Why the government still can't stop ex-sub prime bankers or scammers from destroying homeowners
In the fall of 2008, news stories about “scammers” taking advantage of homeowners at risk of foreclosure started appearing frequently in the media. I remember watching a prime-time news magazine program, I think it was 20/20, that was airing a story about a shady looking middle-age man in Denver, hurriedly walking from a small, strip mall store front to his car, his hand covering his face, as a reporter tried to ask him questions that he obviously did not plan to answer.
The story involved a company that had charged a handful of homeowners several thousand dollars to help them get their mortgages modified. The core message being delivered by the show’s host was that the homeowners had been victims of a scam because, as a couple of homeowners interviewed were saying, their loans had not yet been modified.
I remember wondering how in the world such a story had become the subject of a national television program. I mean, “Three homeowners get ripped off by small business inDenver,” is not usually the sort of event that makes national headlines. The clear implication was that this case was emblematic of a widespread problem, but nothing further was offered in the way of proof… no statistics, no additional facts… just statements about how homeowners should NEVER pay anyone up front to help them get a loan modification because in all cases “they” were “scammers.”
I also remember a newspaper story with a large photo of a young couple with a baby in arms and maybe a four year-old standing at Dad’s hip… a white picket fence was in the background… and a for sale sign in the yard. I can sum up the story in a single sentence: Eight months ago the couple had paid a firm $1,000 to help them get their loan modified… and that’s why they were now losing their $300,000 home.
I remember thinking how ridiculous that sounded. I thought about the time my wife and I paid a contractor $2500 and he never came back to work on our deck. We were plenty angry, all right, but we didn’t even come close to losing our home because of it.
Now, at the time I was spending my weekends interviewing homeowners who had saved their homes from foreclosure, and the reoccurring theme was: “We tried contacting our bank for a year and got nowhere, so we hired a mortgage expert or lawyer for roughly $3,000 and he or she saved our home from foreclosure.”
In addition, I visited with several mortgage experts back then, and they had let me sit by their side as they contacted banks on behalf of their clients… with their client’s permission, of course. So I knew that calling one’s bank to apply for a loan modification was not an easy thing to do. I remember once sitting there for two and a half hours after being placed on hold, only to hear the phone go dead.
I can’t tell you the name of the bank in question, except to say that it was a “bank,” and its name started with “IndyMac”. You’ll have to put it together from there.
Within a few months, the number of stories in the media warning homeowners about “scammers” increased to the point that one might have easily started to believe that tens or even hundreds of thousands of these “scammers” had overrun the country.
At the time, I found it very hard to believe that there were large numbers of such “scammers.” I mean, how many people would be willing to take advantage of working class families, many of whom had lost jobs and now were at risk of foreclosure? What would be next, mugging the elder-blind?
Many told me that I was naïve, but I just couldn’t believe that all of a sudden there were that many people willing to steal three grand from a family at risk of losing their home.
I’m not saying that such aberrations never happen in this country, but it’s rare. Our society simply doesn’t produce that many people willing to commit such despicable acts. Thousands might be willing to rip-off the rich fat cats, or big companies… but working class families losing homes? How many would take a job doing that?
Well, apparently… quite a few.
After two and a half years spent covering the financial and foreclosure crises, I have come to accept that there are a whole lot more people in this country willing to take advantage of homeowners at risk of foreclosure than I would have ever thought possible. In fact, there’s no question that if you throw a dart at the front page of Google when looking for advice related to preventing foreclosure, the odds of being scammed are nothing short of fabulous.
A change in our cultural norms…
Before the current financial crisis engulfed us all, I couldn’t remember scammers looking to con anyone, anytime, anywhere. Where had these scammers come from, that is to say, what were they doing five or ten years ago? Had someone put something in the water in 2007? Could alien spaceships have dropped them off in pods years ago? Was it possible that the Internet was just bringing out the worst in people?
Nothing I could think of would change our country’s societal norms over such a short period of time. I set out to qualitatively analyze the situation and I began by profiling a sample of those that had either been shutdown by authorities for allegedly scamming homeowners or voluntarily closed non-compliant operations.
The most common factor was their chosen profession prior to the financial meltdown… almost all had come from the mortgage industry. In fact, no matter how many I looked at, the number of ex-mortgage people was always close to 90%.
