Monday, December 19, 2011

Whistleblowers and Bounty Hunters

Americans have often had an ambivalent view of whistleblowers. When we feel that the whistleblowing serves some righteous cause, the whistleblower's actions are worthy of a medal; but when the whistleblower's cause is considered to mask self-aggrandizement, then we often contend that some jail time might be a more suitable reward, whatever the cause. Still, one person's justification for such actions may be castigated by another person as an act of perfidy.
In a rather morally twisted way, recent law has combined the act of whistleblowing with the remuneration of bounty hunting, the latter being yet another concerning happenstance of American ambivalence.
Let's call this new ethical imperative the "Dope for Dough" compact.
In this article:
  • A Snitch In Time Saves Crime
  • If You See Something, Say Something
  • Welcome to the Office of the Whistleblower
  • Bounty Hunter
  • Tips, Complaints and Referrals
  • Anonymity More-or-Less
  • Preventing Retaliation More-or-Less
  • First Do No Harm
A Snitch In Time Saves Crime
Being a snitch is not exactly the kind of job position somebody must apply for, even in these days of high unemployment. It's not a career opportunity. A snitch doesn't want to be a snitch, hates snitching, and would rather not have to snitch at all. Being a snitch does not bestow a badge of honor! There are no annual conferences for snitchers. A snitch is not born a snitch; something has to happen to make a snitch snitch.
Often, the stakes for snitching are very high. Being a snitch means subjecting oneself to potential ostracism, being fired, not being hired, jail time, and even community time (yes, courts have held that "community service" may be a proxy for prison time). Snitchers know that whenever people pass them by, there will be fingers pointed at them and breathless whispers behind their backs about the supposed damage done by, or the great good achieved through, their snitching. Snitching has a wake all its own and the snitcher can never get out of it, whatsoever the tattletale tattled.
The list of snitch martyrdom is long and, depending on the results and society's comfort zone, contains patriots and traitors, saints and the damned, reformists and reactionaries, the sempiternal loyalists and the double-crossing turncoat. Even if the weaseling betrayer squeals the unvarnished truth, the very act of making manifest the heretofore hidden may bring with it many dangers impinging on the tipster's physical, let alone social, survival.
If You See Something, Say Something!
We constantly hear, "if you see something, say something." Implied in that statement is the moral judgment that we do know when something is wrong and when something is right, and, knowing that difference, when we know something wrong is happening, we should share such knowledge with somebody else. The phrase does not say, "if you see something, say something, and if you do we'll pay you for the information." It does not say, "if you see something, say something, but if you do you will put yourself and perhaps all of your loved ones at personal risk." And it does not say, "if you see something, say something, but if you do you may go to jail or you may not." Finally, it does not say, "if you see something, say something, though if you do we will ignore what you have to say and nobody will ever know something wrong happened."
The instinct for self-preservation is strong. Especially strong in a stoolie! This is obviously why a recent study shows that 78 percent of Americans said they would report something wrong only if they could be anonymous informants, be assured of evading retaliation, and nevertheless get a reward for information, whether such information was pilfered, pinched, purloined, or professed.
Pity the poor snitch! So misunderstood, often the butt of ridicule, and only occasionally appreciated for the grumbling sacrifice of life and liberty. But now a new era of gratitude, tribute, and prestige has begun for the deep throated canary that yearns to sing.
Welcome to the Office of the Whistleblower
Henceforth, we will need to replace the term snitch with a new title, the "whistleblower," and appoint an overseer to protect the whistleblower's rights, prevent retaliation, and offer remuneration for blowing the whistle and assisting with any investigation or judicial or administrative action that follows from the information thereby obtained.
Section 924(d) of the Dodd-Frank Act (Dodd-Frank) directs the Security and Exchange Commission (Commission) to establish a separate office within the Commission to administer and to enforce the Section 21F provisions of the Securities Exchange Act of 1934 (Exchange Act). On February 18, 2011, the Commission appointed an overseer or Chief, Sean X. McKessy, to head the newly-created Office of the Whistleblower in the Division of Enforcement (Whistleblower's Office). Chief McKessy is looking for a Deputy Chief, and there are several attorneys among the staff.
The ostensible purpose of the Whistleblower's Office is to provide assistance to a whistleblower who knows of possible securities law violations, such as identifying possible fraud and other violations, much earlier than might otherwise have been possible. The result, presumably, will be to minimize the harm to investors, preserve confidence in capital markets, and hold accountable those responsible for unlawful conduct.
Bounty Hunter
For remunerating the whistleblower, the Commission is authorized by Congress to provide monetary awards to eligible individuals who come forward with "high-quality original information" that leads to a Commission enforcement action in which over $1,000,000 in sanctions is ordered. The range for awards is between 10% and 30% of the monetary sanctions collected (which I will term the Bounty Fee).
This Bounty Fee of 10% to 30% is particularly robust, compared to the usual 10% (or less) of bail collected these days by bounty hunters. Of course, the whistleblower's Bounty Fee is not quite the same as the fee paid to a bounty hunter for capturing a fugitive outlaw. Bounty hunters are usually employed by bail bondsmen. But there is, shall we say, a resemblance.

