The Subprime Bailout Plan: Anti-Trust Violation?

I am uncomfortable with the subprime bailout plan for reasons different that those made prominent in the press.  First, it is not an assault on contract rights.  One party to a contract, the loan servicer, can always offer new terms to the other, the loan debtor, in the hopes of working out a default.  Furthermore, the workout cannot be a threat to investors in SIVs who hold the mortgage loan; the investors may get better returns with a workout than a default.  Second, the subprime rate forgiveness agreement is not a government bailout. There is no government money involved, other than perhaps the FHA part of the plan -- which is another matter altogether-- and yet to be worked out (it has to be put into legislation).  Third, it is not government fiat; participation in the plan is voluntary.  But, my problem, the plan is a concerted agreement among competitors, sanctioned by the government. Without government involvement it would be an anti-trust violation.  Individual loan servicers should work on their own rate deals and compete with other loan servicers on how well they do.  The government should not fix the rates and then protected the fixed rates from anti-trust price fixing challenges by its involvement (state action is exempt).  The plan is, flat out, an anti-trust violation.