I considered that perhaps that was to be expected with homeowners at risk of foreclosure, a group well known to those that worked in the mortgage industry, being the primary target for these scams. But I also know many individuals that came from the mortgage industry that would be no more likely to scam a homeowner in distress than I would.
The other commonality was age… as a group they were relatively young, with the vast majority under 40, with many under 35.
Education was the third commonality I identified, at least 80% of any group studied, never graduated from college. A large percentage reported attending some college classes, however, many reporting that they didn’t finish their education because the mortgage business paid so well.
It was also interesting that many of the individuals I contacted reported having lost a home as a result of the economic meltdown, and there was no question that few saw the crisis coming, fully understood its causes, or recognize the permanent or long-term nature of the changes to the mortgage industry even today.
Finally, in terms of our nation’s economy, they are a very optimistic group. The majority say they believe that the housing market will bottom out in the next couple of years, many think that some areas have already hit bottom, and almost all say that they think that what they’re doing today is only temporary… at some point they will return to prosperous careers in mortgage lending.
It may be helpful to remember that qualitative research is used to seek out the ‘why’, as opposed to the ‘how’ of the topic being studied through the analysis of unstructured information, such as interviews, open ended survey responses, emails, notes, feedback forms, photos and videos. Qualitative studies are done to better understand the attitudes, behaviors, values, concerns, motivations or lifestyles of individuals.
Absolute ineffectiveness of the government’s response…
Over the last year, there have been a flurry of state and federal laws ostensibly created to protect distressed homeowners, and one would have to assume that awareness among homeowners about the potential to being scammed is certainly at an all time high.
There is absolutely no evidence, however, that any of this legislation has reduced the number of scams. The new laws have only caused the scammers to diversify their illicit offerings and are therefore more difficult to police.
The latest count, as listed on California’s Office of the Attorney General Website dedicated to loan modification fraud as of April 23, 2011, lists 55 individuals and 32 companies, against which the AG has taken legal action related to fraudulent loan modification, forensic loan audit, and other foreclosure-related services, to-date. Considering the number of homeowners at risk of foreclosure in the State ofCalifornia, those numbers are essentially zero.
The California State Bar is reporting the same numbers of consumers filing complaints this year as last, although the number of disciplinary actions taken by the bar hasn’t changed in any meaningful way, indicating that they are having a difficult time both investigating and prosecuting lawyers accused of being “scammers”.
This article seeks to explain where today’s proliferation of scammers came from, who they are… why they are the way they are… and why their presence is all but certain to impact our society for a generation, because…
They Once Were Lenders…
Being a lender of money… the phrase itself congers up images of stature and great wealth. To be a lender of money has always meant having power and prestige… to be the person with the gold that makes the rules.
To be a lender of funds is to have a seat at the proverbial table. Such a person is to be respected, when they talk… others listen. And while in the past, being a lender meant being a “banker,” over the last thirty-odd years, the advent of securitization and financial innovation, ongoing legislation favorable to the finance industry, a series of disastrous attempts at deregulation, and growth in global capital markets, all combined to broaden the types of lending and need for “lenders.”
Without question, the type of lending that grew the fastest over the last three decades was “sub-prime.”
Sub-prime lending began its meteoric rise in the late 1970s, but the lowering of interest rates in the early part of the 1980s was the fuel it needed to explode. And from the start, sub-prime lending attracted individuals with very a very different set of ethics than were found among the traditional bankers and financiers of Wall Street. Many, in fact, came from failed Savings & Loans.
You see, the 1970s, with the decade’s spiraling interest rates were very difficult for the Savings & Loan industry.
S&Ls were originally a very important component of the government’s response to the financial disaster that caused the Great Depression, because they made it possible for people to buy homes at a time when our nation’s bankers were reluctant or incapable of lending.
S&Ls were required to pay a regulated amount of interest on short-term deposits that were insured up to $40,000 by the FSLIC, and then invest those deposits in 30-year fixed rate mortgages on residential real estate within a 50-mile radius of the S&L’s home office. In the 1970s, an S&L might pay 5.25% to 5.5% on deposits, and because long-term interest rates were generally higher than short-term rates, the owner of a Savings & Loan could make a fairly nice, if somewhat boring living.
Of course, that was fine during the decades of relative stability that followed WWII… before the inflation of the 1970s caused interest rates to rise. Higher rates caused homeowners to keep homes longer, first-time buyers delayed becoming first time homeowners, and rising unemployment all combined to significantly reduce the demand for housing.