Friday, December 16, 2011

OCC Issues Foreclosure Guidance - Part II

In yesterday's newsletter, Part I of this two-part series, I outlined the role of the bank as owner and servicer of foreclosed property, as described in the recent guidance issued by the Office of the Comptroller of the Currency (OCC) with respect to a bank's obligations and risks related to foreclosed property. (See OCC 2011-49)
A bank's obligations with respect to foreclosed residential properties may differ depending upon the bank's role in the foreclosure. For instance, a bank may be (1) an owner of the foreclosed property, or (2) a servicer and/or property manager, or (3) a securitization trustee.
Additionally, there are specific obligations when lenders release a lien securing a defaulted loan rather than foreclose on a residential property.
In today's newsletter, Part II or this two-part series, I outline the role of the bank as trustee of a securitization trust, and also releasing a lien rather than foreclosing.
For detailed information and guidance, please consult with us or a regulatory compliance professional.
In this Newsletter
Safety and Soundness
Bank as Trustee of Securitization Trust
Releasing a Lien Rather Than Foreclosing
Library

Safety and Soundness
As a matter of safety and soundness banking practices, banks should have robust policies and procedures in place to address risks associated with foreclosed (or soon to be foreclosed) properties.
Acquiring title to properties through foreclosure - either for the bank or as servicer for another mortgagee - results in new or expanded risks, including operating risk (which may include market valuation issues), compliance risk, and reputation risk.
Banks should be sure they have identified all the risks, and have policies and procedures for monitoring and controlling these risks. In each risk management consideration, it is critical to establish and implement policies and procedures, and bank management and the Board of Directors should consider, at a minimum, the role of the bank in foreclosure procedures and obligations.
Bank as Trustee of Securitization Trust
The securitization trustee is primarily responsible for holding a lien on the trust assets for the benefit of the investors who purchase securities issued pursuant to the securitization and administering the trust in conformance with requisite agreements.
The trustee's duties and responsibilities are established by a PSA, trust agreement, or indenture. These agreements direct a securitization trustee to perform various complex administrative functions. Such functions usually include ensuring the timely receipt of payments from the servicer, calculating payments, remitting payments to the investors, circulating information to investors, monitoring compliance, and determining if an event of default is triggered.
As permitted by the PSA, the trustee should work with the servicer to ensure the performance of its responsibilities. The securitization agreements may require a trustee to appoint a successor servicer or to take over servicing in the event the original servicer fails to perform its duties or defaults. These agreements generally do not grant the trustee any powers or duties with respect to the foreclosure or with the maintenance, sale, or disposition of foreclosed properties. Instead, these responsibilities typically reside with the servicer.
Nevertheless, to the extent a servicer undertakes foreclosure actions in the trustee's name as the secured party, a bank trustee should be aware of potential reputation and litigation risks. (See my comments in Part I, relating to reputation risk.)
Additionally, if the securitization agreements require a bank trustee to act as a replacement servicer until a successor servicer is appointed, the bank trustee would also be exposed to credit risk.
Releasing a Lien Rather Than Foreclosing
At times, lenders may release a lien securing a defaulted loan rather than foreclose on the residential property.
This decision is often based on financial considerations when the bank or servicer and/or investor determines that the costs to foreclose, rehabilitate, and sell a property exceed its current fair-market value. When this decision is made after a bank or servicer has initiated foreclosure, the borrower may have already abandoned the property or discontinued the care and maintenance of the property, increasing the chance of a blighted property in the community.
Because the decision to release a lien is typically a financial decision, banks and servicers should ensure that their valuation of the property provides the best information practicable, while complying with investor requirements, before initiating foreclosure and subsequently deciding to release the lien. While the financial risk must be considered, banks and servicers should also consider the potential for reputation and litigation risk arising from their position as a prior mortgagee or servicer of a now-abandoned property.
If the decision is made to forego foreclosure and release the lien, the bank or servicer should notify, or attempt to notify, the borrower of the decision. Borrowers should be notified that (1) the mortgage holder is not pursuing foreclosure and has released the mortgage lien, (2) the borrower may continue to occupy the property, and (3) the borrower is obligated to maintain the property consistent with all local codes and ordinances and to pay property taxes and the debt owed. The bank or servicer should also make appropriate notifications to the local jurisdiction when it makes the decision to release a lien in lieu of foreclosure.
Library
Law Library Image
Office of the Comptroller of the Currency (OCC)
Foreclosed Properties
Guidance on Potential Issues
With Foreclosed Residential Propertie
s
OCC 2011-49
December 14, 2011
* Jonathan Foxx is the President and Managing Director of Lenders Compliance Group

