In case you missed it in the Morning Scan, an Op-Ed in today's Wall Street Journal by Arkadi Kuhlmann, CEO of ING Direct USA, offers one of the clearest explanations we've seen for the less-than-stellar results of the Home Affordable Modification Program, or HAMP. (Aside from the fact that HAMP doesn't reduce a borrower's principal, that is.)

Reason number one: the government is "suffocating banks with counterproductive accounting rules." For example, under current law, if a bank modifies a mortgage it must record the write-down as an expense on its books, even though the bank didn't lose any money. It's still scheduled to receive the totality of the loan principal, just less interest. Kuhlmann says this creates "a huge financial disincentive to offer modification."

Reason number two: auditors and regulators are imposing "an ever-increasing load of paperwork on customers and banks looking to modify." In many cases, Kuhlmann writes, there are more forms needed to modify a loan than to get a mortgage in the first place.

Reason number three: regulators haven't done enough to protect banks from "strategic defaulters," including homeowners who seek a modification even though they aren't facing financial difficulty. Kuhlmann writes that strategic defaulters "suck away bank resources and attention, making it that much harder to service people facing true hardship."