patrick.net

Homeowners Losing Equity Lines
As House Values Fall, Some Banks Withdraw Credit

By Dina ElBoghdady
Washington Post Staff Writer
Saturday, February 23, 2008; A01

In one brief phone call, Nancy Corazzi's lender yanked away what was left of the $95,000 home equity line of credit that she and her husband took out five months ago.

The lender informed her that her Howard County home had plummeted in value and the company did not want the risk that she would owe more than the house was worth.

"I got off the phone and I was shaking," said Corazzi, who was using the money to pay preschool tuition for her twins ."I was near tears. We needed this credit line to get us through some tough times."

Several of the nation's largest lenders, along with smaller ones, are shutting off access to home equity lines in areas where home values are declining. It's an unusually aggressive move as the industry grapples with fallout from the mortgage crisis that began unfolding last year.

Now that home prices have dropped in many parts of the country, lenders are nervous that they may never collect the money that they extended to borrowers. They are responding by freezing or lowering the credit limits on home equity lines, leaving thousands of borrowers like Corazzi in the lurch.

"Nearly all the top home equity lenders I know of are doing this or considering doing this," said Joe Belew, president of the Consumer Bankers Association, which represents some of the nation's largest home equity lenders. "They are all looking at how to protect themselves as real estate values go down, and it's just not good for the borrowers to get so overextended."

Countrywide Financial, the nation's largest mortgage lender, suspended the home equity lines of 122,000 customers last month after reviewing their property values and outstanding loan balances. The company, like others, has an internal automated appraisal system that tracks values.

The company declined to disclose how many of the affected borrowers lived in the Washington area. About 381,000 borrowers in the region had home equity lines at the end of last year, according to Moody's economy.com.

USAA Federal Savings Bank froze or reduced credit lines for 15,000 of its customers, including Corazzi, and will not reconsider its decisions until "real estate values improve substantially," the company said in a statement.

Bank of America is starting to do the same and is contacting some borrowers, said Terry Francisco, a bank spokesman.

"We know this can cause hardship to our customers," Francisco said. "If they used the credit to make payments that are in the pipeline, we will work with them to make sure the payment goes through."

The appeal of home equity lines has always been their flexibility.

They operate like credit cards, with the home as collateral. Borrowers can use the money when they want, up to a limit, then repay it over time. The limit depends on the amount of equity they have in the house. Home equity lines, which grew popular in the late 1980s, have typically attracted educated borrowers with above-average incomes and job stability who tend to repay what they borrow in a timely manner, industry studies show.

Since the crisis in the housing and mortgage markets started, however, delinquencies on home equity lines reached 0.84 percent in the third quarter, the highest level in a decade, the American Bankers Association said.

Because missed payments are often a precursor to foreclosure, lenders are spooked. Companies that hold credit lines typically recoup little, if any, of their money in a foreclosure, hence the retreat on home equity lending.

Larry F. Pratt, chief executive of First Savings Mortgage in McLean, said most mortgage documents he has seen give lenders wide latitude to suspend or freeze credit lines.

"A layperson would not recognize the language because it's not that blatant," Pratt said. "It talks about deterioration of the value of the asset or the value of the collateral. . . . It's not boilerplate language by any means."

Maggie DelGallo did not realize that when she took out a home equity line a few years ago on her home in Loudoun County. Her lender recently froze the line.

DelGallo, a real estate broker, has used some of her credit line over the years. Had she known the freeze was coming, "I would have drained it," she said. "I would have taken every dime and possibly placed it in a money-market vehicle."

DelGallo said she does not think she is in dire straits. "It's more like a huge disappointment," she said. "I have this line of credit attached to my home that's useless."

Last year, 34 percent of borrowers said they used their home equity lines to pay off other debt and 29 percent used them for home renovation, according to a survey of lenders by BenchMark Consulting International. Another 31 percent used them to pay for other things, such as medical bills, weddings or vacations.

Corazzi initially used her line to consolidate debt. She and her husband took out the credit line in October because they thought her job was in jeopardy.

It was. In December, her salaried position as a loan-processing manager at a local mortgage bank changed to a commission-only job.

Given the slowdown in the industry, Corazzi has collected only one paycheck since then. Her husband, Ron, sells large-format copiers and printers to builders, and his salary alone cannot support them and their four children, ages 4 to 8.

