Consumer advocates said settlement amounts can obscure the actual costs at stake. But since the disputed business behaviors affected mortgage investors, not mortgage borrowers directly, they welcome any consumer aid.

“This is public policy making through settlements that aren’t even related to the nature of the lawsuit,” says Ira Rheingold, executive director of the National Association of Consumer Advocates. “But there’s no other tool available for people who are concerned about poor communities right now.”

In the deal with JPMorgan in November, the department had a clear message for homeowners: Billions of dollars’ worth of help was coming. Attorney General Eric Holder at the time described the appointment of an independent monitor who would distribute $4 billion set aside for homeowner relief.

The actual relief is more complicated than cash handouts, however.

Both Citigroup and JPMorgan earn credits under the settlement from a “menu” of different consumer-friendly activities, according to settlement documents. The options are effectively an update of the consumer relief previously provided through the national mortgage servicing settlement, a 2012 deal between state attorneys general and the major banks.

JPMorgan probably will earn its $4 billion in credits under the settlement through a total of $4.65 billion of activities that qualified as relief, according to a report by Enterprise Community Partners, a nonprofit run by executives from low-income housing groups and major banks.

More than half will come from principal reductions, with the rest earned through actions such as writing new loans in distressed areas, donating foreclosed properties to community groups and temporarily suspending payments on some loans.

The report described the settlement as “a reasonable model from a consumer perspective.” But one of its authors, Andrew Jakobovics, acknowledged that many of JPMorgan’s credits probably will come from activities that are part of its regular business practices. The bank has announced plans to complete its obligations at least one year ahead of schedule.

Citigroup’s settlement gives it until the end of 2018 to earn $2.5 billion in credits. It must provide half its $825 million in principal reduction credits in neighborhoods designated as “hardest hit” by the Department of Housing and Urban Development because of high concentrations of foreclosures and vacant properties.

It also can earn credit by waiving some closing costs on new loans to low-income home buyers and forgiving principal on loans where the bank began a foreclosure but never completed it.

“Will it cost them money? No,” said Rheingold, who said he supports the settlements. “But would they have done it otherwise? No.”

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