l 
lfthis request denied you are required provide wtittcm statement the grounds tor such denial. TCA 10-7-503(2)(a)(ii). 
Ifany fee charged for copyiag the requested records, please notify i:o. advance ifthe expected cost likely exceed $150.00 
Ifyou not understand this request any portion thereat: you feel you require clarification, please iii.:unediately contact Judicial Watch Research Assistant Justin McCarthy 202~646-5172 Judicial Watch looks forward receiving the requested documents and waiver both sea-rob and duplication costs within seven (7) days. Thank you for your c1:>operation. 

Lisett~ Garcia, J.D. Senior Investigator Judicial Watch, Inc. of2 
E:0/E:0 38;ld 
H:JlJM l11Ioranr 

Jeffrey Powell -RE: CFPB Slides 
From: "Madigan, Patrick [AG]"  
To: "Madigan, Patrick [AG]" , "Abundis, Cecelia" , "Alestra, Mary" , "Anderson, Kevin ", "Azia, Jane" , "Baroni, John" , "Bischoff, Richard" , "Bleicken, David" , "Boggs, Paige" , "Budzik, Matt" , "Butler, Victoria" , "Chambers, Joseph" , "Choe, Susan" , "Conners, Trish" , "Crossland, Brian" , "Daross, Jim" , "Daugherty, Laura11 , "DeBastiani, Donald" , "Dethmers, Jennifer" , "Diehl, Ben" , "Ellis, Susan" , "Hagan, Debby" , "Hartzell, Adam , "Hill, Jeff" , "Hoffman, Sherry" , "Huey, Dave" , "James, Tom" , "Keiser, James" , "Lehman, Phil" , "Levine, Laura" , "Loeser, Jeff' , "Matthews, Carolyn" , "McCallin, Andy" , "McConnel, Ian" , "Norris, Jack" , "Norton, Anne" , 11Palmer, Scott" , "Peacock, Jennifer" , "Powell, Jeffrey" , ''Sears, Kate" , "Slemp, Greg" , "Stretch, Cara" , "Sugarman, James" , "Velasco, Vivian" , "Wrone, Steve" , "Zavislan, Jan" , "Zurn, Morgan"  Date: 2/25/2011 3:16PM Subject: RE: CFPB Slides ------- are for the call. Please use 1-877-284-2201 and PIN 7685617. 
From: [] 
Sent: Friday, February 25, 2011 2:04PM 
To: Madigan, Patrick [AG] 
Cc: WarrenE@treasury .gov; Rajeev .Date@treasury .gov; Richard.Co rdray@treasury .gov; 
Lucy. Morris@treasury .gov; Ethan. Bernstein@treasury .gov 
Subject: settlement slides 
Dear Patrick, 
Here, again, are the settlement slides for this afternoon's phone call. Best, 
Pat McCoy 
FOIL 110200 000019 
file://C:Documents and SettingsjpowellLocal SettingsTempXPgrpwise4D67C7E2NE... 4/11/2011 (4/11/2011 Jeffrey Powell-RE: CFPB Call TODAY at_2ET ---------~-------Pa_;;;ge__, ____ __1 
From: "Madigan, Patrick [AG]"  
To:  "Jeffrey Powell"  
Date: 2/15/2011 4:56PM 
Subject: RE: CFPB Call TODAY think will during tomorrow's call, that's ok. 

-----Original Message----From: Jeffrey Powell [] 
Sent: Tuesday, February 15,2011 2:11PM 
To: Madigan, Patrick [AG] 
Subject: RE: CFPB Call TODAY you have few minutes this afternoon discuss what was presented? got the Powerpoint). 

>"Madigan, Patrick [AG]"  2/15/2011 3:07PM 

-----Original Message----From: Jeffrey Powell [] 
Sent: Tuesday, February 15, 2011 1:06 
To: Deborah Hagan;;; Jane 
Azia; Cara Stretch; Benjamin Diehl; Kate Sears; Madigan, Patrick [AG]; 
Jack Norris; Laura Daugherty; Trish Conners; Victoria Butler; Adam 
Hartzell; Kevin Anderson; Phil Lehman; lan McConnel; Zum Morgan (DOJ) 
Subject: Re: CFPB Call TODAY can't get the call -get message saying the call has reached max. 

Jeffrey Powell 
Deputy Bureau Chief 
Bureau Consumer Frauds 
and Protection 
New York State Office Attorney General 
120 Broadway 
New York, New York 10271-0332 
Phone: (212) 416-8309 
Fax: (212) 416-6003 

>"Madigan, Patr!ck [AG]"  2/15/2011 12:53 

There going confidential briefing from the CFPB TODAY 
ET, CT, PT. Based understanding the briefing, 
inviting the Loss Mitigation Subgroup this call. The CFPB 
wanted stress the confidential nature this briefing. 
apologize for the short notice. This was put together quickly. 