The typical S&L’s mortgage portfolio, that had traditionally turned over every 5-7 years, stagnated during the latter part of the 1970s… and S&L earnings followed suit.
At the same time, S&Ls were finding it increasingly difficult to attract depositors. The five percent interest rates they were permitted to pay started to look pretty silly with inflation at 12% a year… and climbing. Depositors flocked to Money Market mutual funds on which there were no interest rate controls.
S&Ls were now stuck between the rock of the rising costs of funds, and the hard place of stagnant incomes, and with only 30-year fixed rate mortgages to provide returns on invested capital… the S&L industry was doomed.
The pendulum swings too far…
First, Congress and the Carter administration gave us the Depository Institutions Deregulation and Monetary Control Act of 1980, which abolished state usury laws that limited how much interest could be charged on primary mortgages, began a six-year phase out of deposit interest rate ceilings, and raised the deposit insurance provided by the FSLIC from $40,000 to $100,000.
Then, a couple of years later, the Gain-St Germain Depository Institutions Act of 1982, expanded what S&Ls were allowed to invest in, permitting investment in short-term consumer loans, credit cards, and commercial real estate, among others.
It’s not hard to imagine that many owners of S&Ls were a less-than-happy group back in 1980. Many S&L owners were second-generation owners… the sons of founders. For the last decade they had watched their institution’s capital erode as the housing market had essentially slowed to a standstill.
In other words, spending the 1970s running the S&L your Dad founded was no fun whatsoever, and by 1980 many wanted out badly enough that they weren’t all that picky about the price. So, when deregulation of the S&L industry soon created buyers for S&Ls, many were more than ready to sell.
Most were under-capitalized, but the new owners could get their hands on unlimited funds simply by raising the interest rates offered on deposits, and since such deposits were insured by the federal government, the financial health of the S&L didn’t much matter to anyone. New owners raised rates and money flooded in.
Deregulation also meant there were plenty of investment opportunities available to S&Ls for the first time, in much riskier commercial real estate developments, for example, and the S&Ls could compete with the banks by making loans based on more relaxed credit standards, such as home loans that required no down payments.
These new S&L owners, however, were poor managers and as many failed; the deposit premiums paid by those that remained went steadily higher. And because there was no distinction between well-capitalized S&Ls, and the ones that were taking on too much risk, the well-capitalized and more conservative institutions found themselves forced to match the competing interest rates offered by their problem competitors, causing their costs of funds to increase.
Had the federal government taken a tougher stand on S&Ls in 1982, it’s likely that the whole mess could have been avoided, but regulating financial institutions has never been our government’s strong suit. Back then, virtually every congressional representative had at least one “good friend” that owned an S&L in his or her district and none was in any hurry to cause immediate problems for their important constituents.
It was a recipe for the disaster stew that was about to boil over… and yet, Congress kept its collective head firmly planted in the sands of short-term thinking. (It’s nice to know that some things never change.)
From S&L to Sub-Prime…
It seems to me that two key pieces of legislation, the previously mentioned Depository Institutions Deregulation and Monetary Control Act of 1980 (“DIDMCA”), and the Alternative Mortgage Transactions Parity Act of 1982 (“AMTPA”), worked like sperm and egg to give birth to sub-prime lending, with securitization being the incubator.
The AMPTA, which was intended to provide “parity” to non-bank lenders, preempted many state laws that had precluded lenders from offering anything but conventional fixed-rate mortgages, and in practice, allowed for the obfuscation of a loan’s total costs. This was the legislation that led to the creation of a variety of new types of mortgages, including the different flavors of adjustable rate mortgages (ARMs), interest only mortgages, and those offering balloon payments.
Because of AMPTA, consumers could now be titillated by teaser rates for the first few years, only to be slammed when the adjustments caused payments to be reset. And even worse were the loans that gave the borrower the ability to decide how much they would underpay during the first few years, with the amount of the underpayment being tacked onto the loan’s balance. Now your mortgage balance could actually increase from $300,000 to $350,000 in the first few years, destroying any equity a homeowner had in his or her home when they bought it.
It was the days of “red lining,” and it meant that lending was scarce in minority neighborhoods, regardless of an individual’s credit score.
