Maybe the American Securitization Forum ought to do its homework before making emphatic and not very well founded claims.
Right before Thanksgiving, the ASF released its long-awaited white paper, which argued, basically, that industry standard practices for conveying notes (the borrower IOUs) to securitization trusts were sound. Curious readers new to this can read the long-form version, but the overview is that the ASF contended that industry standard practices conformed with generally applicable law (the wee problem is that this argument simply ignores the far more specific requirements of their own contracts). That meant, per the ASF, that the trustees, acting on behalf of securitization trusts, could proceed with foreclosures precisely because the trust did possess the note.
Less than a week later, a court decision in Kemp v. Countrywide reveals that a Countrywide executive testified that Countrywide did not transfer notes to the trusts, which was the foundation of the ASF argument, and this was its normal practice (Bank of America did issue a not-very-convincing denial). That confirms what we’ve heard and reported about Countrywide and other major subprime originators. Needless to say, this made the ASF white paper look more than a tad ill informed. The ASF had said everything was hunky-dory because the trusts held the notes; now it has egg on its face because the biggest player in the business said it, not the trusts, possessed them.
Nevertheless, ASF executive director Tom Deutsch on Wednesday, before the Senate Banking Committee, offered a strident series of declarations in his written testimony:
Ultimately, we find that the conventional process for loan transfers embodied in standard legal documentation for mortgage securitizations has been adequate and appropriate to transfer ownership of mortgage loans to the securitization trusts in accordance with applicable law and contract. Since loan transfers have generally been effective, all of the dire consequences that a few commentators have speculated on fade away, given the faulty premise that they start from. Moreover, a number of the concerns that have been raised that securitization professionals have uniformly opted out of use of laws such as the Uniform Commercial Code (“UCC ”) to set a higher bar for transfers, but then subsequently and systematically failed to meet that higher bar, appear on their face to be illogical assertions and patently false….Moreover the concerns that have been raised have not been supported by substantiation that there are in fact any material signs of systematic fails in the system. Indeed, the origin of these concerns is not clear: they are not the result of a series of court cases supporting the arguments advanced and appear to be largely the result of academic theories.
Deutsch’s testimony focused on the analysis of Georgetown law professor Adam Levitin, who has offered extensive and well supported arguments as to why the problems with mortgage transfers in securitizations are serious and not easily remedies. By personalizing his attack to such a high degree, Deustch appeared to be trying to create the impression that Levitin is a lone critic, which is far from the case.
We called Deutsch’s testimony “monstrous whoppers”. And unlike the first ASF paper, which the Kemp v. Countrywide story challenged in less than a week, the the new, improved ASF argument took a body blow the very next day.
Per the extract above, Deutsch kept asserting that the failure of the parties to the securitization to adhere to their own contracts was not in fact a problem, there was no court evidence, these concerns were the mere natterings of worry-wart academics. We pointed out that there was proof in thousands, if not tens of thousands, of court decisions on consumer cases to the contrary. But you don’t have to take that on our word. On Thursday, the mere day after the dismissive Deutsch remarks, Judge F. Dana Winslow of New York in testimony before the House Judiciary Committee described how there is substantial uncertainty and widespread problems with title, standing, ownership, not to mention bad affidavits and improper service, in foreclosures. And many of his remarks directly contradict what Deutsch asserted the day prior.
For instance, Deutsch asserted, absurdly, despite clear contractual requirements that the notes be endorsed to show the proper chain of title, that really was not necessary. Judge Winslow is not convinced:
Gaps in the chain of title. Missing assignments — effects on prior unnamed mortgagees and their rights. I have obtained from the County Clerk printouts of mortgagee title that have differed substantially from the information provided by Plaintiff Mortgagees in foreclosure applications…
Can deficiencies be addressed by an Allonge, with or without the approval or
signature of the Homeowner? This question has not been answered by the judiciary or the legislature.
We’ve noted that allonges (an attachment to a note for affixing signatures; this has become the new preferred route for on-the-ball foreclosure mills to create the impression that the transfers were done correctly and on a timely basis as required in the governing agreement, the Pooling and Servicing Agreement). Interesting to see that the judge has reservations about them.