FOIL 110200 000020 l{4/11/2011) Jeffrey Powell-RE: CFPB Call TODAY Page 

Please use: 
Dial-in# 202-927-2255 Access code 898862 
Thank you, 
Patrick Madigan Assistant Attorney General Iowa Attorney General's Office 1305 Walnut St. Des Moines, 50319 Phone: (515) 281-4250 Fax: (515) 281-6771 
FOIL 110200 000021 i(4/11/2011) Jeffrey Powell -RE: CFPB Call TODAY Page 

From: "Madigan, Patrick [AG]"  
To: "Jeffrey Powell"  
Date: 2/15/2011 3:07 
Subject: RE: CFPB Call TODAY 


-----Original Message----From: Jeffrey Powell [] 
Sent: Tuesday, February 15, 2011 1:06 
To: Deborah Hagan;;; Jane 
Azia; Cara Stretch; Benjamin Diehl; Kate Sears; Madigan, Patrick [AG]; 
Jack Norris; Laura Daugherty; Trish Conners; Victoria Butler; Adam 
Hartzell; Kevin Anderson; Phil Lehman; lan McConnel; Zurn Morgan (DOJ) 
Subject: Re: CFPB Call TODAY can't get the call -get message saying the call has reached max. 

Jeffrey Powell 
Deputy Bureau Chief 
Bureau Consumer Frauds 
and Protection 
New York State Office Attorney General 
120 Broadway 
New York, New York 10271-0332 
Phone: (212) 416-8309 
Fax: (212) 416-6003 

>"Madigan, Patrick [AG]"  2/15/2011 12:53 

There going confidential briefing from the CFPB TODAY 
ET, CT, PT. Based understanding the briefing, 
inviting the Loss Mitigation Subgroup this call. The CFPB 
wanted stress the confidential nature this briefing. 
apologize for the short notice. This was put together quickly. 

Please use: 

Dial-in# 202-927-2255 

Access code 898862 

Thank you, 

FOIL 0200 000022 

I(4i1W011) Jeffrey Powell-RE: CFPB Call TODA~a_t_2_E_T________________ Page 
Patrick Madigan Assistant Attorney G.eneral 
Iowa Attorney General's Office 
1305 Walnut St. 
Des Maines, 50319 
Phone: (515} 281-4250 
Fax: (515) 281-6771 

FOIL 110200 000023 

Jeffrey Powell -CFPB Call TODAY 
From: 	"Madigan, Patrick [AG]"  
To: 	"Jeffrey Powell" , "Hartzell, Adam" , "Phil Lehman" , "Anderson, Kevin" , "Conners, Trish" , "Daugherty, Laura" , "Butler, Victoria" , "Deborah Hagan" , , , "Zurn Morgan (DOJ)" , "McConnel, Ian" , "Benjamin Diehl" , "Kate Sears" , "Azia, Jane" , "Stretch, Cara" , "Norris, Jack"  
Date: 2/15/2011 12:53 Subject: CFPB Call TODAY 
CC: 	"Madigan, Patrick [AG]"  
There going confidential briefing from the CFPB TODAY ET, CT, PT. Based understanding the briefing, inviting the Loss Mitigation Subgroup this call. The CFPB wanted stress the confidential nature this briefing. apologize for the short notice. This was put together quickly. 
Please use: 
Dial-in 202-927-2255 Access code 898862 
Thank you, 
Patrick Madigan Assistant Attorney General Iowa Attorney General's Office 1305 Walnut St. Des Moines, 50319 Phone: (515) 281-4250 Fax: (515) 281-6771 
FOIL 0200 000024 
file:I/C :I).{.) :b0 ~.,; .,.~"" ~o"' .._o~'i" ~:."' ~"' ~~"' ~'? .. ,;,.<
Effective special servicing delinquent loans would have cost bps/yr more than the actual costs incurred 
--0 ----= 
Notional Billion Context $Billions 
soc ----------- ----""' 
... T~C01CI N"Cidi:ld T~5 TCE Nag E.quty 
Source: CFPB DRAFT-CONFIDENTIAL FOR MILLER penalty based servicing costs avoided would have little effect Tier capital ratios. 

----- ___________----,_8R11 bps 
Bank Wells Fargo Chase Citigroup ResCap U.S. SunTrust PNC Bank 
(Ally) Bancorp Servicer 
Tier Rat1o 
 Tier Ratio M1nus Penalty 

Given the magnitude the "shadow inventory" problem, have gravitated towards settlement solutions that enable asset liquidity and cast wide net. particular, have focused principal reduction~modifications and the short sales enabled them. borrowers become increasingly underwater, they are more likely defauH. date, though, principal reductions have been relatively under-utilized. 
Fig11r~ :!: 1),~.-,niJX"'il ie>n ,-,f IJdauh l'roh..,bi!il.~-by p,.,.. ,.,t Ik1,;ing Eoptity 
Figure Distribution ModiK:ation Type (All Sect(JS)   ~ ~ .. 
l'l  -., ..:-.-'....~. .---,.  ... -~.. - ,. -2001 -21m IUHO
j ~-~ 
:A:=115% 100% 1.Ci 
$27.9 $42.3 $33.3 $74.9 
  ~..:   , 
3.0 $41.8
$63.4 $7o.5 
$135.2 Note: Assuming servicers modify least underwater borrowers; excludes  Servicers fund write-down (makes FHA and loans investors whole} -But investors absorb write-down 
"""" Source: CFPB analysis based FRS staff research 
when NPV positive. DRAFT -CONFIDENTIAL FOR MILLER principal reduction mandate could meaningfully additive HAMP. 

