Here's 60 Minutes on the Mortgage Crisis

Mortgage Servicing Industry

ProPublica has been looking into how homeowners have been treated in the foreclosure crisis. This article deals with how the mortgage servicing industry has dealt with struggling homeowners.

Loan Mod Program Left Homeowner's Fate in Hands of Dysfunctional Industry
by Olga pierce and Paul Kiel - ProPublica

Last February, with 6 million homeowners in danger of losing their homes, the mortgage industry was assembled at a luxury hotel in San Diego applauding themselves—literally.

“As a group, we owe ourselves a round of applause,” said Yvette Gilmore, vice president of loss mitigation at Freddie Mac, citing the industry’s efforts to avoid foreclosures, garnering loud clapping from the ballroom full of bank executives, lawyers and others in the industry.

. . . .

Over the past year, ProPublica has been exploring why the government’s program has helped so few homeowners. So far, we have detailed the Treasury department’s weak oversight [1], and how the administration quietly retreated [5] from a plan to get tough on banks. In part 3, we will discuss reforms that could lead to more help for homeowners.

The stories are based on newly disclosed data, lobbying disclosures, dozens of interviews with insiders, members of Congress, and others. Today we tell the inside story of what happened when the fate of struggling homeowners was placed in the hands of the industry little incentive to help: the mortgage servicing industry.

---

On paper, the government’s Home Affordable Modification Program, or HAMP, was supposed to address one of the main roadblocks to modifying loans: The banks handling most mortgages often have little incentive to avoid a home going into foreclosure since they don’t actually lose money when that happens.

That’s because mortgage servicers, the largest of which are the nation’s largest banks, don’t own the vast majority of the loans they handle. So, they don’t bear the loss if the loan goes to foreclosure. In fact, servicers often make money from foreclosure fees.

“Foreclosure is the path of least resistance inside a servicing shop, because once it goes into that mode, all of the costs are essentially borne by third parties,” said Horne.

But when it comes to making modifications, servicers have to make big investments in staff and infrastructure to work effectively with homeowners. HAMP sought to defray some of those costs by paying servicers $1,000 per modification and up to $3,000 more over time if it was successful.

Before the foreclosure crisis, mortgage servicing was a highly profitable business for large banks. They were paid a flat percentage that more than covered the cost of cashing checks from homeowners. Servicing a typical loan cost the servicer about $48 a year, according to a new Federal Housing Finance Agency analysis, while for a typical $250,000 mortgage, the servicer’s annual fee would be about $625 a year. Given the huge number of mortgages they handled, servicers made tens of billions of dollars in the years leading up to the crisis.

Ideally, “in good times, servicers are using some of the residual income to build out systems and procedures to handle the pressures that come with worse times,” said Fed Governor Raskin. “Unfortunately, as we have seen, this has not happened.”

Instead of investing in technology upgrades or employee training, banks pocketed the profits.

When the default rate tripled, servicers floundered, and almost as soon as HAMP launched it became apparent they weren’t up to the job.

Read the entire article here

A Look Back

I wrote and posted this article at the end of 2008.  It is interesting to look back at it as we enter 2011 - 2 years later - and see how far we have really come.  Remember, at the time we were still being told that we were not in a serious recession and that the outlook for 2009 was good. 

Economic Crisis Continues and Worsens 

As we close out 2008 and embark on our journey through 2009 we need to evaluate what has been and where we are headed.  A look at some recent economic news – while not positive – the knowledge may help us through our journey.  We know for a fact that this is the worst economic crisis to hit our country since the Great Depression and could perhaps be even worse.  We are all in a survival mode and to survive we need the facts.

The New York Times on January 14th reported, in an article written by Jack Healy,   “Stocks Tumble on Retail Sales Slump”.  Here are some excerpts from this article.

The government reported on Wednesday that retail sales fell for a sixth consecutive month in December…..

Sales at department stores, restaurants, gas stations and a host of other retail businesses fell 2.7 percent last month — nearly double what economists had been expecting — and were 9.8 percent lower than sales last December, the Commerce Department reported.

The new retail numbers offered an epitaph for what economists and retailers called the worst holiday shopping season in decades:…

The article said consumers have “holstered” their credit cards implying that many prudently withheld purchases.  I believe the truth of the matter is that the credit card companies “holstered” their credit by freezing, lowering or closing consumer accounts of the average consumer.  However, there are those that still do have cash purchasing power that did prudently withhold purchasing.

