There’s nobody who hates navel-gazing more than I, so I will try to dispense with this quickly. Glenn Thrush thinks I’m wrong to attribute the same perspective on Eric Schneiderman to Tom Miller, who dissed him on the record, and Shaun Donovan.

The National Association of Consumer Advocates, the National Association of Consumer Bankruptcy Attorneys and the National Consumer Law Center have released the results of a survey showing that “mortgage servicers continue to initiate foreclosure proceedings improperly, either while a homeowner is awaiting a loan modification or due to improper fees or payment processing.” And it’s occurring even after the services signed an earlier settlement to end the practices.

The Administration continued to push back on one particular story from Shahien Nasiripour by devoting an entire blog post about whether bank servicers can count the incentives from HAMP modifications toward the “credits” in the foreclosure fraud settlement. But Shahien’s story didn’t make that claim (thought the title hinted), and we’re still without actual terms to see how it all works.

Whether you believe in Eric Schneiderman’s ability to deliver a legitimate investigation on mortgage securitization fraud or not, you have to admit that the united front on opposition to a settlement on foreclosure fraud collapsed the moment that he agreed to helm that federal investigatory task force. Now Iowa AG Tom Miller is publicly denigrating Schneiderman’s role in setting the terms, claiming he didn’t do much.

Just because state and federal regulators reached a settlement with banks over foreclosure fraud – we think – doesn’t mean that the banks have rid themselves of their liabilities, even on these foreclosure fraud-related issues. In Massachusetts, a new ruling by the state Supreme Court may formally grant borrowers the ability to contest their foreclosures on the grounds of faulty document processing. And there are similar cases dealing with commercial property mortgages.

The New York Times today looks at single point of contact, a standard for servicing which has been mandated on at least a couple of occasions, without success. Requiring a single point of access has been required in settlements before, but consumer advocates say little has changed, leaving us to wonder whether any of the new settlement terms will be enforced.

The state and federal regulators may complain that criticism of the bank settlement without actual terms are distortion, and that they have a very difficult job to figure out the terms for 49 states and multiple federal agencies, and they’re just working out the complexities. Well, they should have thought of that when they announced a settlement to great fanfare. Terms matter, and without them, the settlement is no more than a theory.

More reactions from last week’s revelation from San Francisco Recorder-Assessor Phil Ting, that an overwhelming percentage of foreclosure documents he reviewed were found to be at least partially flawed. The two members of Congress who represent San Francisco want Attorney General Eric Holder to convene an investigation. That consists of Jackie Speier and the Minority Leader of the House, Nancy Pelosi.

During the many months over which we read excellent posts from David Dayen, Yves Smith and others about the on/off negotiations between state Attorneys General, the Administration and the five major banks, I assumed, and I suspect many others also believed, that the settlement negotiations were essentially a law enforcement matter. Thus, any settlement should be judged on principles relating to fairness and criminal justice. It now appears that that interpretation was fundamentally inaccurate.

Programming note: I’ll be hosting a special FDL Salon with William Black, professor at the University of Missouri-Kansas City and the author of The Best Way to Rob a Bank is to Own One. Black specializes in white-collar criminology, and in his time as a federal regulator, he helped put over 1,000 financial executives in jail for the savings & loan crisis.