Comparison Borrower Universe, Eligibility, and Impact Millions 

Jeffrey Powell -Letter from Reps. Bachus Moore Capito Elizabeth Warren 
From: "James Daross" To: "Jeffrey Powell" 1 "Laura Levine" 1 "MaryAiestra" 1 "Jeff Loeser" 1 "JeffHill" 1 "Jennifer Peacock" 1 "John Baroni" 1 "Cecilia Abundis"  "Deborah Hagan" 1 "Elizabeth Boggs" 1 "Susan Ellis" 1 "Steve Wrone" 1 "Thomas James" 1 "Vivian Velasco" 1 "Dave Huey" 1 "James Sugarman" 1 "Carolyn Matthews" 1 "Jeremy Shorbe" 1 "JaneAzia" , "Joseph Chambers" 1 "Matt Budzik" 1 "Anne Norton" 1 "Cara Stretch" , "BenDiehl" 1 "Kate Sears" 1 "Patrick Madigan" 1 "Greg Slemp" 1 "Jack Norris" 1 "Laura Daugherty" 1 "Scott Palmer" , "Donald DeBastiani" Ddebastian@state. pa. us>, 
"James Keiser"  
Date: 4/1/2011 5:34 
Subject: Letter from Reps. Bachus Moore Capito Elizabeth Warren 
Attachments: 03-30-11 Chairman Bachus letter Elizabeth Warren.pdf 

See the attached. 
James Daross 
Assistant Attorney General 
Consumer Protection and Public Health Division 
Office the Attorney General Texas 
401 Franklin Ave., Suite 530 Paso, Texas 79901 


542-1546 FAX 

This memorandum may confidential and/or privileged pursuant Texas Government Code Sections 552.101, 552.103, 552.107 552.111, and should not disclosed without the express authorization the Attorney General. 
FOIL 0200 000042 
fil~J/C...:.Do~.uments and Setti_ngsino:w~ULocal Settin!!sTemoXP~~:rowise4D96QC:88NE... 4/llLZ_Q11 

MEMO From: Christina Harvey To: ETS 
cc: Greg Krakower, Jeff Powell, Melissa DeRosa Re: Additional Information Appointees Consumer Fraud Protection Bureau Date: February 14, 2011 
Peggy Twohig Peggy Twohig currently serves Treasury's Director ofthe Office Consumer Protection and Policy Lead for the CFPB implementation team. Prior joining Treasury, Twohig worked the Federal Trade Commission enforcement and policy issues related consumer financial services, including directing the activities the Division Financial Practices. Before her work the FTC, Twohig practiced law with the firm Arnold Porter Washington D.C., handling civil litigation matters. her new role, Twohig will spearhead efforts conduct research and policy analysis around the creation the first federal non-depository supervision program. 
Steve Antonakes Steve Antonakes served the Commissioner ofBanks for the Commonwealth Massachusetts for the past seven years and oversaw nearly 240 state-chartered banks and credit unions and more than 4,500 non-bank financial entities. Antonakes also served voting member the Federal Financial Institutions Examination Council (FFIEC) and the Vice Chairman ofthe Conference State Bank Supervisors (CSBS). began his career entry level Community Reinvestment Act Bank Examiner June 1990 and worked his way through the management ranks become the Commissioner Banks only the second career bank examiner serve that position. his new role, Antonakes will build the consumer supervision program for the nation's largest depository institutions. 
From Elizabeth Warren Steve Antonakes and Peggy Twohig 
"There are plenty good lenders out there that want build their businesses around 
providing good service their customers, but the market doesn't work for them when 
some their competitors aren't playing the same rules," said Elizabeth Warren, 
who serves assistant the President and special advisor the Secretary the 
Treasury the CFPB. "Peggy and Steve will play critical roles building CFPB that 
will level the playing field between bank and non-bank lenders. For the first time 
consumer credit going regulated product instead the kind company 
selling it, and these two will instrumental developing this new approach." 
Richard Channin 
The rule-writing team will the CFPB will headed Richard Channin, who was 
the deputy director the Fed's Division Consumer and Community Affairs, where 
has spent about years his legal career. According the Treasury, Chanin's 
responsibilities include building the rule-writing team and developing initial proposals. 
FOIL 110200 000043 

David Silberman 
The Treasury also named David Silberman, lawyer formerly with the AFL-CIO and Kessler Financial Services, head the new bureau's card markets division, the unit that will research and write rules for credit cards. Warren has said that among her top priorities regulating credit-card disclosures, which would affect issuers including JPMorgan Chase Co., Bank America Corp. and Citigroup Inc. Silberman previously managed the insurance business the Boston-based consulting firm Kessler Financial Services. Its clients include the Hartford Life Accident Insurance Co., the Union Labor Life Insurance Co., and the AFL-CIO. Before joining Kessler 1999, Silberman was co-founder ofUnion Privilege, the benefits arm ofthe AFL-CIO. also served the general counsel ofUnion Privilege for years, then its president and chief executive for five years. the general counsel ofUnion Privilege, Silberman negotiated the first agreements the early 1990s with credit card issuers including HSBC Holdings Plc create "affinity cards" for union members. Affinity cards offer financial benefits cardholders, such discounts certain stores, and funnel fraction each transaction the union, said Leslie Tolf, the current president ofUnion Privilege. Currently about 1.5 million union members have the cards. 
Holly Petraeus 
See below Elizabeth Warren's posting the White House blog about this appointment. 
The White House Blog 
Welcoming Holly Petraeus the Consumer Financial Protection Bureau Implementation Team Posted Elizabeth Warren January 06, 2011 05:30AM EST 
Today, nearly 300,000 American men and women are serving overseas, often harsh conditions and grave risk. For many ofthese brave men and women, the challenge everyday life experienced their families back home significant worry, loved ones struggle with car payments, credit card bills, and trying find the cash needed cover unexpected expenses. 
Regrettably, the evidence clear: servicemembers and their families are sometimes easy targets for unscrupulous lenders. Even families that stay with mainstream lenders can struggle the impact separation and frequent moving takes financial toll, leaving family mired debt and trying digest reams fine print. Today, have good news report. 
Holly Petraeus will take new role the Consumer Financial Protection Bureau 
Implementation Team, directing our effort establish Office Servicemember 
Affairs.  had been the consumer agency for only couple weeks when met Holly. After introduced ourselves, she got straight the point: despite strong efforts the 
Department ofDefense and others, too many military families find themselves 