Thursday, December 15, 2011

OCC Issues Foreclosure Guidance - Part I

The Office of the Comptroller of the Currency (OCC) is providing guidance to banks on obligations and risks related to foreclosed property. Issued on December 14, 2011, this guidance highlights legal, safety and soundness, and community impact considerations. It primarily focuses on residential foreclosed properties. (See OCC 2011-49)
A bank's obligations with respect to foreclosed residential properties may differ depending upon the bank's role in the foreclosure. For instance, a bank may be (1) an owner of the foreclosed property, or (2) a servicer and/or property manager, or (3) a securitization trustee.
Additionally, there are specific obligations when lenders release a lien securing a defaulted loan rather than foreclose on a residential property.
Furthermore, understanding the requirements imposed by Fannie Mae and Freddie Mac (GSEs) or the U.S. Department of Housing and Urban Development (HUD) on servicers is particularly important.
I will analyze the OCC's guidance as it relates to the aforementioned three roles of the bank in foreclosing on residential properties.
This is a two-part newsletter. I will offer a brief overview of the OCC 2011-49 bulletin pertaining to guidance on potential issues with foreclosed residential properties. Today, in this first part, I will outline the role of the bank as owner and servicer of foreclosed property. Tomorrow, in the second part, I will outline the role of the bank as trustee of a securitization trust, and also releasing a lien rather than foreclosing.
For detailed information and guidance, please consult with us or a regulatory compliance professional.

In this Newsletter
Safety and Soundness
Bank as Owner of Foreclosed Property
Bank as Servicer of Foreclosed Property
Library

Safety and Soundness
As a matter of safety and soundness banking practices, banks should have robust policies and procedures in place to address risks associated with foreclosed (or soon to be foreclosed) properties.
Acquiring title to properties through foreclosure - either for the bank or as servicer for another mortgagee - results in new or expanded risks, including operating risk (which may include market valuation issues), compliance risk, and reputation risk.
Banks should be sure they have identified all the risks, and have policies and procedures for monitoring and controlling these risks. In each risk management consideration, it is critical to establish and implement policies and procedures, and bank management and the Board of Directors should consider, at a minimum, the role of the bank in foreclosure procedures and obligations.
Bank as Owner of Foreclosed Property
Obligations and Actions
  • In acquiring title to foreclosed properties, banks assume the primary responsibilities of an owner, including providing maintenance and security, paying taxes and insurance, and serving as landlord for rental properties.
    • Banks should communicate with localities, including homeowner associations, about specific requirements with respect to foreclosed residential properties (i.e., localities may have requirements about certain aspects of upkeep, such as lawn mowing, property maintenance, and security, et cetera).
    • In the absence of these actions, banks should be aware of potential nuisance actions or the exercise of local receivership powers to seize properties.
  • For FHA-insured mortgages, the bank must ensure compliance with property and preservation guidance issued by HUD to preserve the insurance claim and obtain reimbursements for allowable expenses.
  • Following foreclosure, the bank must record its ownership interest in local land records.
  • Banks must comply with the other real estate owned (OREO) appraisal and accounting requirements.
  • Banks should maintain appropriate insurance on the property.
  • Some localities may require registration of foreclosed properties, properties in foreclosure, or vacant properties. Banks should be aware of and comply with such requirements.
  • The Protecting Tenants at Foreclosure Act of 2009 (PTFA) provides tenants with protections from eviction as a result of foreclosure on the properties they are renting.
    • When a bank takes title to a house after foreclosure, it must honor any existing rental agreement with a bona fide tenant and must provide 90 days' notice to the tenant prior to eviction whether or not the tenant has a rental agreement.
    • State laws may impose additional requirements that are not preempted by the PTFA.
    • Additional potential requirements with respect to rental properties include:
      • reviewing the lease to determine if the property can be shown to prospective purchasers; and
      • returning any security deposit upon termination of the rental agreement.