By the time their lender called, the couple had $45,000 remaining unused on the credit line. Ron Corazzi is now looking for a second job, and his wife is hoping to pick up work as a substitute teacher.

Meanwhile, they are trying to open a new home equity line elsewhere, but chances are slim given the change in Nancy Corazzi's job status and the drop in their home's value. Five months ago, the Ellicott City house was appraised at $560,000; the lender says it is now worth $469,100.

"I told them, 'You guys are wrong,' " Nancy Corazzi said. "They said, 'Sorry, this is what we're doing in the entire area.' "

Corazzi said she was blindsided by what's happened. "I didn't know they could do that. I thought I was too smart to have something like this happen to me."

cutting of HELOC is unheard of. yet another 'never happened before' during the credit catastrophe.

most people use it up within the first year I bet. thus the huge losses.

with high LTV those HELOCs are essential unsecured. So its an 8% credit card with a 150K balance, losses will continue to be staggering when you compare them to credit cards. 30k is a 'whopping credit card' max, but it takes 300k for a HELOC to be out of the ordinary large.

http://tinyurl.com/3d35ye

Even Northern Trust?!? This world has gone completely mad.

Corazzi, who was using the money to pay preschool tuition for her twins

Why the heck does fancy-pants private-preschool tuition require going to the poorhouse via HELOC?

And a bailout is coming! How the hell can we stop Washington from bailing out the banksters et al? Any suggestions greatly appreciated!

I wouldn't get change for a dollar at Washington Mutual.

>>Why the heck does fancy-pants private-preschool tuition require going to the poorhouse via HELOC?

Pre-school can range from "horrible" at $1000 a month to "ok" at $1500 a month to "excellent" at $2500 a month.

Seriously - that's the business to be in. (Though I bet their insurance costs must eat all the profit.)

Yup, preschool is pricey. And the lady has twins. That would be about $3k per month for "OK."

Of course, I am going to guess that pulling the twins out of preschool and staying home with them would work out better, money-wise, than leaving twins in preschool and working as a substitute teacher.

Re: preschool as a business...I have a friend who just started a small daycare. She's doing OK with six kids at $12/kid/hour. That puts her in tech salary range for finger painting and sand play. I'm not saying that engaging with kids is not work, it is, but times have changed since the days when there were tons of stay-at-home moms who would be happy to bring in a few pennies for watching the neighbor's kids.

What did Reagan, Clinton and Obama have in common?

Their dads abandoned them at an early age. And they didn't go to hoity toity elite preschools.

Claire Says:
February 23rd, 2008 at 9:38 am
"And a bailout is coming! How the hell can we stop Washington from bailing out the banksters et al? Any suggestions greatly appreciated!"

I think I still have my letter from Barbara Boxer stating there was no planned bailout or bills pending for a bailout.
-Dey are not near Bagdad~Iraqi Info Minister

I have seen the sex tape in valleywag.com:

http://valleywag.com/358401/gene-simmons-sex-tape-leaked-on-web-nsfw

Gene Simmons’ lawyer confirms sex tape is real

Gene Simmons’ lawyers have started sending out cease and desist letters to those that have posted the now infamous ‘Gene Simmons Sex Tape’ - and have pretty much confirmed it’s him in the video.

The letter, sent to Valleywag.com, reads, in part, “The video in question was surreptitiously filmed without Mr. Simmons’ knowledge by a woman named Traci Anna Koval.

“To the the extent that Ms. Koval ever claimed to have any interest in the video, which is both disputed and inconceivable, given its surreptitious filming, such rights were acquired by our client Allied Industry in 2003, pursuant to a written assignment and release agreement in which Ms. Koval assigned all of her interest in the video to Allied Industry, including the copyright, represented and warranted that no additional copies would be exploited or distributed and expressly consented to injunctive relief.”

The video, which surfaced yesterday, shows Simmons wearing his T-shirt in various sexual positions on a bed. It was originally posted on a website that is selling the tape to those who wish to download the footage.

In a recent blog entry, the Kiss rocker spoke out about the sex tape scandal, calling it “garbage”.

Gene’s statement, which hints at legal action, reads: “Hi everyone,

“You may have heard or seen garbage that has sprung up from my past.

“Rest assured the proper legal team is looking at all ramifications and options.

“And us? Shannon, Nick and Soph are happy and healthy.