FOIL 110200 000044 

financial trouble, scrambling hard deal with mounting debts falling into the arms predatory lender. 
Holly was then serving the Director the Better Business Bureau (BBB) Military Line, partnership between the BBB and the Department Defense Financial Readiness Campaign that provides consumer education and advocacy for servicemembers and their families. She knew the challenges facing military families. Her son, brother, father, grandfather, and great-grandfather all served our armed forces. Her husband, General David Petraeus, serving now Commander the International Security Assistance Force and U.S. Forces Afghanistan. 
Holly was doing her best help teaching financial education classes military personnel and other ways, but she thought that country needed more-and she thought the new consumer agency was the way get things done. She listed one idea after another, focusing better law enforcement, tighter rules, and stronger financial education. She wanted see action now. 
Wow, thought. This woman fired up. soon became clear that Holly would the perfect person guide the establishment the office. She the kind leader need. 
Holly understands-from both her personal experience military spouse and her work BBB-that men and women our armed forces encounter unique financial obstacles. Recently-enlisted servicemembers often experience their first steady paycheck and their first opportunity lured into easy credit offers. Far too many also get tangled debt traps. recent online survey commissioned the FINRA Foundation found that almost one four the enlisted personnel junior NCO respondents had used high-cost alternative borrowing method, such payday auto title loan, the previous five years. The same survey found that mainstream credit products can also pose problems: the previous year, percent the enlisted personnel and junior NCOs had made only the minimum payment credit card, and percent had made late payment. 
Financial problems can dangerous distraction for our troops. Undersecretary 
Defense for Personnel and Readiness Clifford Stanley wrote last year, servicemembers 
"and their families are under increasing stress. When have asked surveys about the 
causes, servicemembers responded that finances were second only behind work and 
career concerns and ahead deployments, health, life events, family relationships and 
war/hostilities." Financial problems can also lead troops lose their often essential 
security clearances. For example, the Department the Navy reported 2007 that 
financial management issues accounted for percent security clearance revocations 
and denials for Navy personnel. 

Those who serve the military should able focus their jobs and their families 
without having worry about getting trapped abusive financial practices. America's 
national security depends that basic premise. Undersecretary Stanley wrote, the 
FOIL 110200 000045 

"personal financial readiness our troops and families equates mission readiness." Secretary the Army John McHugh similarly has argued that "Soldiers who are distracted financial issues home are not fully focused fighting the enemy, thereby decreasing mission readiness."  her role the new agency, Holly will continue her work strengthen consumer financial protection for servicemembers. The Office Servicemember Affairs will work partnership with the Department Defense help ensure that: military families receive the financial education they need make the best financial decisions for them; complaints and questions from military families are monitored and responded to; and federal and state agencies coordinate their activities improve consumer protection measures for military families. 
This month, Holly and will visit Lackland Air Force base San Antonio, Texas, where all three brothers took basic training. will hear from servicemembers and financial counselors about the unique lending circumstances and challenges facing military communities. this and our later trips, will ask many questions, listen our troops, and apply what learn directly our efforts. 
The goal ofthe new agency provide basic consumer protection and voice for 
American families. Military families have unique challenges, and now they have 
unique advocate ensure that their special concerns get the attention they deserve. 
Elizabeth Warren Assistant the President and Special Advisor the Secretary ofthe Treasury for the Consumer Financial Protection Bureau 
FOIL 110200 000046 

