Upon further review... New short sale program lacks teeth!

I posted a couple of weeks ago about the government passing a new streamlined short sale program. I'd like to go over my thoughts on the program now that I have had some more time to evaluate it.

The key aspects of the program are:
1. The banks participating in this program have 10 days from a submitted offer to accept or deny the offer. Currently this time frame ranges from 30 days on the good side to 2 yrs if its Bank of America.
2. The banks would have no recourse after the acceptance of the short sale. Currently, if the short sale approval does not have the correct "verbiage" the bank can and will on occasion sell the deficiency to a collection agency.

This is a start and I have been preaching about reform for 3 yrs. The problem with this program however, is it does not address secondary lien holders which are in many cases the banks themselves, that usually hold up the transaction. The program allows secondary lien holders to receive a maximum of $3k. Right now secondary lien holders are asking much more than $3k. This is also a voluntary program, how realistic is it to think that the banks are going to be nice and agree to $3k when they are owed $100k and they know they can hijack the deal unless someone gets them some additional money? That will never happen. I applaud the government for trying but this program lacks the teeth that is needed when dealing with the likes of Bank Of America!