Friday, May 30, 2014

Privacy Invasion



"Here to Help"

Ever heard of the Consumer Financial Protection Bureau (CFPB)?  Or the Federal Housing Finance Agency (FHFA)?  Probably not.  But if you have a mortgage on your home then chances are these groups have heard of you.  And they want to get to know you better, much better. 
According to a notice posted on April 16, 2014 in the Federal Register, the FHFA will be gathering and maintaining personal information as part of the “National Mortgage Database Project”.  Sounds harmless. Whose data will be collected?  According to the notice, “individuals who have records in… credit bureaus or consumer reporting agencies”, which includes just about anyone with a wallet or a purse. Estimates are that 227 million Americans will be effected.  The justification for compiling this information is to facilitate the FHFA / CFPB’s ability to comply with reporting requirements under the Housing and Economic Recovery Act (HERA), legislation brought in response to the sub-prime mess of 2008.  
The database will include mortgage information, such as loan amount, monthly payment, delinquency information.  But that’s not all.  It also includes information of a more personal nature.  What sort of personal information?  Generally speaking, everything.  Info you don’t tell your mama. 


Altogether the Database Project includes about eighty-five fields of information (the entire list is included below).  Here are some of the more troubling items:  race, ethnicity, language, religion.”  What?  How does being a Presbyterian or an Animist affect a person’s credit?  Further overreach, “household composition (i.e. single female), number of children and their ages, marital status.”  Is this the government or a dating site?  More,  household income, credit score, number of bedrooms and baths.”  And my personal favorite, “latitude and longitude”, which I guess is a big help if someone needs to dial up a drone strike. 
The information will be obtained from "individuals who respond to the National Survey of Mortgage Borrowers" as well as FHFA system records, Federal government systems of records (IRS?), credit repository files and "commercial data aggregators".

Who will have access to all this information?  No worries – all of the information is protected under the Privacy Act.  According to the notice, only the Federal Housing Finance Administration, the Consumer Finance Protection Bureau and their advisory committees have access.  Oh, and perhaps a contractor, volunteer or intern working for those agencies.  And a Congressional office in response to an inquiry.  Or a court, magistrate or administrative tribunal in the course of an investigation.  And possibly the Department of Justice, which would include the US Attorney, FBI, DEA, etc.  And of course, the Department of Homeland Security, Department of Labor, Equal Employment Opportunity Commission, or “other Federal agencies”.      

In George Orwell’s “1984”,  Big Brother's fascist regime referred to its propaganda and history revision bureau as the “Ministry of Truth”.  Similarly, in 2010 under Dodd-Frank, the CFBP was created ostensibly to “protect consumers”.  Call me paranoid, but why exactly does the federal government need to know how many bathrooms I have?  Or what the credit limit is on my MasterCard?  The longitude and latitude of my home?  My employment records?  A list of my assets?  Or my religious affiliation?  

The legal definition of invasion of privacy is the intrusion into the personal life of another without cause.  If that's the standard of invasion, then this action against 277 million Americans constitutes a Normandy-style frontal assault.  How does this new database protect the consumer?  Ronald Reagan put it this way, “the nine most terrifying words in the English language are, ‘I’m from the government and I’m here to help.’”      

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The following is the full list of the data points included in the federal notice for the National Mortgage Database Project:


Borrower/co-borrower information
name
address
zip code
telephone numbers
date of birth
race/ethnicity
gender
language
religion
social security number
education records
military status/records
employment status/records
Financial Information
account number
financial events in the last few years
life events in the last few years
other assets/wealth
Mortgage Information
current balance
current monthly payment
delinquency grid
monthly payment
refinanced amount
bankruptcy information
Credit card/other loan information
account type
credit amount
account balance amount
account past due amount
account minimum payment amount
account actual payment amount
account high balance amount
account charge off amount
second mortgage
Household composition
single male / single female, etc.
presence of children by various age categories
number of wage earners in household
household income
credit score
deceased indicator
marital status
Property Attributes
property type
number of bedrooms and bathrooms
square footage
lot size
year built/age of structure
units in structure
most recent assessed value (per tax roll)
year of most recent assessed value
effective age of structure
assessor's parcel number
neighborhood name
project name
Real Estate Transaction Attributes
sales price
down payment
occupancy status (own, rent)
new versus existing home
county
census tract/block
latitude/longitude
date purchased
Mortgage Characteristics
mortgage product and purpose
origination date
acquisition date
amount of mortgage
refinanced amount
amount of down payment
term of mortgage
interest rate of mortgage
source of mortgage/mortgage channel
mortgage insurance type
loan to value at origination
origination amount/credit limit
originator
current servicer
debt to income ratio at origination
number of borrowers
number of units in mortgage
presence of prepayment penalty
origination points paid by borrower
discount points paid by borrower
balloon payment date/amount
percent of down payment
secondary market indicator
Information collected from consumers as part of
surveys
randomized controlled trials
or through other mechanisms.

