A new report from the National Consumer Law Center analyzes the record of the government’s main mortgage modification initiative, and where we go from here.

“[P]ortions of today’s rule should have been stronger, and the CFPB has put one very important question on the table for further comment, creating a risk of further slippage.”

The rules… are “likely to resemble” an October draft that “extended a legal safe harbor to loans issued at prime interest rates to borrowers whose total debt-to-income ratio doesn’t exceed 43 percent.”

With new rules for mortgage lending and servicing due to be issued soon, the Bureau faces an important opportunity to make the housing market work better for families and communities.

More specificity and disclosure are needed in the big banks’ “living wills.”