Warren Recruits Dodd-Frank Enforcers From States December 02, 2010,2:44 EST Carter Dougherty 
Dec. (Bloomberg)--Elizabeth Warren, the Harvard University law professor deputized President Obama police consumer finance, recruiting state prosecutors help. She may even bankroll their work. 
"The state attorneys general are natural partners for the consumer agency," Warren, 61, said interview. "There are regulators Washington that used prevent state attorneys general 
from protecting consumers." 
The attorneys general say they are now invited the nation's capital and talk with Warren 
telephone almost weekly she sets the Bureau Consumer Financial Protection. Nov. 
30, Warren traveled Fort Lauderdale, Florida, plot strategy the prosecutors' winter 
Bernard Nash, iaw partner Dickstein Shapiro LLP Washington, said Warren's alliance 
with state prosecutors will strengthen both her hand and theirs. will also antagonize banks, 
who opposed the creation the consumer bureau. 
"There are going major consequences here," said Nash, who leads his firm's state attorneys general practice. "Instead one enforcement arm, there are going ofthem." 
The Dodd-Frank financial overhaul that became law July revamped the relationship between 
federal agencies and state enforcers, and Warren has seized that change. 
The law gives state attorneys general the authority enforce regulations written the new bureau court, and aJlows the agency take part the case. vote majority the states can force the bureau consider adopting new regulation. 
'Natural Partners' 
Dodd-Frank also curbed the ability national regulators, primarily the Office ofthe Comptroller the Currency, block state consumer protection actions. That's one reason large banks including JPMorgan Chase Co. opposed the bill. 
"We're not favor states having enforcement, because that means will really hard service you the customer," JPMorgan Chief Executive Officer Jamie Dimon said conference call last December. "Ifwe something like that, the customer will pay the price, not JPMorgan." Mierzwinski, director the consumer program PIRG, said banks opposed the creation the new agency because they preferred the status quo. 
"There are many regulations, like tax systems, that modem companies deal with profitably 
across state lines," said Mierzwinski, whose Washington-based group supports the consumer 
FOIL 110200 000047 

bureau. "The real reason industry does not want strong state laws because they prefer one 
weak federal law." 

Common Cause 
Enlisting state attorneys general part Warren's strategy ofmaking common cause with 
people who believe the agency's new mission and can support for the long term, she said. long-term way anchor the agency consumer protection --as opposed bank protection -is anchor the state attorneys general," said Prentiss Cox, former assistant attorney general Minnesota and now professor the University Minnesota law school. 
Roy Cooper, tbe attorney general North Carolina, said Warren bas. told them she wants states help formulate new policies around mortgages and credit cards, her two top priorities. Last month, Cooper formed group attorneys general from Washington, Indiana, Illinois and Iowa work with Warren those issues and others. 
'Portal Complaints' 
"We are the initial portal ofcomplaints from consumers, and can react more quickly than federal agency," said Cooper, Democrat who heads the National Association Attorneys  General. "But will interesting see how nimble this new bureau will be." 
The state AGs may help the bureau spot national trends more quickly, allowing faster 
enforcement, Cooper said. 

"By leveraging our resources, can make the whole greater than the parts," Warren said. financial issues, the OCC has long restrained state efforts regulate enforce standards nationally chartered banks, said Chris Kukla, senior counsel for government affairs the Center for Responsible Lending Durham, North Carolina. 
"The attorneys general see chance finally have seat the table Washington," Kukla 

'Preemption.' key goal ofstate attorneys general forging close relationship with Warren influence regulations "preemption," the legal doctrine that allows federal law trump state law when they conflict, Cooper said. 
"One ofthe reasons are getting early have say what these regulations say 
regarding preemption," Cooper said. 

The American Bankers Association, which represents major banks, has placed high priority maintaining federal preemption for state actions, and downplays the role state attorneys general. 
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"Ultimately, the court's decision preemption, before after Dodd-Frank," said Kenneth Clayton, senior vice~ president and general counsel for card policy the ABA. 
During this week's Florida meeting, Warren said state attorneys general asked whether she could make federal money available fund state enforcement efforts. She was noncommittal: "It's one the ideas the table, but it's early the game," Warren said. 
The idea has precedent. For instance, the U.S. Department ofHealth and Human Services gives states grants finance prosecutions ofMedicaid fraud, said Greg Zoeller, the attorney general Indiana 
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Create Sound Economic Foundation Grow Jobs, Protect Consumers, Rein Wall Street and Big Bonuses, End 
Bailouts and Too Big Fail, Prevent Another-Financial Crisis 

Years without accountability for Wall Street and big banks brought the worst financial crisis since the Great Depression, the loss million jobs, failed businesses, drop housing prices, and wiped out personal savings. 
The failures that led this crisis require bold action. must restore responsibility and accountability our financial system give Americans confidence that there system place that works for and protects them. must create sound foundation grow the economy and create jobs. 
Consumer Protections with Authority and Independence: Creates new independent watchdog, housed the Federal Reserve, with the authority ensure American consumers get the clear, accurate information they need shop for mortgages, credit cards, and other financial products, and protect them from hidden fees, abusive terms, and deceptive practices. 
Ends Too Big Fail Bailouts: Ends the possibility that taxpayers will asked write check bail out financial firms that threaten the economy by: creating safe way liquidate failed financial firms; imposing tough new capital and leverage requirements that make undesirable get too big; updating the Fed's authority allow system-wide support but longer prop individual firms; and establishing rigorous standards and supervision protect the economy and American consumers, investors and businesses. 
Advance Warning System: Creates council identify and address systemic risks posed large, complex companies, 
products, and activities before they threaten the stability the economy. 
Transparency Accountability for Exotic Instruments: Eliminates loopholes that allow risky and abusive practices unnoticed and unregulated--including loopholes for over-the-counter deri~atives, asset-backed securities, hedge funds, mortgage brokers and payday lenders. 
Executive Compensation and Corporate Governance: Provides shareholders with say pay and corporate affairs 
with non:binding vote executive compensation and golden parachutes. 
Protects Investors: Provides tough new rules for transparency and accountability for credit rating agencies protect 
investors and businesses. 
Enforces Regulations the Books: Strengthens oversight and empowers regulators aggressively pursue financial 
fraud, conflicts interest and manipulation the system that benefits special interests the expense American 
families and businesses. 
FOIL 110200 000050 