Friday, December 9, 2011

OCC and OTS: Policy Integration

On December 8, 2011, the Office of the Comptroller of the Currency (OCC) issued a bulletin that outlines the process which the OCC intends to follow to fully integrate the Office of Thrift Supervision (OTS) policy guidance documents into a common set of supervisory policies that applies to both national banks and federal savings associations.
We have been monitoring the integration from its inception and informing our OCC and OTS clients accordingly. [For instance, see our newsletter OCC and OTS Synchronizing (6/8/11)]
If you are one of our OCC or OTS clients, please contact us for further information and discussion.
In this Newsletter
Overview
Process
Process: Phase I
Process: Phase II
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Overview
Dodd-Frank required that all functions of OTS relating to federal savings associations, and the rulemaking authority of the OTS relating to all federal savings associations, were transferred to the OCC on July 21, 2011. Consequently, the OCC assumed the responsibility for the ongoing supervision, examination, and regulation of federal savings associations.
Further, Dodd-Frank continues all OTS orders, resolutions, determinations, agreements, regulations, interpretive rules, other interpretations, guidelines, procedures, and other advisory materials in effect the day before the transfer date, while also permitting the OCC to administer these documents with respect to federal savings associations, until the documents are modified, terminated, set aside, or superseded by the OCC, by a court, or by operation of law.
The OCC issued an interim final rule on July 21, 2011, with request for comments that republished, with nomenclature and other technical changes, the OTS regulations formerly found in chapter V of title 12 of the Code of Federal Regulations. (These republished regulations became effective on July 21, 2011, and will be codified in chapter I at parts 100 through 197.1.)
Now, the OCC has announced in bulletin OCC 2011-47 that it is embarking on a comprehensive rulemaking project to integrate, when possible, these former OTS rules with OCC rules applicable to national banks. Concurrently, the OCC is integrating more than 1,000 supervisory policies of the former OTS into the OCC policy framework.
The OCC expects to produce a consistent, supervisory approach and integrated policy platform for national banks and federal savings associations, while recognizing differences anchored in statute.
Process
The OCC will group, to the extent possible, rescission notifications and other announcements related to the integration of OTS guidance, according to a two-phased process.
Process: Phase I
This phase involves rescinding a significant number of documents. The documents rescinded in this phase will include OTS documents that:
  • transmitted or summarized rules, interagency guidance, or Examination Handbook sections (not the conveyed guidance or rule itself);
  • are no longer useful because of the elimination of the OTS or the passage of time; and/or
  • duplicate existing OCC guidance.
Additionally, the OCC will rescind outdated guidance issued to national banks. Forthcoming OCC bulletins will announce these rescissions.
NOTE: In order to minimize confusion, documents will be watermarked as rescinded on the OCC Web site or former OTS Web site, as applicable.
Process: Phase II
This phase focuses on guidance that requires further review, substantive revision, or combination or is considered unique to federal savings associations.
Guidance
Guidance that is linked to regulatory or statutory requirements will be coordinated closely with the concurrent integration of OCC and former OTS regulations. In many cases, guidance cannot be revised or combined until the revisions to the rules on which the guidance is based have been finalized.
Priorities
Prioritization of the work will be influenced by feedback from the OCC's supervision staff as it encounters policy differences in the day-to-day supervision of national banks and federal savings associations.
Cross-References
Former OTS policies and guidance remain applicable to federal savings associations until rescinded, superseded, or revised. In some cases, the OCC may amend an OTS rule, policy, or practice that is cross-referenced in more than one document or affects only a portion of a document.
Duplications
If overlapping guidance exists, any guidance or regulation issued by the OCC after July 21, 2011, that specifically includes federal savings associations in its scope, will prevail. If a document has not been rescinded, but a portion of the content no longer applies, the superseded portion will be grayed out electronically.
Library
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Office of the Comptroller of the Currency
OCC 2011-47 (Bulletin)
Subject: OTS Integration
December 8, 2011

