Yes they are & you can add this along with Deficiency Judgments I mentioned. Why must we do all the thinking and the work for these regulators? You know who you are.

NYT–

AFTER slowing down in the first half of the year, the rate of homes entering foreclosure is rising again. First-time default notices were served on 78,000 homes in August, a 33 percent increase from July. A $1 billion federal program to help jobless and underemployed homeowners ended Friday. Foreclosure notices were filed against a record 2.9 million properties last year, and an additional 1.2 million in the first half of this year.

Foreclosure is not just a metaphorical epidemic, but a bona fide public health crisis…

[NEW YORK TIMES]