THE FEDERAL response to the country's foreclosure crisis has been too little, too late. The best that the Bush administration has come up with so far to help homeowners with both prime and subprime mortgages falling into foreclosure has been a hot line established by the mortgage industry - a voluntary effort set up by the very industry responsible for the problem in the first place.

Congress is considering a number of options, which may include federal mortgage guarantees for troubled borrowers.

But with millions of homeowners living in homes valued less than their mortgages, or facing loan rates resetting beyond their reach, it's going to take a bold plan, like a moratorium on foreclosures, to carve a solid path out of the mess.

Could Philadelphia City Council show the way? Despite the fact that Council has little power over the banking or mortgage industry, it held a hearing last week and listened to housing advocates and others pitch a variety of ideas for confronting the foreclosure problem.

Those people on the front lines of the issue - such as ACORN and Philadelphia Unemployment Project- seem to agree that pressure must be put on loan servicers to work more closely with local housing agencies to devise workout agreements with homeowners facing foreclosure.

Lenders and servicers can't work fast enough - or don't want to - to handle large numbers of mortgage workouts. But they need to be pressured to come to the table and work with those on the front lines to help homeowners.

With thousands of subprime mortgages in the city scheduled to "reset" to higher interest rates this year, the city's role in this national crisis could expand.

Despite the limits of what it can do, Council is right to grapple with this. Even if Congress and the Bush administration doesn't.