Consumer finance companies started offering small loans in disadvantaged communities that people used to pay medical bills, or maybe to get through the holidays, but by the mid-1980s, securitization was lowering the risk associated with lending and they began offering second mortgages.
In “The Monster,” Michael Hudson provides vivid descriptions of how these companies would hook someone with a $300 loan, and then systematically barrage them with offers for additional loans in an effort to make them a “customer for life”… although a “debtor for life,” would be more accurate. These companies would make loans at 15 to 18 percent, with as much as 10 points up front, which was still less than hard money lenders, so they could actually say… with straight faces… that they were good guys serving underserved communities.
These companies were literal pressure cookers for sales people. They were widely known for their abusive managers that would constantly drive salespeople to make more loans at all costs… and then make even more still. They were the predecessors to the sub-prime lenders that would come out of the failed Savings & Loans.
So, it was the loan officers trained at Transamerica, ITT Financial, Household Finance, and others, they were soon recruited by institutions like Roland E. Arnall’s Long Beach Savings & Loan. Soon, the restrictions on S&Ls will become too much for Arnall, and he’ll openLong BeachMortgage… later to be renamed “Ameriquest.”
Arnall was known for doing things like doubling sales goals moth over month and firing anyone who said they couldn’t do it. He began to build one of the country’s largest sub-prime mortgage companies, but he was making so many loans so fast that he simply ran out of money.
He needed a new source of funds, looked to Wall Street and found Lehman Bros.
Enter the Financial Innovation of Securitization…
Wall Street’s new invention was “securitization,” and it would allow lenders like Arnall’s Long Beach Mortgage to make essentially an unlimited number of loans because they could now be immediately sold to Lehman Bros., who would then use them to create a pool of loans, which would then be sold in slices, called “tranches,” to investors.
The investments were referred to as “mortgage-backed securities,” and the investors that bought these bonds, of sorts, did so in order to receive a percentage of the cash flows generated by the mortgage payments that were paid into the pool. As compared with other investments, they were considered very safe, and yet they paid a relatively high rate of interest… like tasting great and being less filling all at the same time… what’s not to love?
Now, the sub-prime lenders had essentially unlimited capital at their disposal. The world was about to change because now anyone would be able to get a loan. Prices would rise with the increasing demand that would be created by the flood of accessible capital, and those loans could be refinanced over and over as the value of the collateral increased.
All they needed now were army of loan officers…
Roland Arnall, fueled by unlimited funds, was ready to spread out across the country bringing his high cost loans to millions of Americans. He was never satisfied… a billion a month in loans, only made him demand two billion, and he became immeasurably wealthy as a result, as did those that worked for him.
Ameriquest needed an army of salespeople, and Arnall wanted them trained the Ameriquest way.
In all-importantCalifornia, prior to 1996, this meant finding loan officers and recruiting them to come over to Ameriquest. It couldn’t have been easy, not just anyone would put up with working in an environment in which you could be berated to get more sales, not just anyone could be pushed into taking advantage of borrowers as was required at Ameriquest.
Luckily, in 1996 the law governing the licensing of mortgage lenders inCaliforniachanged when the California Residential Mortgage Lending Act and the California Finance Lender’s License (“CFL”), used when you sold only through in-house loan officers, and the broader CRMLA licenses were created, both became operational. Now someone could become licensed to broker, originate and service mortgages without the need to pass that pain-in-the-neck test required by the state’s Department of Real Estate. Yes, it was very lucky, indeed.
Now large sub-prime lenders could easily recruit the personnel they needed to grow their sales without having to bother with new sales people having to receive any training or pass any tests. Armall and others in his peer group were free to hire young salespeople in masses, put them in classes, and if they didn’t perform… toss them out on their behinds.
Hudson’s investigations of Ameriquest showed that the company’s system was designed to back borrowers directly into a corner, or if you prefer, put them up against a wall. The company’s loan officers were trained that when a customer complained about the costs of their loans, they were to assure them that they need not worry because once they’d made their payments on-time for 12 months, the company would refinance them into the lower cost loan.
In addition, the payments on Ameriquest’s 2/28 adjustable rate mortgages ALWAYS shot up towards the end of the second year, driving the borrowers to refinance with Ameriquest or pay higher fees somewhere else.
As the second half of the 90s came and went, Ameriquest employees saw the company’s sales practices investigated by various state attorneys general, and numerous fines get paid, but at the end of the proverbial day, they also saw Armall become a billionaire as he lived out the rest of his life in opulent luxury.