Most important, Winslow specifically disputes the argument made by the ASF, that they can rely upon Article 3 of the Uniform Commercial Code as the rational for ignoring the provisions of their own contracts (Article 1 of the UCC provides for parties to contract for different procedures, such as the ones stipulated in the PSA):
UCC Article 3. Some Plaintiff Mortgagees have argued that their status as the holder of a negotiable instrument (the Note) under UCC Article 3 allows them to proceed in foreclosure without proof of the chain of title (i.e., endorsements, intermediate assignments of the Note and Mortgage). Problems: first, a Mortgage is not a negotiable instrument under UCC Article 3; second, the endorsement in blank procedure, frequently used by a Plaintiff Mortgagee, does not necessarily create the elusive negotiable instrument; and third, in many cases, the Plaintiff Mortgagee cannot produce the Note.
So what will the ASF do to dig itself out of this new hole? This analysis is from an impartial party who has reviewed hundreds of cases with problems and has serious doubts with the ASF’s position on both assignment and endorsement in blank. Failure of many judges to accept either one, let alone both, creates huge problems for trusts seeking to foreclose. And if you think I am overstating, consider the judge’s overview comment:
Standing has become such a pervasive issue that I frequently use the term “presumptive mortgagee in foreclosure” to describe the Plaintiff Mortgagee.
In other words, the problems with standing are so widespread that the judge no longer assumes the party showing up to foreclose really has the right to do so.
The testimony is simply damning and goes through a long litany of deficiencies at every step of the process. One example:
Plaintiff Mortgagee “Bad faith.” CPLR 3408(f) – Plaintiff Mortgagees must participate in mandatory settlement conferences, and negotiate in good faith for a mutually agreeable resolution, including loan modification, if possible.
Timely response – A Plainliff Mortgagee must timely acknowledge the information provided by the Defendant Homeowner and respond to justified offers of modification. There are many instances o f a Plaintiff Mortgagee refusing to consider a loan modification because the Defendant Homeowner’s financial information was not up-to-date, even though the delay was due to the Plaintiff Mortgagee’s own failure to timely respond to the Defendant Homeowner.
So will we see the ASF issue yet a new paper to refute this damaging testimony? How will the ASF respond to this suggestion of problems? Attack the judge too? Given the ASF’s advanced state of denial, it might take a paper a week before they engage the issues that are well known and well documented in tens of thousands of consumer cases across the US.
It’s high time that the securitization industry recognize that bluster and attack the messenger is not going to make deep seated problems vanish. It’s time they admit to the widespread failings and work towards solutions, rather than persist in being part of the problem.
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ASF will produce another document denying the problem.
Meanwhile it will run to the regulators and Congress and say if “originators have to buy back all the private mortgage deals that were fraudulently sold, it will be a repeat of the credit crisis. Therefore, you need to grant us absolution for our sins.”
The regulators and Congress will see the potential for trillions in losses and the collapse of a major portion of the banking system and do what they always do: bail them out at the taxpayer expense!
Please note, while I hate bailouts, this is a bailout that should happen. The only difference with the previous bailouts is that fraud cases and forfeiture of bonuses should be pursued against every Wall Street participant that benefitted directly or indirectly since say 2004 when the fraud began. In addition, now that the government has to step in and rescue the TBTF, the government can now break them up into little pieces.
Please note, while I hate bailouts, this is a bailout that should happen. RF
How about we bailout the victims, the entire US population including savers, instead of the villains, the banks?
Screw the banks, let them fail, take them over as a goverment controlled entity or carve them up like a thanksgiving turkey….
Actually, this bailout will be good for the taxpayers and savers. It will be very bad for the individuals who perpetrated fraud.
Taxpayers will benefit because with the bailout the mortgage foreclosure crisis and loan modifications can really be addressed.
Savers will benefit because with the bailout the Fed no longer has to pursue zero interest rate policies to try to recapitalize the banks. Interest rates can return to a more ‘normal’ level.
The individuals who initially benefitted from the fraud, and this includes the senior management of these institutions, will find that they get to write very sizable checks to the US government (upwards of 100% of their compensation since say 2004). These checks should help to defray a small portion of the actual cost of the bailout. However, these checks will have the symbolic impact of showing that these individuals were not above the law.
Finally, with the bailout, the government will be in the position to break up the TBTF. Going forward there will be a lot more financial institutions that are the right size to regulate.
You don’t seem to understand this government at all.
