This is the second part of a story on the Office of the Comptroller of the Currency's independent foreclosure review program. A close look suggests that the program is taking far longer than originally expected and resulting in much larger payments to consultants than to wronged borrowers.

Consumer groups have been quick to criticize the Office of the Comptroller of the Currency's independent foreclosure look-back reviews for giving the banks under scrutiny too much say in the process of reviewing their own loans.

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