Like a gaggle of raptors…
The loan officers that trained at companies like Ameriquest would ultimately move on to places like WaMu, IndyMac, or even Wells Fargo, Bank of America or Countrywide. And as the housing bubble began to inflate in 2003, sub-prime was ready for prime time. Wall Street firms like Lehman Bros. were buying sub-prime mortgage originators… and what had been a relatively small group of loan officers was now multiplying like a gaggle of raptors.
They had learned the business of lending in the most oppressive and unethical environments and as they moved up corporate ladders at various commercial banks and mortgage companies, they instilled their own ways of doing business, developed their own cultures, and tried to make work what worked before, cross pollenating sales techniques until the influence of places like Ameriquest could be seen and felt throughout hundreds of lenders all over the country.
Over the years, a variety of state AGs tried to take action against sub-prime lenders who were clearly abusing communities and ruining the lives of homeowners, and in limited instances had some success. But, the lenders on the losing side of such actions often just filed for bankruptcy and the perpetrators ended up opening new companies that went right back to their underhanded business as usual.
The sub-lending industry’s lobbying efforts essentially won out in all cases, the argument was simple: poor and working class neighborhoods need loan sharks.
That sinking feeling…
By the summer of 2006, the Fed had raised interest rates 17 times in a row, housing sales had slowed, prices were softening, and I had long-since started warning my own friends to get out of speculative real estate deals as the evidence of dark skies forming on horizon was now abundant.
It’s astonishing how fast things locked up. Demand for residential mortgage-backed securities (“RMBS”) dried up overnight and a cornucopia of derivatives went with them.
With no demand for MBS, the secondary mortgage market stopped buying mortgages almost immediately and banks and other non-bank lenders found themselves unable to sell the loans that were now stuck on their balance sheets, and capable of destroying their required ratios. Everyone started hoarding cash… banks stopped lending even to each other… no one knew who had what on their balance sheet, who would prove overleveraged and potentially not recover.
No mortgage lending,,, VERY ABRUPTLY… means housing prices will fall, because can’t get a mortgage means can’t buy a home, and when demand for something goes down… anyone, anyone… price goes down… very good, class. Refinancing loan also dried up VERY ABRUPTLY, and by the time there was any hope of refinancing most people were already underwater.
What the banks did leverage-wise is akin to a homeowner taking out a second mortgage in order to invest in the stock market. As long as the market was rising, this leverage magnified their returns, but when prices started falling the effect was horrendous. Lehman Bros. was leveraged by about 30:1. WaMu, I believe was around 40:1. Other institutions were even in worse shape.
And we all know what happened after that.
Since then, the banks have been permitted to publicly lay blame for the catastrophic outcome that has broken the economic back of the world’s wealthiest nation, on the loan officers they trained and armed, and on working class American homeowners, to whom they’ve also been allowed to send the bill.
It’s amazing thatAmerica’s homeowners haven’t risen up with a voice so loud as to make the Tea Party sound like a dropped pin.
But, today’s homeowners at risk of foreclosure must also face the fact that they are literally being hunted by a group of highly trained individuals desperate for money, and trained to take whatever they need from homeowners in distress.
They once were lenders…
As a group, those that hunt homeowners in distress are still relatively young in terms of their years, they have little if any formal education… they have natural sales abilities, which were honed by professionals who trained them to achieve their objectives irrespective of who they hurt.
They were paid, in many cases, $50,000 a month or more, and over a decade they were shown indisputable evidence that crime pays, and pays handsomely, as they watched their bosses make incalculable sums through at best highly questionable means… and flat out get away with it.
Them one day, quite abruptly, the proverbial music stopped… without any warning they could discern, the whole thing was over… overnight. The money was gone, and they were not prepared. They lost their cars, their homes, everything, and they could no longer do for a living what they had been trained to do.
It was over too fast and they were left with no seat at tomorrow’s table. They once were lenders, but now what?
Loan modifications and debt settlement programs provided a soft landing for the first few years… the up front fees made them feel rich again.
It’s not clear just how many loan modification and debt settlement companies were truly deserving of the moniker “scammer,” but regardless, state and federal regulators started receiving thousands of complaints from homeowners claiming to have been scammed, and the FTC, state Attorneys General, State Bar associations, and other regulatory and law enforcement agencies have all played a role in shutting down companies that were run by those that came from the mortgage lending industry for unethical or illegal acts involving homeowners in distress.