Tuesday, December 6, 2011

Defining “Homeless”

Yesterday, HUD reasserted its definition of the term "homeless." It also established the regulatory final rule for the definition "developmental disability'' and the definition and record keeping requirements for a "homeless individual with a disability.''
Many people do not come into face-to-face contact with this population on a regular basis. Indeed, except as we might encounter such individuals through charitable venues, outreach programs, and so-called "faith-based" initiatives, most of us have derived our knowledge about the situation faced by the disabled and the homeless from infrequent news broadcasts as well as from media Spin Meisters and politicians.
In the spirit of this holiday season, a time of charity and compassion, let's explore together the various ways that HUD has sought to provide a definition for the often disenfranchised and weakest amongst us. I think you will find it enlightening.
Background
On May 20, 2009, an important congressional act was enacted into law. It is called the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009, aptly named HEARTH. This law consolidated three separate homeless assistance programs administered by HUD under the McKinney-Vento Homeless Assistance Act into a single grant program, revised the Emergency Shelter Grants program (renaming it the Emergency Solutions Grants program), and created the Rural Housing Stability program (which replaced the Rural Homelessness Grant program). HEARTH also codified in law the Continuum of Care planning process, long a part of HUD's application process to assist homeless persons by providing greater coordination in responding to their needs.
Yesterday, HUD issued its final rule to integrate the regulation for the definition of "homeless," and the corresponding record keeping requirements, for the Shelter Plus Care program, and the Supportive Housing Program. And it established the regulation for the definition  of "developmental disability" as well as the definition and record keeping requirements for the "homeless individual with a disability" for the Shelter Plus Care program and the Supportive Housing Program.
What does "homeless" mean?
According to HUD, there are currently four categories of homelessness:
(1) Individuals and families who lack a fixed, regular, and adequate nighttime residence. This includes a "subset" subset for an individual who resided in an emergency shelter or a place not meant for human habitation and who is exiting an institution where he or she temporarily resided.
(2) Individuals and families who will imminently lose their primary nighttime residence.
(3) Unaccompanied youth and families with children and youth who are defined as homeless under other federal statutes who do not otherwise qualify as homeless as described herein.
(4) Individuals and families who are fleeing, or are attempting to flee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to violence against the individual or a family member.
Sheltering Children and Youth
Some terms above require an explanation. For instance HUD considers a "shelter" to mean "emergency shelter," but not "transitional housing." And "youth" is defined as less than 25 years of age. Traditionally, HUD has defined children as less than 18 years of age and adults as 18 years of age and above. But by establishing the term "youth" to mean less than 25 years of age, HUD hopes to more fully address the special needs of transition-aged youth, including youth exiting foster care systems to become stable in permanent housing.
I would also mention that other federal statutes provide definitions of homelessness under which unaccompanied youth and families with children and youth could alternatively qualify as homeless under category 3 of the homeless definition. These statutes are the Runaway and Homeless Youth Act (42 U.S.C. 5701 et seq.), the Head Start Act (42 U.S.C. 9831 et seq.), subtitle N of the Violence Against Women Act of 1994 (42 U.S.C. 14043e et seq.) (VAWA), section 330 of the Public Health Service Act (42 U.S.C. 254b), the Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), section 17 of the Child Nutrition Act of 1966 (42 U.S.C. 1786), and subtitle B of title VII of the McKinney-Vento Act (42 U.S.C. 11431 et seq.).
As best as I can tell, this list represents the salient statutes with definitions under which an unaccompanied youth or a family with children and youth can qualify as homeless under this category; that is, although there may be other federal statutes with definitions of "homeless," the statutes I've listed include those that encompass children and youth.
A Fifth Category?
A public comment was submitted for HUD to consider in its drafting of the final rule. This comment recommended a fifth category of "homeless," one that frankly I also can see as having a category of its own.
Here's the proposed fifth category:
Persons with disabilities who (1) have resided with a relative, but by virtue of age or other circumstances of that relative is unable to continue to provide shelter to the individual with a disability; (2) reside in an institution or facility not meant for permanent human habitation such as a hospital, rehabilitation facility, nursing or board and care home, and such individual has no home to return to where that person could live independently and safely; and (3) are in situations such as (1) and (2) who no longer choose to live in that circumstance and who wish to live independently.