The Consumer Financial Protection Bureau 
Independent Head: Led independent director appointed the President and confirmed the Senate. 
**Elizabeth Warren Progressive Champion The Middle Class -Has Been Appointed Special White House Position Oversee The Establishment OfThis Board. She Was Supported Progressives And Opposed Wall Street Lobbyists And The GOP 
Independent Budget: Dedicated budget paid the Federal Reserve system. 
Independent Rule Writing: Able autonomously write rules for consumer protections governing all financial institutions -banks and non-banks -offering consumer financial services products. 
Examination and Enforcement: Authority examine and enforce regulations for banks and credit unions 
with assets over $10 billion and all mortgage-related businesses (lenders, servicers, mortgage brokers, and 
foreclosure scam operators), payday lenders, and student lenders well other non-bank financial 
companies that are large, such debt collectors and consumer r~porting agencies. Banks and Credit Unions 
with assets $10 billion less will examined for consumer complaints the appropriate regulator. 
Consumer Protections: Consolidates and strengthens consumer protection responsibilities currently handled host different agencies, which also have the responsibilities support the banks and lenders. 
Able Act Fast: With this Bureau the lookout for bad deals and schemes, consumers won't have wait 
for Congress pass la':" protected from bad business prattices. 
Educates: Creates new Office Financial Literacy. 
Consumer Hotline: Creates national consumer complaint hotline consumers will have, for the first time, single toll-free number report problems with financial products and services. 
Accountability: Makes one office accountable for consumer protections. With many agencies sharing 
responsibility, it's hard know who responsible for what, and easy for emerging problems that haven't 
historically fallen under anyone's purview, fall through the cracks. 
Works with Bank Regulators: Coordinates with other regulators when examining banks prevent undue 
regulatory burden. Consults with regulators before proposal issued and regulators could appeal 
regulations they believe would put the safety and soundness the banking system the stability the 
financial system risk. 
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Fiduciary Duty: Gives SEC the authority impose fiduciary duty brokers who give investment advice --the advice must the best interest their customers. 
Encouraging Whistleblowers: Creates program within the SEC encourage people report securities violations, creating rewards 30% funds recovered for information provided. 
SEC Management Reform: Mandates comprehensive outside consultant study the SEC, annual 
assessment the SEC's internal supervisory controls and GAO review SEC management. 
New Advocates for Investors: Creates the Investment Advisory Committee, committee investors advise the SEC its regulatory priorities and practices; the Office Investor Advocate the SEC, identify areas where investors have significant problems dealing with the SEC and provide them assistance; and ombudsman handle investor complaints. 
SEC Funding: Provides more resources the chronically underfunded agency carry out its new duties. 
Federal Insurance Office: Creates the first ever office the Federal government focused insurance. The Office, established the Treasury, will gather information about the insurance industry, including access affordable insurance products minorities, low-and moderate-income persons and underserved communities. The Office will also monitor the insurance industry for systemic risk purposes. 
International Presence: The Office will serve uniform, national voice insurance matters for the United 
States the international stage. 
Streamlines regulation surplus lines insurance and reinsurance through state-based reforms. 
The Financial Stability Oversight Council 
Tough Get Too Big: Makes recommendations the Federal Reserve for increasingly strict rules for capital, leverage, liquidity, risk management and other requirements companies grow size and complexity, with significant requirements companies that pose risks the financial system. 
Regulates Nonbank Financial Companies: Authorized require, with 2/3 vote and vote the chair, that nonbank financial company regulated the Federal Reserve the council believe there would negative effects the financial system the company failed its activities would pose risk the financial stability the US. 
Break Large, Complex Companies: Able approve, with 2/3 vote and vote the chair, Federal 
Reserve decision require large, complex company, divest some its holdings poses grave threat the financial stability the United States -but only last resort. 
Make Risks Transparent: Through the Office Financial Research and member agencies the council will collect and analyze data identify and monitor emerging risks the economy and make this information 
public periodic reports and testimony Congress every year.    
FOIL 110200  000052 Evasion: Large bank holding companies that have received TARP funds will not able avoid Federal 
Reserve supervision simply dropping their banks. (the "Hotel California" provision) 

Capital Standards: Establishes floor for capital that cannot lower than the standards effect today and 
authorizes the Council impose 15-lleverage requirement company necessary mitigate grave threat the financial system. 
Limiting Large, Complex Financial Companies and Preventing Future Bailouts Taxpayer Funded Bailouts: Clearly states taxpayers will not the hook save failing financial 
company cover the cost its liquidation. 
Discourage Excessive Growth Complexity: 
Volcker Rule: Requires regulators implement regulations for banks, their affiliates and holding companies, prohibit proprietary trading, investment and sponsorship hedge funds and private equity funds, and limit relationships with hedge funds and private equity funds. Nonbank financial institutions supervised the Fed also have restrictions proprietary trading and hedge fund and private equity investments. The Council ~ill study and make recommendations implementation aid regulators. 
Extends Regulation: The Council will have the ability require nonbank financial companies that pose risk the financial stability the United States submit supervision the Federal Reserve. 
Liquidation: Creates orderly liquidation mechanism for FDIC unwind failing systemically significant 
financial companies. Shareholders and unsecured creditors bear losses and management and culpable 
directors will removed. 