“People hunkered down pretty dramatically,” said John Silvia, chief economist at Wachovia. “Yes, everybody celebrated the holidays, but there was far less spending than in prior years.”

Consumer spending, which accounts for more than two-thirds of the economy, has slowed sharply since mid-September as the problems on Wall Street began to spread. With the uncertainty of jobs weighing on consumers, economists do not expect a turnaround anytime soon.

If “more then two-thirds of the economy” is in consumer spending then it appears that the economists not expecting a turnaround anytime soon is accurate.  This being the case then we all need to prepare for the long haul.  It is going to be a rough ride.

The Fed’s beige book, a regular survey of businesses around the country that was released Wednesday, indicated that the economic slump worsened in December.

This is certainly an understatement.

“Overall economic activity continued to weaken across almost all of the Federal Reserve districts since the previous reporting period.” the report added.

And the months ahead will be difficult……

It is a valid warning to all of us.  This is the reality of our current economic crisis.  With so many other factors involved – it is prudent to be aware.

Links to other business headlines in the New York Times  

·                        Rescue of Banks Hints at Nationalization

·                        Stocks Fall Again After a Hopeful Start

·                        Prices Rose Just 0.1 Percent Last Year

Citigroup Reports Big Loss and a Breakup Plan

By ERIC DASH - New York Times

Published: January 16, 2009

This headline comes as no surprise to me.  What is surprising however is that our initial bailout program along with almost $350 billion was to shore up our financial industry.  It was meant to “rescue” these behemoth banks and begin to restore our economy.  What it did instead was to allow banks like this to buy other failing financial institutions, a concept I never could grasp.  How does buying a failing business by another failing business serve to create a profitable one?  My grade school math taught me that two negatives never make a positive.  Obviously not the same math used by our government or the banks.  Math supposedly is a universal language but there must be another universe with an entirely different set of rules.

Let’s look at some of what the article had to say.  For the full story click the link above.

Citigroup capped a devastating 2008 with an $8.29 billion fourth-quarter loss on Friday, as the company comes under mounting pressure from regulators to rethink its financial supermarket model and shrink itself.

Skip to next paragraphWith nearly every part of the company suffering a huge blow,…..

Continuing losses being generated while the taxpayer continues to shovel money into institutions like Citigroup. You have to remember here that they got the TARP funds with additional funds to follow.  In addition, we are absorbing much of their loss.    

One good sign reported by Forbes.com, “In the headlines this afternoon, the U.S. Federal Reserve has barred Citigroup from making new acquisitions until it cleans up its act”. 

The article further went on to say, “A slew of regulatory violations and scandals in the U.S. and abroad have mired the financial giant's reputation,…” .

You must wonder why we are supporting and funding billions of dollars to a company that has “a slew of regulatory violations and scandals….”.  Why are the taxpayers paying for these improprieties allowing the executives to continue earning “behemoth” incomes?

Bank of America Posts Loss as It Gets New U.S. Aid

By LOUISE STORY, ERIC DASH and ANDREW ROSS SORKIN - New York Times

Published: January 16, 2009

Hours after receiving another government lifeline, Bank of America posted a fourth-quarter loss of $1.79 billion on Friday, down from net income of $268 million a year earlier, in a reversal caused largely by growing consumer loan losses.

Skip to next paragraph And bigger troubles came from Merrill Lynch, which Bank of America hastily snapped up in September for $50 billion. A fresh round of write-downs at Merrill pushed that firm into a $15.3 billion loss for the fourth quarter. That was the firm’s sixth troubled quarter since the credit crisis began. Merrill was among the most aggressive — and most harmed — by mortgage investments.

Merrill’s results for the fourth quarter are not a part of Bank of America’s. The merger of the two banks closed on Jan. 1….

“Hours after receiving another government lifeline”!  Not a good sign.  Not only does it bring into question our bailout program and the billions of dollars the tax payer will be paying back for generations, but it brings into question the solvency of our biggest financial institutions.  With all the money being thrown at them – they are still sinking – which indicates that our economy is still sinking, perhaps quicker and deeper then we think.