“All is well.

“And thank you all for the kind words of support.”

cutting of HELOC is unheard of

That brings up a question that has been running around for a few days in my mind, and which I think I will raise on each of my favourite blogs (here, Ben's and CR :) ). Hopefully I can get at least one definite answer.

Can the lender do a similar thing on an Option-ARM? By that I mean call force majeure based on declining values, and demand that the borrower pay at least the monthly interest going forward.

According to Tanta at CR, no.

Why the heck does fancy-pants private-preschool tuition require going to the poorhouse via HELOC?

Because, DennisN, the clowns see any bill paid by HELOC as being paid with free money, not as a loan with interest that must be paid back. Note that she only needs to find work now that the HELOC ATM is closed. Further proof of that demented mentality comes from another lady quoted in that article:

Had she known the freeze was coming, “I would have drained it,” she said. “I would have taken every dime and possibly placed it in a money-market vehicle.”

Does she really think she can find a money-market vehicle that pays higher interest than the HELOC would charge? Her statement implies she thinks of HELOC money as "profit" to invest.

“I would have drained it,” she said. “I would have taken every dime.."

@Headset. Yup, agreed. And another interpretation is "I don't want to lose that financial security, that lifeline. After all, that's my cheap money isn't it?"

A worrisome speculation. Is the implication that once this gets out, will widespread reaction be this kneejerk "crisis" withdrawal? Its very possible that many consumers will want to do this very thing, yank out that cash before that opportunity disappears. I wonder what controls the banks have in place, it could get out of control in a hurry. Ummm, folks are sitting on checkbooks and debit cards to do the drawdown, right?

I even hear this from my friends, "well, we always have the heloc if things get a little more messy".

Who is up for a HELOC bank run, anyone?

Had she known the freeze was coming, “I would have drained it,” she said. “I would have taken every dime and possibly placed it in a money-market vehicle.”

How great would this be if she had done that only to see the money market fund "break the buck" due to losses in SIVs, etc..

Imminent spike in non performing loans, this will clear out all those folks paying their firsts via Heloc withdrawal mighty quickly. Or maybe these 759 Fico's are all sitting on 100K in unused credit card lines to tap now. Fair Issac needs to get busy on profiling those who look like they lost Heloc via new credit card activity. Wonder if they are sophisticated enough to do this?

No doubt the major credit card issuers have their eyes on this one, already some significant activity reducing unused credit card lines. I suspect we will see a whole wave of pull back in short order.

No more soup for you. Credit and lending is about to finally seriously contract.

This thing is about to get very serious. If the general public had any idea just how serious I think we would have a general panic on our hands. I am astounded daily at the absolute cluelessness of folks on these matters. I do feel like the clock is ticking, it will eventually get out.

I am astounded daily at the absolute cluelessness of folks on these matters.

It may not be "those folks" who are clueless. The gov right now may be working on ways to take the sting out of reckless debt. All at the expense of savers, of course. After all, who would have predicted the "tax rebates" and the lack of M3 data?

Save the Nation with Inflation

Pay the Chinese with Inflation ease

Cure the Mess with the Printing Press

Despite any such efforts, I hope Mish is correct and deflation vindicates savers and creates affordable housing for future generations.

Last year, 34 percent of borrowers said they used their home equity lines to pay off other [improvidently-acquired] debt and 29 percent used them for [pergranitile] home renovation, according to a survey of lenders by BenchMark Consulting International. Another 31 percent used them to pay for other things, such as medical bills, [unneccesarily-ostentatious] weddings or [unnecessarily lavish] vacations.

That story was missing a few details so I took it upon myself to add in a few details. Is this hubris? No, let me tell you what's hubris - a quote from the same story.

"I thought I was too smart to have something like this happen to me."

This is the first mention I've seen of this particular bailout plan. It would seem to have just enough common sense in it to pull through our political diligence process. For my money, I'd bet you this is what the first phase of our government bailout plan looks like. It's interesting and entertaining that our financial leadership is inviting anyone with "ideas" at this point also. Good stuff.

http://www.nytimes.com/2008/02/23/business/23housing.html?_r=1&oref=slogin

partial excerpt

The House Financial Services Committee is working on various options, including a government buyout. The Bush administration may be softening its hostility to a rescue as well. Top officials at the Treasury Department are hoping to meet with industry executives next week to discuss options, according to two executives.