Costs Financi~l Firms, Not Taxpayers: Taxpayers will bear cost for liquidating large, interconnected financial companies. FDIC can borrow only the amount funds liquidate company that expects repaid from the assets the company being liquidated. The government will first line for repayment. Funds not repaid from the sale the company's assets will repaid first through the claw back any payments creditors that exceeded liquidation value and then assessments large financial companies, with the riskiest paying more based considerations included risk matrix 
Bankruptcy: Most large financial companies that fail are expected resolved through the bankruptcy 
Limits Debt Guarantees: prevent bank runs, the FDIC can guarantee debt solvent insured banks, but only after meeting serious requirements: 2/3 majority the Board and the FDIC board must determine there threat financial stability; the Treasury Secretary approves terms and conditions and sets cap overall guarantee amounts; the President activates expedited process for Congressional approval. 
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Bringing Transparency and Accountability the Derivatives Market 
Central Clearing and Exchange Trading: Requires central clearing and exchange trading for derivatives that can cleared and provides role for both regulators and clearing houses determine which contracts should cleared. 
Closes Regulatory Gaps: Provides the SEC and CFTC with authority regulate over-the-counter derivatives that irresponsible practices and excessive risk-taking can longer escape regulatory oversight. 
Market Transparency: Requires data collection and publication through clearing houses swap repositories improve market transparency and provide regulators important tools for monitoring and responding 
Financial safeguards: Adds safeguards system ensuring dealers and major swap participants have 
adequate financial resources meet responsibilities. Provides regulators the authority impose capital and 
margin requirements swap dealers and major swap participants, not end users. 
Higher standard conduct: Establishes code conduct for all registered swap dealers and major swap 
participants when advising swap entity. When acting counterparties pension fund, endowment fund, state local government, dealers are have reasonable basis believe that the fund governmental 
entity has independent representative advising them. 
NEW OFFICES MINORITY AND WOMEN INCLUSION federal banking and securities regulatory agencies, the bill establishes Office Minority and Women Inclusion that will, among other things, address employment and contracting diversity matters. The offices will coordinate technical assistance minority-owned and women-owned businesses and seek diversity the workforce the regulators. 
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Require Lenders Ensure Borrower's Ability Repay: Establishes simple federal standard for all home loans: institutions must ensure that borrowers can repay the loans they are sold. 
Prohibit Unfair Lending Practices: Prohibits the financial incentives for subprime loans that encourage lenders steer borrowers into more costly loans, including the bonuses known "yield spread premiums" that lenders pay brokers inflate the cost loans. Prohibits pre-payment penalties that trapped many borrowers into unaffordable loans. 
Establishes Penalties for Irresponsible Lending: Lenders and mortgage brokers who don't comply with new standards will held accountable consumers for high three-years interest payments and damages plus attorney's fees (if any). Protects borrowers against foreclosure for violations these standards. 
Expands Consumer Protections for High-Cost Mortgages: Expands the protections available under federal rules high-cost loans -lowering the interest rate and the points and fee triggers that define high cost loans. 
Requires Additional Disclosures for Consumers Mortgages: Lenders must disclose the maximum 
consumer could pay variable rate mortgage, with warning that payments will vary based interest 
Housing Counseling: Establishes Office Housing Counseling within HUD boost homeownership and rental housing counseling. 
Neighborhood Stabilization Program: Provides billion States and localities combat the ugly impact neighborhood the foreclosure crisis--such falling property values and increased crime-by rehabilitating, redeveloping, and reusing abandoned and foreclosed properties. 
Emergency Mortgage Relief: Building successful Pennsylvania program, provides billion for bridge 
loans qualified unemployed homeowners with reasonable prospects for reemployment help cover 
mortgage payments until they are reemployed. 
Foreclosure Legal Assistance. Authorizes HUD administered program for making grants provide foreclosure legal assistance low-and moderate-income homeowners and tenants related home ownership preservation, home foreclosure prevention, and tenancy associated with home foreclosure. 
Monitor Personal Financial Rating: Allows consumers free access their credit score their score negatively 
affects them financial transaction hiring decision. Gives cons~mers access credit score disclosures part adverse action and risk-based pricing notice. 
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Raising Standards and Regulating Hedge Funds 
Fills Regulatory Gaps: Ends the "shadow" .financial system requiring hedge funds and private equity advisors register with the SEC investment advisers and provide information about their trades and portfolios necessary assess systemic risk. This data will shared with the systemic risk regulator and the SEC will report Congress annually how uses this data protect investors and market integrity. 
Greater State Supervision hedge funds with less that $100 million assets: Raises the assets threshold for federal regulation investment advisers from $30 million $100 million, move expected significantly  increase the number advisors under state supervision. States have proven strong regulators this area and subjecting more entities state supervision will allow the SEC focus its resources newly registered hedge funds. 
New Requirements and Oversight Credit Rating Agencies 
New Office, New Focus SEC: Creates Office Credit Ratings the SEC with expertise and its own 
compliance staff and the authority fine agencies. The SEC required examine Nationally Recognized 
Statistical Ratings Organizations least once year and make key findings public. 
Disclosure: Requires Nationally Recognized Statistical Ratings Organizations disclose their methodologies, 
their use third parties for due diligence efforts, and their ratings track record. 