Saturday, May 10, 2014

Naming Money



When there’s trouble, bust-out nations and their central banks go to the International Monetary Fund (IMF) to pick up some walking around money.  Like a super-national quick-cash store, the IMF is the world’s lender of last resort.  When the IMF issues a loan it isn’t denominated in dollars, euros or yen, but in Special Drawing Rights, aka SDRs, the fiat currency issued by the IMF.  Economists say that the IMF has the cleanest balance sheet of all the world’s central banks.  Meanwhile, the IMF is known to have a longstanding desire to become the source of the world’s monetary supply, under a single, one-world currency.  With the major central banks in the US, the EU and Asia going broke, maybe now is time for the IMF to make its move.  If that happens the SDR would become the new global currency.

Politics and economics aside, does an “SDR” sound like money to you?  Maybe I’m too superficial, but frankly, I don’t get a warm and fuzzy feeling from the term “SDR”.  If it’s going to be the new money, can’t the world come up with a better name for it?  As a good global citizen, I offer some suggestions to name our new cash.  

First, the Global.  Not too imaginative, but it creates a mental image that would dovetail nicely with the IMF’s branding efforts.  Clear.  Concise.  It has a nice, round sound to it.  But it’s bland.

How about the Gaia?  Working from a similar theme, but with more sophistication and international flair.  The Gaia sounds warm and lush, at least to me, as a northern-hemispherer.  Maybe to a Saharan it sounds hot and dry, I don’t know.   It will need to be tested marketed.  But the environmentalists should love it.  Unless they take exception to having "filthy lucre" named after their Mama. 

Speaking of mama, how about the Mother Earth?  Admittedly, this is an Anglicization of Gaia, which may be undesirable.  Empire building has that effect on people.  The Mother Earth does connote nurturing and care, with a planetary ring to it, which is good for the big picture.  But it may prove too unwieldy for day-to-day use.

Then how about this -- the Bling?  How often do you get to create a one-world currency?  Why not make it fun?  Besides, Hollywood glitz and glamor is popular worldwide.  Everybody wants to be a star.  Why not work with that?  Give it some street, yo!  You feelin’ me?  

But how would it sound in use?  For example, “that Rolex costs five thousand Bling.”  Or this, “the US economy posted a one-point-two-billion Bling deficit last quarter.”  I don’t know, kind of works, kind of doesn’t.   Better keep going.

The Kumbayah.  Isn’t this global peace-in-our-time, buy-the-world-a-Coke thing all about  getting along?  Then this name’s a winner.  How could I get ticked off at someone over a few hundred Kumbayah?  The spelling is a little tricky, but it has a friendly sound to it.  For ease in trade it could be shortened to the Yah.  Yah” has a positive ring to it too.  Let’s try it, “the Big Mac is three Yah.”  Sounds agreeable, yes?

The Shizzle.  This one is fun to say.  It even sounds funny.  There’s a “shh” sound and a “zzz”.  It’s easy to shorten, “that shirt is on sale for fifteen Shizz.”  What’s not to like?  May sound slightly Yiddish, which could be an issue in some quarters, but all and all, a good solid choice.

How about the Illumibuck?  This name will appeal to the skeptics, who look for the story inside the story, or the man behind the curtain.  Could the whole one-world thing be nefarious?  Maybe so.  But give credit, or debt, as the case maybe, where it’s due.  If there are puppeteers leading us along, throw them a bone.  Put a name on it! 

Maybe all this naming stuff is over the top, too complicated, too many syllables.  Instead, I offer a last, simple, straight-forward name, the MF, short for Monetary Fund.  Easy to remember, easy to spell.  What’s the big deal?  Loss of state sovereignty, democratic control, regional accountability.  Why all the fuss?  It’s just currency, right?

Best of all, with a name like the MF, people can dress it up with nicknames on their own.  Names that encapsulate their feelings for the new currency and the people responsible for bringing it about.