Last week John Koskinen, Chairman and Chief Executive of Freddie Mac, made the bold statement that the worst of the housing market is “clearly” behind us. This must be some kind of “exit” statement as he’s heading for the door next month. He sees the uptick in housing numbers and lull in foreclosures as basis for renewed enthusiasm and optimism. But is it time to break out the party hats? Not just yet. According to recent studies by Deutsche Bank and Credit Suisse, we may be in for a renewed cycle of loan defaults equal or in my opinion, greater than we experienced in 2007-2008.

A recent research report by Deutsche Bank, as reported on MSNBC, estimates that roughly half of all U.S. homeowners will be under water by 2011. Credit Suisse recently reported that we may be in for a renewed cycle of loan defaults equal, or in my opinion, greater than we experienced in 2007-2008. Credit Suisse estimates that during June 2009 mortgage defaults reached a two year low and are now one third the number that occurred during the fourth quarter 2008 peak. The next great wave will be in resetting teaser rates in Alt-A and Option loans.

We should see Alt-A and Option adjustable defaults begin to swell later this year, peaking in 2011 with a slow decline into 2012-2015. During that next peak in resetting teaser loans, the number of loan defaults and foreclosures will in all likelihood be higher than in fourth quarter 2008, and more than three times what we are experiencing this year.

Alt-A and Option teaser loans were not limited to one or another economic class. They helped the poor and well heeled buy up on property they couldn’t otherwise afford. The bigger problem with this next wave in resets is that it begins in a world where millions of jobs have already been lost along with billions in home equity, unlike the world of 2007-2008 when we kicked off this great recession we’re in today. That means that folks close to the edge will fall off even faster than before unless there are effective programs in place to refinance and stem the flood tides of default and foreclosure.

With the next great wave of resets on the horizon, I’m not ready to start celebrating the turning of the tide just yet. Lenders and government officials must put effective programs in place to take out the teaser loans that could pull our economy and housing market out to sea in the greatest riptide we’ve seen in our housing history.

On August 1, 2009, the FTC began enforcing its so called “Red Flag Rules,” which requires certain businesses, including franchisors, to develop effective programs to identify the warning signs of identity thief.

Franchisors that regularly extend “credit” to their franchisees or arrange financing are subject to the rule. A franchisee may be regarded as a creditor if it defers payments from its franchisees or extents credit or if a franchisor bills a franchisee after providing goods or services. The other way a franchisor would fall under the rule is if it suspects that it may be subject to risk of identity thief. With such broad coverage, most national and regional franchise systems would appear to be subject to this new rule.

If a franchise system is subject to the rule, then it is responsible to develop and put an effective identity theft program into place. The program must be approved by the corporate board of directors or senior management. Failure to comply could result in a franchisor being fined civil penalties.

Although burdensome on franchisors, hopefully this new rule will help curb identity thief, a growing international concern. For more information about the Red Flag Rules, the FTC has published a free plain-language handbook, Fighting Fraud with the Red Flags Rule: A How-To Guide for Business. For a free copy of the guidebook, or for more information about compliance, visit the FTC’s website.

Postscript: With news today of Federal prosecutors charging a Miami man of trying to gain access to 130 million credit and debit card accounts, mostly though hacking into retail networks, it’s difficult to argue against the logic of the Red Flag Rule, despite the obvious burden it places on certain business and franchise enterprises.