A hint: It could have done any and all of those things (and lots more) at will, any time it chose, right from the start, and can do them all at will today.
So why do you think this government didn’t do so before but would do so in a new bailout? You think they’ve learned a lesson? Had a change of heart? Conscience bugging them? No longer want to be bankster flunkeys?
This government is no longer anything but a terminal kleptocracy.
The banks have a major problem here. No amount of allonges will cover up this issue. We will find the ability to challenge these fake docs, just like we have found all the others.
The banks have taken money from investors to fund the loans, have taken money from the homeowner to service the loan, now are taking ridiculous amounts in fees and other tack ons….and yet they think they can also take the house FOR FREE and sell it and retain that money as well.
I think I will try to forge a title to my neighbor’s car and see how far that will get me. I see the U.S. has become lawless….might as well see if I can hightail it with a nice BMW…or two.
Justice Winslow’s statement was revealing, and unusual, in coming from a sitting judge. I am looking for the video of yesterday’s hearing – I am unable to find a working video. Note-there is another hearing by the Judiciary Committee scheduled for Thursday, December 8.
Why did she attend the hearing? She stated in opening that approximately 11% of all homes in Nassau County (where her court is situated) are either in foreclosure or have been in default for 90 days or more.
There are two areas missing from her presentation:
1.Reference to the issues raised by New York attorney Thomas Adams and Professor Ira Bloom, professor of Law at Albany Law School, as discussed in Yves’ post at http://www.nakedcapitalism.com/2010/12/american-securitization-forum-tells-monstrous-whoppers-in-senate-testimony-on-mortgage-mess.html#comments. In this regard, note that the Justice ignored the issue of whether the Trust was qualified to do business in NY – since the Trusts are NY Trusts, and this issue would not appear to apply in NY cases.
2.Abusive servicing practices by servicers such a delaying posting of payments and applying payments first to penalties rather than P&I.
Also, the Justice referred to foreclosure counsel representing both the primary and second lien holder. I assume in some cases, the plaintiff’s attorney appear for both as she indicates, if the second lien holder is foreclosing. I think the larger issue is that the servicer running the foreclosure is owned by a second lien holder, and that is not disclosed to the court, creating an undisclosed conflict for the plaintiff’s attorney. Second, in some ways the servicer is a party in interest with conflicting interests, and that as well is not disclosed to the court. So, the attorney may have 3 conflicting interest – not disclosed to the court. The judge pointed out that many attorneys do not even know who they represent – an ethical problem and I would think enough to toss out the case.
Mineola, New York is just a short train or limousine ride from Manhattan – I wonder how many of the securitization expert law firms take the short trip out to her courtroom to appear in court and help the judge sort out these issues.
PS
For those of you not from NY, the highest court in NY State is the Court of Appeals (normally named the Supreme Court in most other states). The Supreme Courts in New York are the primary trial court (except for smaller matter in the Civil Court). The judges are called “Justices”. NY Supreme Court Justices are elected.
She’s not going to even see those issues unless defense counsel raises them. Both are costly. You need experts to make the NY trust argument. In the case in Alabama I pointed to the other day, each side has spent over $200K. And only the consumer lawyers hired expert witnesses. This on a $100 K mortgage. It’s only after there are more affidavits and court testimony on the NY trust theory that it will be cheaper for regular consumer level attorneys to pursue.
You have the same issue with servicing abuses. It’s an incredible pitched battle to even get the servicer to release the records, and then they are often incomprensible. In the Senate Banking Committee hearings (first installment) IIRC the lawyer from the Center for Responsible Lending said it took two years to get the records in one consumer case. And then you often need to hire a forensic accountant to testify, you need a credible expert to present the finding, which is the bank’s records v. the consumer payments.
Much easier to fight on standing issues if there is a screw up on that front too than the real issues.
I understand, Yves.
I was not being critical of the judge. Perhaps she will read this blog and then see the other issues.
The issues raised are way more sophisticated than most state court litigators are comfortable with, of, if they understand, are willing to put before busy, short attention-span, judges.
Oops
It is Justice Dana Winslow.
Winslow’s testimony is on video (RealPlayer) at:
http://judiciary.house.gov/
His testimony starts at 1:07. Then a break.
He answered questions at 2:24, 2:42, 2:51, 3:05, 3:57, 4:11(MERS),4:16, 4:21, 4:29,
I point you to 4:13:20 pretty much demolishes MERS and their attempts to act as as a foreclosing lender. AT 4:17 he described how MERS morphed.