“There are a lot of ideas out there,” said Scott Stanzel, a spokesman for President Bush, when asked at a White House press briefing on Friday about a possible buyout program. “There are many different ways in which we can address this problem and we continue to look at ways in which we can do that.”

Supporters contend that a government rescue could be the fastest and cleanest way to force banks and investors to book their losses from bad mortgages — a painful but essential first step toward stabilizing the housing market.

The government would buy the mortgages at their true current value, perhaps through an auction, at what would probably be a big discount from the original loan amount. The mortgage lenders, or the investors who bought mortgage-backed securities, would be free of the bad loans but would still have to book their losses.

If the government took control of the bad mortgages, supporters of a rescue contend, it could restructure the loans on terms that borrowers could meet, keep most of them from losing their homes and avoid an even more catastrophic plunge in housing prices.

“Every citizen has a dog in this hunt,” said John Taylor, president of the National Community Reinvestment Coalition, a community advocacy group that has developed its own mortgage buyout plan. “The cost of spending our way out of a recession is something that everybody would have to bear for a very long time.”

Mr. Taylor estimated the government might end up buying $80 billion to $100 billion in mortgages. But he said the government could recoup its money if it was able to buy the mortgages at a proper discount, repackage them and sell them on the open market.

Treasury officials confirmed that several senior officials invited Mr. Taylor to present his ideas to them on Feb. 15. Mr. Taylor said he had also received calls from officials at the Office of Thrift Supervision and the Office of the Comptroller of the Currency, which is part of the Treasury Department.

But even supporters acknowledge that a government rescue poses risks to taxpayers, who could be left holding a very expensive bag.

Ellen Seidman, a former director of the Office of Thrift Supervision and now a senior fellow at the moderate-to-liberal New America Foundation, said the government’s first challenge is to buy mortgages at their true current value. If the government overpaid or became caught by an even further decline in the market value of its mortgages, taxpayers would indeed be bailing out both the industry and imprudent home buyers.

“It’s not easy, but it’s not impossible,” Ms. Seidman said. “There are various auction mechanisms, both inside and outside government.”

A second challenge would be to start a program quickly enough to prevent the housing and credit markets from spiraling further downward. Industry executives and policy analysts said it would take too long to create an entirely new agency, as Bank of America suggested. But they expressed hope that the government could begin a program from inside an existing agency.

But even if the government did buy up millions of mortgages and force mortgage holders to take losses, the biggest problem could still lie ahead: deciding which struggling homeowners should receive breaks on their mortgages.

Government wont buy bad loans at discount - it will probably be at 100% of loan amount. Thats what a fannie refi is right? thus the increased limit allowing these big loans to be insured by taxpayer. Also fannie can buy 'old' loans from 1-2 years ago right?....I wonder what the criteria is....if they buy delinquent loans lookout below taxpayerss....

In other news Nader is running for president! I think he is the opposite of Ron Paul. If they shake hands they will combust like matter/anti-matter reaction.

When buying a home, be wary of `creampuffs’

A perfectly groomed home could be irresistible — but acting on emotion might be risky.

They were a couple in their early 30s, out for a day of house-hunting when they happened upon a ranch-style place they found irresistible — first for its lovely gardens and later for its exquisite interior furnishings.

”Coming up the walkway, they bought that house before setting foot inside,” recalls Sid Davis, the real estate broker who listed the property.

After more than 25 years of selling homes, Davis knows which upgrades most enhance the salability of a place. And in this case the owners, following his advice, used all the hot buttons that excite buyer interest.

”The man of the house was an electrician who was exceptionally handy and could make a house look really sharp. He did a superb job of painting inside and out. His wife, a nursery school teacher, used her amazing green thumb to nurture the flower beds and lawn. When they were ready to sell, the place oozed with curb appeal,” says Davis, author of Home Makeovers That Sell.

LOOK CHANGED

But the property proved a disappointing choice for the purchasers, a civil engineer and his homemaker wife.

”Like most people, they had neither the skills nor inclination to maintain the gorgeous gardens and perfect lawn,” Davis says. ‘Also, the worn furniture they hauled in from their apartment didn’t look nearly as good as the sellers’ furniture. After moving in, they were shocked that the house had lost a lot of its ‘wow’ feeling.”