With enforcement actions making headlines it was predictable that state legislatures would get involved and starting in the latter part of 2009, new laws protecting consumers gradually took the ability to market loan modifications and debt settlement services away from those licensed as loan officers, by making it illegal for them to charge a customer until they had obtained a loan modification for that customer.
So, now that they couldn’t sell loan modifications or debt settlement programs anymore, they moved into areas that were more difficult for authorities to pin down.
Many sold “forensic loan audits,” which are report that claim to identify laws that were broken by the originator of the loan. The pitch was (and is) that armed with this proof of impropriety the homeowner could hire an attorney, sue their servicer who would be forced to modify the loan. Homeowners bought them in the tens of thousands… it felt like a way to regain some of their power and once again feel in control of their lives.
The problem, however, was that these “audits” were largely worthless, either because they failed to take into account statute of limitations issues, or they pointed out violations that offered only impractical remedies or provided for no cause of action for the homeowner whatsoever. The homeowners were buying something for thousands of dollars that would end up being thrown into the trash.
In the most outrageous example, a company that was shut down byCalifornia’s Attorney general, and is currently being sued by the state for something like $60 million, is alleged to have charged an elderly man $53,000 for a forensic loan audit that was to put him in the driver’s seat with his mortgage servicer.
The list, it pains me to say, goes on and on.
Stopping the failures to stop the scammers…
There are thousands of individuals unleashed on our society today that were raised in a mortgage industry at its worst… taught to hunt for homeowners in distress… and shown that acts of fraud are profitable and likely to go unpunished. Now, unable to make their livings making loans, they continue to seek out ways of using their skills to target homeowners in order to line their pockets.
They look just like the rest of us… they present themselves very well… ooze with credibility when needed… lie effortlessly and without conscious. They were trained by sub-prime lenders to function as sociopaths. They represent a clear and present danger to our society today and they aren’t going away anytime soon.
The only way to stop the scammers who prey on homeowners in distress, is for our government to acknowledge that homeowners need expert assistance and ethical legal representation when dealing with their banks as they try to save their homes from foreclosure. And then, make access to legitimate assistance and readily available.
Consider that during prohibition of the 1930s, G-Men running around the country trying to enforce the 18th Amendment to the U.S. Constitution by smashing stills and spilling illegal booze in the streets accomplished nothing. The only way our government ultimately stopped bootleggers… was to put legal liquor stores on the corner. People wanted to drink, and they were going to find a way. The only lasting outcome of prohibition was well-funded organized crime.
The same factors apply here. Homeowners at risk of foreclosure are going to do everything they can to save their homes, including writing a check to organized crime, if that’s the only option available. Passing new laws has not stopped a single scammer, nor will it. That’s why we call them “scammers,” because they don’t follow the laws.
The anger felt by homeowners is building and their knowledge of the situation is increasing each day. Our government’s response to the crisis has been laughable, were it not so very tragic.
It’s the bankers and sub-prime lenders that led us into this crisis… and they trained today’s scammers to scam, as well. Until our government regulators come to understand the dynamics of what’s going on, the scammers will proliferate, home prices will continue to fall, and our economy will deal out pain ever more broadly.
And for what?
The economic problems being faced by our country’s middle class are unprecedented. If they have ever been faced before, it would have been 70 years ago… it’s quite obvious that no one is prepared. For those same reasons we cannot expect to find that the optimal business model already exists to handle a situation never before faced, no more than we could have expected to find a software store, before the computer was invented.
We have mortgage experts, underwriters, credit counselors, attorneys, and real estate agents… all the pieces of the puzzle are here. It’s time to look for new ideas and new organizational structures, time to allow new solutions to be put on the table. We’ve failed at every turn and in every way to-date, as far as the foreclosure crisis is concerned, and we simply can’t afford not to understand the problem any longer.
Because until we understand where we are and how we got here, we have no hope of moving beyond what history may very well one day view as the darkest days in our nation’s history.
Martin Andelman is a staff writer for The Niche Report. He also writes an almost daily column on ML-Implode called Mandelman Matters. He also publishes a Monthly Museletter and you can follow “Mandelman” on Twitter. Send your responses to [email protected]