Independent Information: Requires agencies consider information their ratings that comes their 
attention from source other than. the organizations being rated they find credible. 
Conflicts Interest: Prohibits compliance officers from working ratings, methodologies, sales; installs new requirement for NRSROs condl;lct one-year look-back review when NRSRO employee goes work for obligor underwriter security money market instrument subject rating that NRSRO; and mandates that report the SEC when certain employees the NRSRO work for entity that the NRSRO has rated the previous twelve months. 
Liability: Investors can bring private rights action against ratings agencies for knowing reckless failure conduct reasonable investigation the facts obtain analysis from independent source. NR$ROs 
will now subject "expert liability" with the nullification Rule 436(g) which provides exemption for 
credit ratings provided NRSROs from being considered part the registration statement. 
Right Deregister: Gives the SEC the authority deregister agency for providing bad ratings over time. 
Education: Requires ratings analysts pass qualifying exams and have continuing education. 
Eliminates Many Statutory and Regulatory Requirements Use NRSRO Ratings: Reduces over-reliance ratings and encourages investors conduct their own analysis. 
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Independent Boards: Requires least half the members NRSRO boards independent, with financial stake credit ratings. 
Ends Shopping for Ratings: The SEC shall create new mechanism prevent issuers asset backedsecurities from picking the agency they think will give the highest rating, after conducting study and after submission the report Congress. 
EXECUI'IVE COMPENSATION AND CORPORATE GOVERNANCE Gives Shareholders Say Pay and Creating Greater Accountability 
Vote Executive Pay and Golden Parachutes: Gives shareholders say pay with the right nonbinding vote executive pay and golden parachutes. This gives shareholders powerful opportunity hold accountable executives the companies they own, and chance disapprove where they see the kind misguided incentive schemes that threatened individual companies and tum the broader economy. 
Nominating Directors: Gives the SEC authority grant shareholders proxy access nominate directors. 
These requirements can help shift management's focus from short-term profits long-term growth and 
Independent Compensation Committees: Standards for listing exchange will require that compensation committees include only independent directors and have authority hire compensation consultants order strengthen their independence from the executives they are rewarding punishing. Compensation for Lies: Requires that public companies set policies take back executive compensation was based inaccurate financial statements that don't comply with accounting standards. 
SEC Review: Directs the SEC clarify disclosures relating compensation, including requiring companies provide charts that compare their executive compensation with stock performance over five-year period. 
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Volcker Rule Implementsa strengthened version the Volcker rule not allowing study the issue undermine the prohibition proprietary trading and investing banking entity's own money hedge funds, with minimis exception for funds where the investors require some "skin the game" the investment advisor--up tier capital the aggregate 
Stronger lending limits: Adds credit exposure from derivative transactions banks' lending limits. 
Interest business checking: Repeals the prohibition banks paying interest demand deposits. 
Charter Conversions: Removes regulatory arbitrage opportunity prohibiting bank from converting its 
charter (unless both the old regulator and new regulator not object) order get out from under 
enforcement action. 
Establishes New Offices Minority and Women Inclusion the federal financial agencies 
Protects Small Businesses from Unreasonable Fees: Requires Federal Reserve issue rules ensure that fees charged merchants credit card companies debit card transactions are reasonable and proportional the cost processing those transactions. 
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Reducing Risks Posed Securities 
Skin the Game: Requires companies that sell products like mortgage-backed securities retain least the credit risk, unless the underlying loans meet standards that reduce riskiness. That way the investment doesn't pan out, the company that packaged 'and sold the investment would lose out right along with the people they sold to. 
Better Disclosure: Requires issuers disclose more information about the underlying assets and analyze the quality the underlying assets. 
Be.tter Oversight Municipal Securities Industry 
Registers Municipal Advisors: Requires registration municipal advisors and subjects them rules written the MSRB and enforced the SEC. 
Puts Investors First the MSRB Board: Ensures that all times, the MSRB must have majority 
independent members, ensure that the public interest better protected the regulation municipal 
Fiduciary Duty: Imposes fiduciary duty advisors ensure that they adhere the highest standard 
care when advising municipal issuers. 
Congo Conflict Minerals: 
Manufacturers Disclosure: Requires those who file with the SEC and use minerals originating the 
Democratic Republic Congo manufacturing disclose measures taken exercise due diligence the 
source and chain custody the materials and the products manufactured. 
Illicit Minerals Trade Strategy: Requires the State Department submit strategy address the illicit 
minerals trade the region and map address links between conflict minerals and armed groups and 
establish baseline against which judge effectiveness. 
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December 22,2010 Wednesday 
HEADLINE: New consumer agency frightfully necessary-and late;  Foreclosure crisis 
BYLINE: Elizabeth Warren; elizabethwarren@do. treas. gov one has missed the headlines: Haphazard and possibly illegal practices mortgageservicing companies have called into question home foreclosures across the nation. 
The latest disclosures are deeply troubling, but they should not come big surprise. 
For years, both individual homeowners and consumer advocates sounded alarms that 
foreclosure processes were riddled with problems. 
While federal ar:td state investigators are still examining exactly what has gone wrong and why, two things are clear. 
First, several financial services companies have already admitted that they used "robo
signers," false declarations, and other workarounds cut comers, creating