Now, listen to this as the article continues,

In a conference call Friday morning, analysts asked Kenneth D. Lewis, the bank’s chairman, whether he had regrets that he had agreed to purchase Merrill.

Mr. Lewis said that as Merrill’s fourth-quarter losses mounted, he did re-evaluate whether he should close the deal and whether he could renegotiate the price for Merrill. But, he said, regulators implored him to complete the transaction and said they would provide support.

“The government was firmly of the view that terminating or delaying the closing of the transaction could lead to significant concerns and could result in significant systemic concerns,” Mr. Lewis said. “We did think we were doing the right thing for the country.”

It is shocking to hear that “regulators”, our government, “implored him” to complete the transaction.  It is even more shocking and disturbing to hear that “they”, the government –us the taxpayer – would provide support. 

I am outraged by this.  Bank of America, who loans money and made mortgages to illegal aliens – the only lender to do so – and has credit card interest rates well in the thirty plus percent range, preying on the American public but being supported by, funded by, enlarged by and sustained by the Federal Government.  There should be a public outcry over this as THIS JUST IS NOT RIGHT!

But that’s not all; listen to what Mr. Lewis says:

“This company will generate huge amounts of profit when we get a normal economic environment, not even a great one but a normal one, and so it’s almost directly related to how fast you think the economy will come back,”  

In other words, as long as we continue to support him and keep his bank in business, eventually the company will eventually become profitable – meaning just that much more money in terms of income and bonuses for him.  Why should we be supporting two failing companies, funding their losses, just to keep them in business?  I JUST DON’T GET IT!

But it gets even more outrageous;

In the conference call, Bank of America executives also discussed the government assistance that was announced overnight to help them complete the merger with Merrill.

Two weeks after closing its purchase of Merrill Lynch at the urging of federal regulators, the government cemented a deal at midnight Thursday  to supply Bank of America with a fresh $20 billion capital injection and absorb as much as $98.2 billion in losses on toxic assets, according to people involved in the transaction.

More midnight – after hours – deal making by our government, or shall I say midnight robberies of the public.

It gets even more upsetting when the article continues;

The bank had been pressing the government for help after it was surprised to learn that Merrill would be taking a fourth-quarter write-down of $15 billion to $20 billion, according to two people who have been briefed on the situation, in addition to Bank of America’s rising consumer loan losses.

The second lifeline brings the government’s total stake in Bank of America to $45 billion and makes it the bank’s largest shareholder, with a stake of about 6 percent.

Federal regulators – and I would like to know who they are, their names and positions in our government – were quoted as saying;

“The U.S. government will continue to use all of our resources to preserve the strength of our banking institutions and promote the process of repair and recovery and to manage risks,”  

Imagine if all of us could play high stakes poker and corporate monopoly with virtually unlimited funds – we would all be rich and the economic crisis would be over.  It doesn’t matter how long you lose, eventually with a bottomless pot of money you will begin to win.  So it appears that our government is funding one of the biggest gambling games ever. 

Mr. Lewis had earned a reputation for taking big bets that helped transform NationsBank, a small lender, into a consumer powerhouse with bicoastal branches — and was often accused of overpaying. It snapped up Bank of America and took on its name, then followed with flashy deals for FleetBoston Financial in 2003 and then the credit card giant MBNA in 2006. That was followed by US Trust and LaSalle Bank of Chicago a year later.

Last year, Mr. Lewis’s bank also bought Countrywide Financial Corporation, the troubled mortgage giant that has come to symbolize many of the excesses of the subprime mortgage era. That made Bank of America the biggest player in every major financial service but wealth advice.

Failing companies buying other failing companies – again, the math and logic does not work or maybe it does.  Add one failing company to another you get a bigger failing company.  Add to that yet another failing company and you get and even bigger failed company.  Do that enough times and the government says you are now to big to fail so we will support you with debt that our grandchildren’s children can not repay.  All this for the financial benefit of a very few with no benefit to the public at large.  No Mr. Lewis, you are not doing this for “the country”, you are very definitely doing this for yourself with the help of “the country”.  By the way, that’s me – the public - and I object!

After Bank of America told regulators in December that it might walk away from Merrill because of mounting losses at the brokerage, government officials said they decided they needed to take immediate action to avert a systemic risk.

The systemic risk is allowing mismanaged corporations led by greedy, headstrong and obviously incompetent people to continue this debacle.