HUD's response to this proposed fifth category was that it recognized there are "vulnerable populations that continue to be excluded from the definition of homeless," however, HUD determined to stay close to the statutory guidelines established in section 103 of the McKinney-Vento Act as HUD further clarifies the definition. That means, in brief, that the definition provided in the McKinney-Vento Act for "at risk of homelessness" reaches to the Emergency Solutions Grants program, the Rural Housing Stability program, and the Continuum of Care program. So, re-setting the interpretation will require proposed and interim program rules.
Proving Disability
HUD does look for written documentation of disability status. Information on disability is obtained in the course of each individual's assessment once that individual is admitted to a project, unless having a disability is an eligibility requirement for entry into the project.
And, where disability is an eligibility requirement, an intake staff-recorded observation of disability may be used to document disability status as long as the disability is confirmed by the aforementioned evidence within 45 days of the application for assistance.
The procedural criteria for determining disability are:
(1) Written verification from a professional who is licensed by the state to diagnose and treat that condition, that the disability is expected to be long-continuing or of indefinite duration and that the disability substantially impedes the individual's ability to live independently; and,
(2) Written verification from the Social Security Administration, or the receipt of a disability check (i.e., Social Security Disability Insurance check or Veteran Disability Compensation).
What does "lacking resources" mean?
It is worth considering what HUD views as a condition in which an individual may claim to be "lacking resources." Often, the ideologues and demagogues of the world assert that this condition is contrived, a result of an unwillingness to work, laziness, lack of ambition, squandered opportunities, and willfully failing to contribute to their own and society's betterment.
I think the question to ask ourselves, when determining this condition, is "Who would we turn to if we were down and out?" For many people, there simply are no support networks available, and that is a condition which has nothing to do with rejecting a work ethic or turning away from contributing positively to society.
Historically, HUD's view has not specifically defined in regulations or notices the concept of "lacks the resources or support networks" for the purposes of documenting eligibility for HUD's homeless and homelessness prevention programs. HUD's view has been that the resources and support networks required to demonstrate this criteria can vary drastically from person to person and community to community. This is a valid view, given that HUD could never capture all of the various possibilities.
The final rule, therefore, does not provide a definition for "resources or support network." However, it does provide examples of support networks when determining whether an individual or family lacks the resources or support networks to obtain other permanent housing.
These examples, which include friends, family, and faith-based or other social networks, are not meant to be an all-inclusive list, but rather they are designed to illustrate the kinds of support networks that people must first turn to, if they are able to, before drawing on the scarce resources targeted to homeless people. Putting this differently, a housing situation that is unsafe due to violence is obviously not considered a "resource or support network," and such a condition does not disqualify an individual or family under the applicable category based on such a situation.
So HUD has clarified that family, friends, and faith-based or other social networks are examples of "resources or support networks."
"We" or "Me"
The challenge of homelessness, especially at a time when millions of families have lost their homes and jobs, is not someone else's problem. The effects of homelessness, as we all know, reach horizontally out to virtually all areas of economic activity, and vertically through generation after generation.
The least amongst us affects the strongest. I hope we will continue to address the needs of the homeless, especially because we are a great and caring nation, so that the children and youth that suffer as a result of homelessness will join us all in the task of building a stable and prosperous society.
Consider Hillel the Elder's piercing questions:
If I am not for myself, who will be for me?
If I am only for myself, what am I?
If not now, when?
In this season of joy and charity, maybe there will be a chance for us to become "first responders" to the homeless and the disabled.
Is our country a "We" or a "Me" nation?
Since 1776 we have had the answer: E Pluribus Unum. Out of Many, One.
Further Readings
Homeless Emergency Assistance and Rapid Transition to Housing: Defining "Homeless"
Final Rule
Department of Housing and Urban Development
Federal Register - 76/233
December 5, 2011
* Jonathan Foxx is the President and Managing Director of Lenders Compliance Group.