Realtors refer to a home that’s perfectly groomed for sale as a ”creampuff.” They caution buyers against making a snap decision on such a property without further analysis. The risks of buying solely on emotion are that you’ll buy the wrong home, overpay or both.

Here are three tips for prospective homebuyers:

• Look for signs of ‘’staging.” In recent years, an increasing number of home sellers have begun hiring a ”home stager,” someone with a flair for making a property look enticing to potential buyers.

Staging, which typically includes the removal of excess furniture and the rearrangement of remaining items, is widely recommended as a savvy step for home sellers. But advocates for purchasers say they should be careful not to let good staging lure them into buying an unsuitable home.

TELLTALE SIGNS

Merrill Ottwein, a past president of the National Association of Exclusive Buyer Agents, says there are several telltale signs buyers can use to determine if a property has been staged to evoke positive emotional reactions.

”Many times stagers move out much of the kind of furniture real families use — just to make the rooms seem larger than they really are,” he says. “For example, they’ll take out a sofa or loveseat from the living room and replace it with a small armchair.”

• Realize that many ”For Sale” properties are presented free of clutter.

Listing agents are at war with the kind of clutter people routinely accumulate — whether this involves mountains of shoes in a bedroom closet, dozens of bowling trophies in the den, or countertops crowded with gadgets. They know a cluttered home usually sells more slowly and for less money.

There’s nothing wrong with buying a home that’s been de-cluttered. But don’t let the clean, sleek quality of such a property dissuade you from your larger purpose of selecting a property that meets your family’s needs.

• Be realistic about your ability to maintain lush landscaping. First-time buyers, like the civil engineer and his homemaker wife, are the ones most easily swayed by blooming flower beds, carefully clipped bushes and well-pruned trees. That’s because most first-timers live in apartments with little greenery of their own. Novice buyers are also the least likely to appreciate the time demands that yard maintenance can make, according to Davis.

”Beautiful curb appeal is a high-effort endeavor, and few are willing or skilled enough to do all the work involved,” he says.

Of course, those who can’t uphold the standards of the property’s former owners can hire a landscaping firm to do the work. Still, he says anyone expecting to rely on a landscaping service should make sure they can afford it before buying a property with elaborate upkeep requirements.

”Call in a couple of landscapers for estimates on what they’d charge,” Davis says. “Then just assume this cost would be tacked on to your regular monthly house payment. If you can’t manage the upkeep costs on the property, you should back away.”

Ralph Nader is an Arab terrorist. He's the very opposite of Ru Paul.

www.msnbc.msn.com/id/23319781/ Sorry HK, I didn't at first believe you until I looked it up myself.

Nader is the nadir of American politics.

Nader is massively massively powerful. Or was. He took Gore's 'ez win' and gave it to bush in 2000. My republican friends used to love him for that. As if Nadar was on GOP payroll. Imagine the alternate history we coulda woulda shoulda had!

I'm waiting for McCain to announce at a press conference that he's making a $100 contribution to the Nader campaign. ;)

off topic:
check out how Obama voted
http://www.votesmart.org/voting_category.php?can_id=9490&type=category&category=40&go.x=13&go.y=13

Please notice the church he has attended for 20 years, the Trinity Church of Christ (Google), its pastor, Jeremiah Wright and the relationship to Louis Farrakhan. Is this even close to the man we want as the leader of the free world? In the “Capital Contacts”, the directory of our elected officials in D. C. there is a question asked of all elected officials; what is your religious denomination? Instead of stating his religious denomination; Mr. B lists his church “United Church of Christ”; food for thought

In other news Nader is running for president!

Excellent! :)

Again, congrats to President McCain.

Imagine the alternate history we coulda woulda shoulda had!

Gore would have put us through that Kyoto Protocol nonsense using convenient fiction.