Still, the Merrill deal has not been any easy deal for Mr. Lewis to digest. “He made a bet,” said Brad Hintz, an analyst with Sanford C. Bernstein & Company.

He made a bet with our money and the blessing of our government - which seems to only work for the few and continues to worsen this crisis.
Let’s not forget that Merrill Lynch, the failed Wall Street firm was one of the root causes of this crisis.  They were at the forefront of the mortgage meltdown.  They were the innovators, creators and dealers of all the toxic mortgage loan programs and securities that made them billions of dollars.  Question is, where did all that money go if they are on the verge of bankruptcy?    Not even the government has asked that question nor investigated their books.  Hmmmm.

Yes, the betting and gambling all are being done with “our” money which the Fed can print at will.  For every dollar they print, it is another dollar plus interest that we owe to this “other Private Company”.  If gambling with our money is truly the case, and it appears as it is, then is it not a safer bet for that money to be given or made available to you and me and our neighbors?  Would not that money on the street immediately turn the crisis around and put the economy on solid footing?  Of course it would. 

What is missing in this crisis is “money on the street”, not more credit or debt but actual cash – that same cash that comes out of thin air for Citigroup, Bank of America, J. P. Morgan Chase, Merrill Lynch, Bear Stearns and all of their respective executives (sorry Lehman Brothers, you obviously made someone angry so they threw you out of the game).

We are continuing steadily on a road to total economic destruction.  There are no signs of improvement.  The Federal financial experiment is failing as we, real people, are having our lives destroyed.

The New Year Will Be Grim For Many

Recently, I had an argusation (that's a combination of a friendly argument and a conversation) with a very dear and close friend of mine. His point was that the economy is getting better (he says we are in a recovery) and many will feel the affects of this in a positive way.

My position wasjust the opposite. The real and published unemployment rate is still as high and housing prices are still falling.  Not so says my friend. Where I am, he says, real estate values have leveled, there is an increase in spending and there seems to be a recovery.

Well, that may be so where you are (West Palm Beach, Florida) but it is not the case just south of you in the greater Ft. Lauderdale and Miami areas. It is certainly not the case up here in Tampa Bay where unemployment is well over 12% and real estate values in many areas have declined well over 50% with no leveling in sight.

However, my friend did concede that nationwide, real estate values would not level until the job market improves and unemployment decreases. Exactly said I, that is what I have been saying all along. We can't have any kind of real recovery until the housing market improves, foreclosures decrease substantially and the unemployment - and underemployment - situation decreases substantially.

We have, I fear, a second economic disaster looming in the "cloud" (yes, I am not sure what a "cloud" is either but it is used daily in the IT world as a place where stuff is stored...I think).

Yes, a second wave (like in a tsunami) of financial disturbances for the average person in this country and more good deals and profits for our large (too big to exist) corporations.

Of course, all of the conversation I had with my friend was only my opinion and who am I in terms of expertise on the subject (I am just one small victim of the Great Recession which in reality was and still is a Depression). As a famous political science comedian always says after his rant..."I could be wrong".

However, someone at the New York Times feels much the way I do and the New York Times itself feels it newsworthy to publish this opinion.

When people say that the recovery does not feel like a recovery, they are describing reality. The economy is growing, but for many Americans life is not getting better. Unemployment remains high. Home values are depressed. And state budgets are in deep trouble, presaging more layoffs, service cuts and tax increases.

The Times editorial echoes much of my conversation with my friend which also echoes much of my opinion - if not all of it.

So, my friend (I hope you still follow my blogs), do you really think things (the economy and people's lives) are going to be better in 2011?  To view another opinion please read The Economy in 2011 in the New York Times on line...click here.


One last word of advice to those of you who represent us in the House of Representatives and the Senate (notice that the House is the House of REPRESENTATIVES).  Begin your new term by truly representing the people not your own agendas be they Democrat or Republican.  Leave your personal agendas and partisan politics at the front steps of the building you work in 9you know, the one with the large dome on top).  This is no time to commit yourselves to defeating the other party at all costs.  All Costs - in this case - means all the people of this country, especially those in the middle and lower classes you commonly refer to as the 'MAJORITY".


Of course this is just my opinion again.  I could be wrong.

