The settlements have two components. The first was a fine payable to the government. The second was labeled “consumer relief.” Since consumer relief was added to the fine, I naively assumed it represented payments by banks to consumers or additional relief from obligations for distressed borrowers. In fact, rather than these sums cited by the banks and DOJ, it seems that zero is a better estimate of the cost to banks of providing “consumer relief.”
.. I’d imagine other major banks with mortgage portfolios got consumer relief credit for carrying through on principal reductions that they would have found necessary wholly apart from the DOJ’s intervention.
.. the wrongdoing in question involves lack of financial integrity, clarity and transparency in reporting the settlement should have been a preeminent value. I wish this had been the case.