How about McCain-Romney?

off topic: http://politicalnighttrain.wordpress.com/2008/02/01/is-farrakhan-influencing-obama-through-jeremiah-wright/
Obama ‘repudiates’ Farrakhan?Ed Lasky
The New York Sun is reporting that Barack Obama repudiated the views of Nation of Islam leader Louis Farrakhan that were discussed in Richard Cohen’s Washington Post column. Cohen’s criticism regarding Obama’s ties to the Church and the Pastor that gave an award to Farrakhan were reaching a large audience that included potential Democrat voters who might be swayed to withdraw support from Obama. This statement by Obama is a political maneuver that should be given little credence. Obama is very actively involved in his church; he knew of this award long before Richard Cohen publicized its grant to Farrakhan. Furthermore, Pastor Wright has had a long relationship and alliance with Louis Farrakhan. Obama did not object to these ties between Pastor Wright and Farrakhan before; nor has Obama rejected the anti-Israel diatribes of Wright. Regardless, Obama adheres to a church and a minister that have long espoused positions inimical to the American-Israel relationship, let alone the trumpeting of black values and racial exclusiveness. This follows a pattern for Obama: he shows extreme loyalty to a church and pastor whose controversial views eventually become publicized. Then Obama “disappears” the Minister and Obama’s campaign (not Obama himself) issues a statement that Obama does not agree with everything that Wright espouses. He solicits and gains support from the controversial George Soros, a man whose anti-Israel passions and allegations regarding America’s Jewish community and Congress are well-known. When these ties become publicized, Obama’s campaign (not Obama himself) issues a statement that Obama does not agree with Soros on this topic. When Obama articulates anti-Israel positions in off-the cuff remarks, his campaign (not Obama himself-stop me if you have heard this before) issues clarifications that attempt to explain away the plain English import of Obama’s (the supreme orator) expressed views. In other words, Obama only disavows when it is politically opportune to do so. He seems to have never objected to these views before they become publicized and create a political firestorm because they belie his image of peace, compassion, unity. Obama is not a profile in courage and his disavowals are political pabulum.

DennisN,

I don't think Nader will be able to do any damage this time. Obama is the anti-Nader, in the sense that I think people who are susceptible to voting for Nader will vote for Obama this time. Of course Obama cannot ignore Nader and has to be vigilant about the threat.

If Clinton wins the nomination, things could go wrong for the Democrats with respect to Nader.

My take is that Hillary will fight dirty to get the delegates from MI and FL seated for her. Disaffected Dems will then vote Nader in protest.

DennisN,

I don't straight-thinking democrat will risk the chance of getting McCain as president, protest or not. The last 8 years have shown with total clarity the risks of having a war-hawk/republican in the white house, and people will vote to ensure it does not happen again.

Besides, on the very odd chance that Hillary gets the nomination, I would wager that Obama will get behind her and talk the Nader swing/protest voters down from the ledge, so to speak. That would require real statesmanship on Obama's part, but if anyone has got it, it is him.

Corerection:

I don't THINK straight-thinking democrats ....

If the government took control of the bad mortgages, supporters of a rescue contend, it could restructure the loans on terms that borrowers could meet, keep most of them from losing their homes and avoid an even more catastrophic plunge in housing prices.

A further plunge in house prices is what is needed. Where was the demand for policies to prevent rapid price increases when the bubble was inflating? Now that we are on the back side of the bubble, I hear the politicos and newspaper columnist claim that the problem we must butts to fix is falling house prices.

>> Again, congrats to President McCain.

I am voting for him. I can not imagine voting for Democrats (supporters of Illegal Immigration and massive bailout)

I will be voting for McCain because he will screw up the US further much faster. I also like a Republican in the seat when all the shit hits the fan so that Bush will have no one else to blame for all the great setup job he did.

I'd like to see this country crash hard FAST, and then we can bounce back faster from the bottom. I hate slow motion landing that takes years, I like crash landing.

With a war-hungry, Alzheimer patient-to-be in charge, a crash landing is sealed. It will be more interesting to watch who will run in 4 years, because whoever is gonna be in white house from 2008-2012 will certainly be an one-term President.

So I am voting for McCain, but for a set of entirely different reasons.

Hi OO,
I have to say that I hate the concept of trying to plunge this country into complete chaos for our amusement but then on the other hand, the rampant stupidity that seems to be escalating is so discouraging that I have to end up agreeing with you.
I'm going to vote for Obama simply because I like the chance to at least be part of a very progressive step in history. Who wants to tell their kids one day that they voted against the first black President? Apart from that, I don't really give a crap. The current disaster is on the verge of exceeding our worst expectations. I don't even know if I care about that, but now people I know and somewhat care about are starting to get hurt in all of this chaos. I'm still really pissed off about how the bank bailout is being marketed as a consumer assistance plan.