There are lots of other points to criticize with this counterproposal, but it's hardly worthwhile doing so--it's such an obvious in-your-face document that it's really not worthwhile engaging with serious. This isn't the basis for a good faith discussion of mortgage servicing reform. It's simply another part of the banks' strategy to run the clock and thereby avoid doing principal reductions--that's what will cost them the big bucks, not a $20B fine.
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Banks to AGs on Servicing Fraud: Drop Dead - Credit Slips Make big money in penny stocks today