Residential Mortgage Rules

The following information by Stephane is excerpted from FedUpUSA

Congressmen Joining Fight To Stop Mortgage Servicer Fraud

Congressman Brad Miller is sending the following letter to the financial regulators, and is currently rounding up additional signatories:

The Honorable Timothy Geithner Secretary of the Treasury Department of the Treasury 1500 Pennsylvania Avenue, N.W. Washington, D.C.

The Honorable Edward DeMarco Director (Acting) Federal Housing Finance Agency (FHFA) 1700 G Street, N.W. 4th Floor Washington, DC 20552

The Honorable Sheila Bair Chairman Federal Deposit Insurance Corporation 550 17th Street N.W. Washington D.C., DC 20006

The Honorable Ben S. Bernanke Chairman Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue N.W. Washington, DC

The Honorable Mary L. Schapiro Chairman Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549

The Honorable John Walsh Comptroller of the Currency (Acting) Administrator of National Banks 250 E Street, S.W. Washington, DC 20219

Dear Secretary Geithner, Chairman Bair, Chairman Shapiro, Acting Director DeMarco, Chairman Bernanke and Controller Walsh:

We are writing to urge that any exception to the credit risk retention requirements of section 941 of the Dodd-Frank Act include rigorous requirements for servicing securitized residential mortgages.

The Act requires that securitizers retain five percent of the credit risk on mortgage-backed securities. The requirement is the subject of a study by Christopher M. James published by the Federal Reserve Bank of San Francisco dated December 13, 2010, and entitled “Mortgage-Backed Securities: How Important Is ‘Skin in the Game’?”, which finds that the requirement will have the intended effect of reducing “moral hazard” and significantly reducing the loss ratios on mortgage-backed securities.

The Act provides for an exception, however, for “qualified residential mortgages” and for other “exemptions, exceptions, and adjustments” to the risk-retention requirement. We strongly urge that you use great care in allowing any exception to the risk retention requirement, and that you be vigilant in assuring that any exception not defeat the purpose of the requirement. Recent experience in financial regulation has been that seemingly modest, reasonable exceptions have swallowed the rules and allowed abusive practices to continue unabated. In considering any requested exception under section 941, please remember that the advocates for rule-swallowing exceptions to other financial regulation have not been entirely candid with regulators or legislators on the likely effect of those exceptions.

The rules adopted pursuant to section 941 must, of course, require rigorous underwriting standards for “qualified residential mortgages” or any other mortgages excepted from the risk retention requirement, but underwriting requirements are not enough. The rules must also address the servicing of securitized mortgages. Much of the turmoil in the housing market, which is largely responsible for the painfully slow recovery, is the result not just of poorly underwritten mortgages, but of conduct by mortgage servicers.

We direct your attention to the “Open Letter to U.S. Regulators Regarding National Loan Servicing Standards” dated December 21, 2010, and signed by 51 people with extensive knowledge of mortgage servicing (the “Rosner-Whalen letter”). We strongly urge that you consider closely the recommendations included in that letter.

The Rosner-Whalen letter makes sensible recommendations regarding the treatment of payments by homeowners, “perverse incentives” in servicer compensation, mortgage documentation, and foreclosure forbearance during mortgage modification efforts.

We especially urge that any exception require that servicers modify mortgages pursuant to established criteria to avoid foreclosure where possible. The statute governing “Farmer Mac” mortgages provides a useful example of such criteria. See 12 U.S.C. 2202a (“Restructuring Distressed Loans”). Foreclosures are catastrophic for homeowners, holders of mortgage-backed securities, the housing market, and the economy as a whole.

The conduct of servicers is largely responsible for much unnecessary hardship. A requirement that servicers modify mortgage according to established criteria to avoid foreclosure can avoid that hardship in the future. Neutral, established criteria will also avoid “tranche warfare” between classes of investors.

We also especially urge that any rule for securitized mortgages require that servicers not be affiliated with the securitizer. There are obvious potential conflicts of interest, and no apparent countervailing justification. At a recent hearing of the House Financial Services Committee, several witnesses from major servicers were unable to offer any advantage in being affiliated with securitizers, other than to offer “full service” to customers. That justification is entirely unpersuasive. Homeowners may select the bank with which they have a credit card or a checking account, but they have no say in who services their mortgage.

