September 11, 2011
I was heartened to read that SEC is considering requiring initial and ongoin asset-level information with respect to ABS offerings.
As a realtively well paid engineer in California, I was priced out of the housing market by a factor of 5 during the boom. Still, I could easily have rented a $850k house for $2500 per month.
Had the banks taken the extra effort to include median incomes and rents into their evaluation of asset values, things would have been different.
While I appreciate the attention you draw to the matter, I also think we all need to approciate how obvious it is that a lender should consider median incomes and rents. To think that lenders need SEC to regulate something so simple is to beg the question as to whether there isn't a more fundamental problem at hand with lenders. Maybe, the problem is "investment banks" themselves.
I think both the obvious and maybe the underlying issues could be addressed if SEC required mmedian income and rent discolsures. I think the information would impart so much clarity that we would see the end of the investment banking induatry - which clearly relies on deception and burying customers in volumes of paper work. If the numbers are right there in a column next to the assumed asset value and "asset value to" ratios, how many invemstment bankers would it take to screw in that light bulb? Sure, there would probably be hundreds of pages of accompanying reps, warranties, etc. etc. But who would bother reading all of that if it was clear that "asset value to" ratios were out of whack.