Also, see 4:14 where Julie Williams of OCC tried to defend MERS, and then say that that is not a federal issue, and described it as a “modern” system. She was most disappointing – see 4:32, 4:34 where she tries to describe why they never were aware of the documentation issues. The OCC was the one that preempted state regulation of mortgage fraud a few years ago – now they seem to say they have no power and that this is a state issue. It is astonishing that she never referred to the REMIC issues – see below.
The government witnesses see this as a documentation issue – none seemed to indicate the more serious nature of the problem, including fouling the real estate recording system and the problems of the REMIC trusts. Not that I listened to every word, but no questioners mentioned the REMIC issuers. Also, they seem to be blaming the “servicers”, without realizing that the REMIC trustees and sponsors created the problem, and the passive nature of the trusts as to the modification deadlock.
I think they are terrified by the Trust issues.
The second panel was rescheduled and did not testify. That would include Professor Peterson.
Justice Winslow is retired and is male.
You are correct
I actually wrote that it was Mr. Justice Winslow.
I put greater than and less than signs around the “Mr.”
And, it did not appear when posted.
He may be retired, but sure acts like he is still sitting.
The judge is a man and it is not retired. sitting on the bench right this moment
This is going to take a lot of scrutiny: we’re going to have to watch very carefully for the quiet add-on to some omnibus bill (the reauthorization is a prime target) that bails out MERS and retroactively authorizes all the fraud and theft.
Global “fix will be nearly impossible. States rights and all. Will also be a tough political sell. You can’t rewrite centuries of property law. As the crisis comes to a head, there will be de riguer whining and lobbying and threats of apocalypse, but at the end of the day it will be receivership.
The notes weren’t properly transferred on a systemic basis. I know this to be true based on a lot of research and conversations with high level TBTF executives. All the proof hasn’t come to light yet, but it will/is.
As we all contemplate what the future would look like, how bout we cut 60 million American families loose from their mortgage. Would that be a stimulus?
Say all the proof of notes not being transferred comes to light, and it becomes common knowledge. Then what? I understand investors have legal right to putback loans, and statute of limitations should pressure them to challenge banks soon but they’re not doing it now, why would they do it later?
Feds are taking a do-anything-to-keep-banks-healthy approach to financial crisis. Its unquestionable the banks engaged in reckless behavior, but I question whether they will suffer much damage from this…
Exactly. But who the hell is going to reign them in? ie Runaway train, what do the people do? Write letters to Bernie Sanders?
Smith’s blog gives some morsel of hope because a Judge actually appears to be carefully deliberating, if that is the correct term. If I’m reading the news today correctly. it appears unemployment has once again ticked upwards.
As we all contemplate what the future would look like, how bout we cut 60 million American families loose from their mortgage. Would that be a stimulus? viking
Spoken like a true Viking, bold!
But let’s bailout the savers too with an equal amount of debt and interest free United States Notes. And to prevent an inflationary spiral, banks should be put out of the counterfeiting business via a 100% reserve requirement on new loans.
As we all contemplate what the future would look like, how bout we cut 60 million American families loose from their mortgage. Would that be a stimulus?
How about we cut ourselves loose. Stop paying the mortgage. Stay in the house. Keep paying the property tax.
Jubilate in Place.
I realize more than a few are confused by how we arrived at this execrable point, so a quick refresher is in order to cover the predatory legislation and predatory jurisprudence involved:
1994: Interstate Banking Law passed
1994: Supreme Court decision: Central Bank of Denver v. First Interstate Bank of Denver, saying that plaintiffs cannot sue investment banks, accountants and attorneys for aiding and abetting securities fraud.
1995: The above SC decision legislated into law by the US Congress — Private Securities Litigation Reform Act
1999: Passage of the Gramm-Leach-Bliley Financial Services Modernization Act, allowing bank holding companies and finance holding companies to own commercial banks, securities firms and insurance companies, allowing for ultra-monopolies and financial manipulation at extraordinary levels.
2000: Passage of the Commodity Futures Modernization Act, removing anti-fraud and anti-manipulation laws and regs, killing oversight for OTC credit derivatives, and legalizing single stock futures. This allowed ultra-debt-leveraging, thus ultra-leveraged speculation.
