Comment from Manuel Layson

Document ID: TREAS-DO-2009-0001-0005
Document Type: Public Submission
Agency: Department Of The Treasury
Received Date: March 13 2009, at 04:37 PM Eastern Daylight Time
Date Posted: March 18 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: January 21 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: March 23 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 809102f5
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This is comment on Rule

TARP Conflicts of Interest

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Greetings: I've also shared my idea with Maria Bartiromo and Dylan Ratigan at CNBC Below is my idea on how to deal with the “TOXIC ASSETS”, get the Banks in much better Positions, help out the Borrowing public and stop the slide of Home prices. Ultimately, this will help bring back the much needed confidence levels in the marketplace from Banks to Consumers to Investors and lead the US out of this recession and on to a more robust growth in economic activity. Please share with the TREASURY DEPARTMENT… Extraordinary events need make sense extraordinary measures like the government plan to buy "toxic assets" from Banks and the like. This Financial and Economic crisis started with the Mortgage markets and the first order in the solutions train will have to come from the Mortgage side as well. My idea is similar in nature but different and very probably a lot less costly than the original All out "toxic Assets" purchase. My solution -, THE GOVERNMENT INSTEAD USES the "TARP" MONEY TO BRING ALL DELINQUENT MORTGAGES and IN FORECLOSURE LOANS to CURRENT STATUS instead of outright Purchase of "toxic assets".. These "toxic assets" crisis came at us almost at a Tsunami pace, affecting all markets in the US and worldwide, creating massive Business closings and Unemployment, wreaking havoc and almost destroying the Financial markets, leaving everybody at a loss for make sense solutions. The rationale behind my idea is to bring the Mortgage market back to a "temporary whole" mode, giving all and sundry the time needed to assimilate what to do but from a position of more relative strength than the alternative of trying to find solutions from a weaker Position of adverse market conditions, i.e., mortgage delinquencies and Foreclosures clogging up the system. My idea will buy All Parties & Counterparties involved in a Mortgage loan, more time to modify Loans and find possible solutions going forward. Banks now will have records of which of the loans may be at risk and anticipate helping either by providing upfront Loan Modifications, Refinancing or keeping track of a Borrower who just might go back into Delinquent status but at least, these Borrower now can be watched more closely and surprises will be reduced dramatically. Banks who can anticipate bad debts can more likely allow for the possible bad debts or resort to other ready financial solutions than the alternative of not knowing what might happen to any of the loans in their Portfolio. Provide Banks the needed breathing room to come up with better solutions and procedures on how to deal with Borrowers who may not be able pay at a future date. Here are some of the other reasons why this makes most sense: 1) It's a quicker clean up of the Banks' Balance sheets than the alternative of buying all "toxic assets". No need to take out these Assets from the Banks' Balance sheets and get transferred to the Federal Reserve's or Treasury's. 2) It'll cost much less vs. buying out all the "Toxic Assets" from the Banks 3) It'll provide the Investors and Counterparties the perceived and psychological feeling of relief and confidence that indeed all is not lost 4) Build back confidence in the Borrowers' perspective and removing the proverbial Damocles foreclosure sword over their heads. This will now allow Borrowers' the space to consider all the options like Loan Mods, Refinances or Sale. 5) Stopping foreclosures and instilling new confidence in the market place will stop on it's heels the Price slide in most neighborhoods 6) Borrowers who are also Consumers will be in a better Position to spend again once Loans are Modified and Refinanced to lower payments which will allow a lot of them to have extra monies to spend. 7) The ability of Borrowers who lost their jobs to be able to get new jobs ( and help out pay or co pay for the new & lower mortgage payments) is tied in to the next paragraph below but at least, if the mortgage payments are reduced dramatically, these Borrowers will be in a far better Position mentally, emotionally and psychologically to have a clearer path to income production since they have now been given a new lease on their "mortgage life". My idea does not cover how to rebuild more Consumer buying strength which is another discussion but there's no question, Tax incentives ( like a 12 month Federal Tax & FICA Tax holiday for Americans making $250,000 or less, Tax abatements for Small to Medium sized business is very much needed). This will truly guarantee, I say guarantee a road back to Prosperity and success at a faster pace than any other options. The US and the World Markets will open up again with newly found confidence and bounce. 8) Capital, Secondary Markets and Securitization will really open up again, and Banks will be back to real Lending !!! Good luck and Best regards. Manny Layson Arcadia, CA

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