Consumer Compliance Outlook: Fourth Quarter 2010

Setting the Record Straight


An article in the Third Quarter 2009 issue of Outlook, “An Overview of the Home Affordable Modification Program,” stated that “HAMP requires that all banks and lending institutions accepting funding from the Troubled Asset Relief Program (TARP), after the announcement of HAMP in March 2009, must implement loan modifications for eligible loans under HAMP's guidelines.”

For clarification, HAMP was announced in February 2009, after the majority of the support for banks and lending institutions had already been made under the Capital Purchase Program of the Troubled Asset Relief Program's (TARP). In February 2009, the Treasury Department proposed another TARP program: the Capital Assistance Program (CAP). It was originally expected that financial institutions participating in CAP would be required to participate in HAMP and modify eligible loans, but the CAP program was never used. However, because additional TARP support was provided to AIG, Citibank, and GMAC after the announcement of HAMP, these three institutions were required to participate in HAMP.


An article in the Third Quarter 2010 issue of Outlook, “Mortgage Disclosure Improvement Act (MDIA): Examples and Explanations,” acknowledged Jeff Paul and Gary Louis of the Federal Reserve Bank of Atlanta for their work in developing a MDIA training tool on which the author of the MDIA article relied. We should have acknowledged Jeff Paul and Bill Beall of the Federal Reserve Bank of Atlanta.