During those 7 years, JPMorgan Chase and the Rockefeller Foundation-founded Group of Thirty was pushing for removal of legal risk pertaining to securitizations and credit derivatives, and their widespread adoption.
Must see vids:
[Swedish Prosecution Authority on Wikileaks’ warrant: Weird]
http://www.youtube.com/watch?v=SLy2UOaA0CU&feature=player_embedded#!
[Chris Hedges]
http://www.youtube.com/watch?v=bYCvSntOI5s
[Russ Baker v. George Bush: Family of Secrets]
http://www.youtube.com/watch?v=03ZkqfRsiRo
[The Federal Reserve]
http://www.youtube.com/watch?v=PTUY16CkS-k&feature=player_embedded
[Media and Propaganda]
http://metanoia-films.org/watchonline.php
YVES! Something to look into!!
I came across this while going through the TILA hadbook from the OCC.
http://www.occ.gov/static/publications/h….
Quote:
Notification of Sale or Transfer of Mortgage Loans [Section 226.39]
No later than 30 calendar days after the date on which a mortgage loan is acquired by, or otherwise sold, transferred, or assigned to a third party, the creditor that is the new owner or assignee of the debt (“covered person”6) shall notify the borrower in writing of such transfer and include:
Identification of the loan that was acquired or transferred.
Identity, address, and telephone number of the covered person who
owns the mortgage loan.
Acquisition date recognized on the books and records of the covered person.
How to reach an agent or party having authority to act on behalf
of the covered person.
Location where the transfer of ownership of the debt to the covered person is recorded (note, however, that if the transfer of ownership has not been recorded in public records at the time the disclosure is provided, the covered person complies with this paragraph by stating this fact).
At the option of the covered person, any other information regarding the transaction.
This notice of sale or transfer must be provided for any consumer credit transaction that is secured by the principal dwelling of a consumer. Thus, it applies to both closed-end mortgage loans and open-end home equity lines of credit (HELOC). The notification is required even if the loan servicer remains the same.
6 A “covered person” means any person, as defined in 12 CFR 226.2(a)(22), who becomes the owner of an existing mortgage loan by acquiring legal title to the debt obligation, whether through a purchase, assignment, or other transfer, and who acquires more than one mortgage loan in any 12month period. For purposes of this section, a servicer of a mortgage loan shall not be treated as the owner of the obligation if the servicer holds title to the loan or it is assigned to the services solely for the administrative convenience of the servicer in servicing the obligation. See section 226.39(a)(1).
I came across this while going through the TILA hadbook from the OCC.
http://www.occ.gov/static/publications/h….
Quote:
Notification of Sale or Transfer of Mortgage Loans [Section 226.39]
No later than 30 calendar days after the date on which a mortgage loan is acquired by, or otherwise sold, transferred, or assigned to a third party, the creditor that is the new owner or assignee of the debt (“covered person”6) shall notify the borrower in writing of such transfer and include:
Identification of the loan that was acquired or transferred.
Identity, address, and telephone number of the covered person who
owns the mortgage loan.
Acquisition date recognized on the books and records of the covered person.
How to reach an agent or party having authority to act on behalf
of the covered person.
Location where the transfer of ownership of the debt to the covered person is recorded (note, however, that if the transfer of ownership has not been recorded in public records at the time the disclosure is provided, the covered person complies with this paragraph by stating this fact).
At the option of the covered person, any other information regarding the transaction.
This notice of sale or transfer must be provided for any consumer credit transaction that is secured by the principal dwelling of a consumer. Thus, it applies to both closed-end mortgage loans and open-end home equity lines of credit (HELOC). The notification is required even if the loan servicer remains the same.
6 A “covered person” means any person, as defined in 12 CFR 226.2(a)(22), who becomes the owner of an existing mortgage loan by acquiring legal title to the debt obligation, whether through a purchase, assignment, or other transfer, and who acquires more than one mortgage loan in any 12month period. For purposes of this section, a servicer of a mortgage loan shall not be treated as the owner of the obligation if the servicer holds title to the loan or it is assigned to the services solely for the administrative convenience of the servicer in servicing the obligation. See section 226.39(a)(1).
Viking, I’m getting page not founds on both of those.
The main OCC web page says the web page is down for scheduled maintenance. HMMMMMMM.
