When the $25 billion national mortgage settlement was struck in early 2012, regulators bragged that the top five mortgage servicers would be held responsible for their conduct, particularly the "robo-signing" of foreclosure documents.

But it turns out that mortgage bondholders paid for nearly one-quarter of the $20 billion in relief provided in the settlement, or $5 billion at a minimum. (The banks paid $5 billion in cash penalties.) These investors have long complained to regulators that the settlement was poorly structured because large bank servicers got credit for principal reductions and loan modifications they did not pay for themselves.

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