In fact, community banks and credit unions have been reluctant to sell the mortgages that they originate to “private-label securitizers” for fear that the mortgages will be serviced by an affiliate of a bank, and the servicer will use that relationship to “cross market” other banking services to the homeowner. Requiring that servicers be independent of banks, therefore, would advance the goal of increasing the availability of credit on reasonable terms to consumers.

The Dodd-Frank Actives provides you ample authority to reform servicing practices, and regulation of mortgage securitization will be ineffective without such reform.

Sincerely,

Rep. Brad Miller [and others]

See the article and letters here

William Black takes on Andrew Kahr on Sub-Prime Lending

In a two part series, Mr. Black takes on Andrew Kahr's assertions that mortgage applicants should be prosecuted.

Here's an excerpt from The Huffington Post:

Lender's Put the Lies in Liar's Loans
by William K. Black - The Huffington Post

I have noted before a family maximm -- one cannot compete with unintended self-parody. Andrew Kahr has recently written a column in the American Banker entitled "Spread the Word: Lying to Banks is Illegal." Mr. Kahr is one of the architects of subprime lending. He warns:

Federal law provides that anyone who knowingly makes a false statement to a[n] ... insured institution ... shall be fined not more than $1,000,000 or imprisoned for not more than thirty years, or both.

To say the least, this criminal law, intended to protect banks and hence the deposit insurance fund, is very, very rarely enforced against consumers. Why?

How is a U.S. attorney to know that a customer has defrauded a bank by giving false information, unless the case is referred to him or her by the bank? And we're not doing that, at least not for mortgages, credit cards or other everyday consumer lending.

Hence, the plethora of consumers giving willfully and materially false information to banks on applications and during loan servicing has mushroomed. With "liar's loans," this went from a cottage industry to an epidemic.

Mr. Kahr neglects to mention that "insured institution[s]" are required to file Suspicious Activity Reports (SARs) (criminal referrals). As the FDIC explains:

The U.S. Department of the Treasury's financial recordkeeping regulations (31 CFR 103.18) require federally supervised banking organizations to file a SAR when they detect a known or suspected violation of federal law meeting applicable reporting criteria.

Collectively, banks make massive numbers of SARS filings with regard to mortgage fraud, over 67,000 annually, but a mere 10 institutions file 72% of those referrals. The typical nonprime lender deliberately violates its legal requirement to file a criminal referral when it discovers mortgage fraud even though that practice would be irrational for an honest lender. The federal regulatory agencies have not taken any effective action against these pervasive violation of their rules despite an "epidemic" of mortgage fraud that drove the ongoing financial crises.

The remainder of this article can be read here
Part II of this article can be read here

The Wall Street Conspiracy...As broadcast on TruTV's "Conspiracy Theory"

Note:  This was first published in our sister publication - GoldmanSachs666.com.  The information is not new for some of us but it is information needed to be seen and heard by all of us.  It will be simul posted on all of our sister sites.

This is a MUST SEE program.

Jesse Ventura, former Governor of Minnesota and  host of TruTV's program Conspiracy Theory exposes the scam that brought the country into financial ruin.  He exposes - through interviews with Wall Street insiders such as Nomi Prins, former Goldman Executive turned whistleblower and Matt Taibbi reporter for Rolling Stone and author of the "Giant Vampire Squid" label he placed on Goldman.  Also interviewed such people as Rep. Ron Paul in reference to the Federal Reserve offering some very important information which some of us already know but all need to know.

This program exposes the criminal activities, the fraud and the cover ups that lead to the Great Recession we are still in the midst of.

This is a must see program already viewed by thousands but should be viewed by all Americans.  We Americans have been "had".  We have been "duped".  We have been and robbed.  In fact, we are still being robbed.  As I have been saying, a systematic program of stripping Americans of all their assets - money, property, jobs and entitlements - leaving us totally dependent on a government controlled by Wall Street, the Federal Reserve and their true owners - foreign bankers whose families were involved in its inception back in 1913 and will continue control until we, as a nation, decide to dissolve the Federal Reserve.
There have been thousands of views already.  If you like it like I do, then please forward it as well.  America MUST KNOW the truth.  The information in this program just further verifies what I and others have been writing about for years.

Wall Street Conspiracy with Jesse Ventura...Part 1


Part 2


Part 3