In a recent article, "The State That Ate the National Mortgage Settlement," American Banker suggested that, in the implementation of the national mortgage settlement involving the states and the federal government, California received a disproportionate share of the homeowners' benefits at the expense of other states due to a separate guarantee it negotiated.

At the time of settlement, we believed that California would receive well in excess of its guaranteed amount ($12 billion) regardless of the guarantee. The latest progress report issued by the independent Office of Mortgage Settlement Oversight bears this out. The guarantee has neither benefited California nor harmed other states.

Last February we estimated, without factoring in the guarantee, that California would receive $14.9 billion in homeowner benefits (almost $3 billion in excess of the $12 billion guarantee). The estimate was based on the amount of homeowner debt greater than the value of the home or loan-to-value ratio (over 115% for some benefits and over 100% for others). The total projected homeowner benefit for all states was $30.4 billion.

We did not want to over promise, and believed at the time that the estimates for all states were conservative. That has turned out to be the case. Through only the first seven months of the settlement's implementation, homeowners' benefits nationally have totaled $24.7 billion, 81% of our original estimate.

In only seven months, California has received $10.3 billion, approaching its $12 billion guarantee and 69% of our original estimate. At 69%, California is actually running behind the national average of 81% of our estimate.

The four states with the most underwater loans were California, Florida, Arizona and Nevada. Of those states, only Arizona did not have a guarantee. Yet, at 78% of our original estimate for that state, Arizona has achieved, thus far, a higher percentage of its estimated homeowners' benefits than the other three states.

Some states without guarantees have already reached more than 100% of their projected benefits. Iowa and Ohio are two of these states.

As we expected, California's guarantee has not affected the level of benefits for its homeowners. California is receiving a notably large share of national mortgage settlement benefits because of the level of harm the state sustained during our nation's mortgage crisis.

Iowa Attorney General Tom Miller was the lead state attorney general in the joint state-federal $25 billion national mortgage settlement.