Yves, thanks for keeping me informed. I started following this mess about three months ago. I am sending everyone I know to your site to get informed.
I was literally screaming at the computer when the ASF thug was testifying on Wednesday. Outright lies.
Do you think there is a solution to this fiasco that wont harm further a person like me who is paying their mortgage and not yet under water?
Am I right to be very concerned that after I pay off my mortgage I will still be on the hook somehow or will be unable to sell the house? What is the best case scenario to fix this?
go here:
http://www.occ.gov/occsearch/Search.aspx?output=xml_no_dtd&client=OCC_Main&proxystylesheet=OCC_Main&entqr=0&ud=1&sort=date%3AD%3AL%3Ad1&site=All_OCC&ie=UTF-8&oe=UTF-8&filter=0&q=lending%20act%20tila&Submit=Go&access=p
download second PDF doc in list
viking, take a look at this comment from last month by tom bokuniewicz. He makes reference to exceptions to Section 226.39.
http://www.nakedcapitalism.com/2010/11/more-frauds-on-the-court-bank-of-america-foreclosing-improperly-in-name-of-bank-on-securitized-deals.html#comment-225320
It’s been asserted that MERS only tracks mortgage servicing rights. The notes stay in warehouses until presented in FC court. The mortgage is recorded once in MERS’ name. Allonges and/or assignments are fabricated to account for the servicer’s ‘standing’ to foreclose. But does anyone record the mortgage when the fabricated, back-dated assignment is made from MERS (or prior entity) to the foreclosing bank or trust?
——-
In case you missed it, there was discussion of notes in warehouses on this post: http://www.nakedcapitalism.com/2010/11/more-on-bofa-employee-damaging-admissions-re-failure-to-convey-mortgage-notes.html
Is it possible that WF consolidated their notes to a warehouse in Mendota Heights, MN? Near LPS?
AR,
MERS would not appear to give an out here. MERS only registers the mortgage, which is the lien. The note, which is the loan, is what is traded or sold. The OCC language seems to require notification within a certain time frame upon sale of the loan, irrespective of whether the note was actually moved physically.
“Problems: first, a Mortgage is not a negotiable instrument under UCC Article 3; second, the endorsement in blank procedure, frequently used by a Plaintiff Mortgagee, does not necessarily create the elusive negotiable instrument;”
The mortgage note is a negotiable instrument. Its status as such isn’t “created” by the endorsement process; that process is possible because it’s a NI.
His comments just seem flat-out bizarre to me, so I assume I’m misunderstanding or something.
SECURITIZATION AND THE STATE OF FETID ROT…
as usual, the Yves group here is kicking butt and taking names…well, maybe not kicking butt quite yet, but making piercing , insightful statements. I feel as frustrated as you all do. The big thing is to get to CRITICAL MASS. DO NOT QUIT FOR GOD’S SAKE!!! YOU ARE HEROES in my book. KNOWLEDGE IS POWER. THE ESSENCE OF THIS KLEPTOCRATIC DANCE OF THE MACBRE IS THE SEURITIZATON PROCESS ITSELF. NEXT STOP: FIAT MONEY. BUT NOW IT IS THE VENALITY OF SECURITIZATON!
While all this discussion is very interesting, and Yves has clearly explained how the banksters have screwed up the system (Tanta at Calculated Risk was describing this two years ago), I’d like to know who is going to force the banks to obey the law? The judges? All of them? You don’t think that most judges are just going to side with the banks and say the problems are technical and allow the banks another chance to produce better forged documents? Take a look at what’s happening in Florida. I can imagine one or more State Attorneys General holding some banks to account, but I’ll bet it only happens in a few individual cases, at best. Or the SEC imposing fines of a couple of million on the banks, which will be paid by the shareholders anyway, and won’t affect the bonuses.
Will the banks begin to work faster on short sales??
You know, if we did just two little things our entire financial system would grow legs again and families would not lose their homes anymore to banksters. #1 Get rid of MERS. Send them back to hell. But first make them pay every county in every state for every filing fee or tax they evaded in their phoney land registry fiasco. #2 Sanction the banksters and their lawyers. Make them follow laws. Whatever the penalty is for fraud, perjury, forgery, preditory lending,rico,ect start dealing it out and stop babying these banks. Make them PAY. stop changing their diapers for gods sake!