Linda Green

Filing # 63142758 E-Filed 10/20/2017 05:58:45 PM
IN THE SUPREME COURT OF FLORIDA
THOMAS CARLISLE,
Petitioner, CASE NO.: SC17-1719
vs. THIRD DCA CASE NO.: 3D17-58
U.S. BANK NATIONAL LOWER CASE NO.: 2009-86386 CA 01

ASSOCIATION, ETC.,
Respondent.
____________________________/
RECEIVED, 10/20/2017 06:03:36 PM, Clerk, Supreme Court
APPENDIX TO PETITIONER’S PETITION TO INVOKE ALL WRITS

JURISDICTION PART II
Respectfully submitted,
JACOBS KEELEY, PLLC

ATTORNEY FOR PETITIONER
ALFRED I. DUPONT BUILDING
169 EAST FLAGLER STREET, SUITE 1620
MIAMI, FLORIDA 33131
TEL (305) 358-7991
FAX (305) 358-7992
SERVICE EMAIL: [email protected]
BY: /S/ BRUCE JACOBS

BRUCE JACOBS
FLORIDA BAR NO. 116203
PETITIONERS’ APPENDIX
Appendix G Office of the Attorney General Economics Crime Division: Unfair,

Deceptive and Unconscionable Acts in Foreclosure Cases ..... 3-101
Appendix H Attorney General Pam Bondi’s Press Release ..................... 102-106
Appendix I Consent Order from Office of the Comptroller

of the Currency .................................................................... 107-140
Appendix J Memorandum of Review on Bank of America’s Foreclosure and
Claims Process from the Department of Housing and Urban
Development’s Office of Inspector General ....................... 141-167
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
emailed to [email protected]; [email protected], Nancy M.
Wallace Esq., Akerman, LLP, 106 East College Avenue, Suite 1200, Tallahassee,
Fl 32301 this 20th day of October 2017.
/s/ Bruce Jacobs

Bruce Jacobs
Respectfully submitted,
JACOBS KEELEY, PLLC

ALFRED I. DUPONT BUILDING
169 EAST FLAGLER STREET, SUITE 1620
MIAMI, FLORIDA 33131
TEL (305) 358-7991
FAX (305) 358-7992
SERVICE EMAIL: [email protected]
BY : /S/ BRUCE JACOBS

BRUCE JACOBS
FLORIDA BAR NO. 116203
Office of the Attorney General
Economic Crimes Division
UNFAIR, DECEPTIVE
AND UNCONSCIONABLE
ACTS IN
FORECLOSURE CASES
PREPARED BY: JUNE M. CLARKSON, THERESA B. EDWARDS AND RENE D. HARROD
Overview of Foreclosure Industry
Florida Attorney General investigation

50 State Multi-State Team
Investigation
Law firms began withdrawing
documents
Banks suspended foreclosures
Delinquency & Foreclosure Rates 2006-2010
Source: Oversight Panel Oversight Report, Examining the Consequences of Mortgage Irregularities for Financial Stability and Foreclosure Miigation
Data itot available Low for eclosur e r ate Modef ate for eclosur e r ate High for eclosui e s ate
F Lee County, FL
Total househokis: 364,932
Foreclosur es: 1 in 96
Foreclosure Rates Unemployment Rates Median Household Income
Data uot available Low for eclosui e Iate Moder ate fos eclosur e Iate High for eclosur e Iate
Hillsborough County,
FL
Total households: 522,057
For eclosur es: 1 in 116
Foreclosure Rates Unemployment Rates Median Household Incon
Data liot available Low for eclostu e i ate Moder ate for eclosur e late High for eclosur e i ate
Duval County. FL
Total households: 394,126
For eclosur es: 1 in 224
The History of Mortgages in America
Bankers used to take the

original note and
mortgage and secure it in
the bank vault.
Mortgage-Backed Trusts
As the mortgage industry

grew, bankers began
securing the notes in
mortgage-backed trusts
Trusts are a bundle of
5,000 notes secured by
mortgages
A bundle of notes may
contain 5,000 notes and
mortgages with a face
value of $1.5 Billion
Sales & Servicing of Trusts
These Trusts were

packaged as Residential
Mortgage-Backed
Securities (“RMBS”) and
could be sold to investors
in bite-sized pieces
The rules for the
operation of these RMBS
trusts were set forth in
“Pooling and Servicing
Agreements”
The Travels of a RMBS bundle
Trust bundles travel

from:
The Lender
To the Depositor
To the Securities
Company
To the Trustee
When it doesn’t work quite right . . .
Sometimes a note or a mortgage gets lost.

Sometimes the document

custodians are lax about
their procedures.
That appears to be the
situation here in Florida as
well as across the nation.
Sometimes there are just too many documents to

keep track of any single Note or Mortgage.
Keep in mind these are

some of the largest banks
in the country . . . losing
ownership paperwork!!
IMPORTANT: The Key
The key to the problems

regarding foreclosures of
mortgages are the
ASSIGNMENTS of
mortgage.
IMPORTANT: The Key
Assignments of
mortgage operate to
transfer ownership
of the mortgage from
one bank to another.
You sue on the note
but foreclose under
the mortgage.
What if there is no valid assignment?
A valid assignment
transfers the ownership of
the mortgage and allows the
assignee of the assignment
to begin a foreclosure
action.
Only the holder/owner of
the note and mortgage can
institute a foreclosure
action if the homeowner
stops making their
mortgage payments.
If the
mortgage
is not
properly
assigned….
the result
is chaos.
The Paperwork in Securitization Process
Assignments
Source: Oversight Panel Oversight Report, Examining the Consequences of Mortgage Irregularities for Financial Stability and Foreclosure Miigation
Sample Assignment of Mortgage
C e 10/28/2008-PRef#:A 0- F
Da e:1 6/2008-P tc ID: 79
3281 DID ___

FORT PIERCE, FL 34982
This space for Recorders tJse ordy
ASSIGNMENT OF MORTGAGE
FOR GOOD AND VALUABLE CONSIDERATION, the receipt and sufficiency of which is hereby
acknowledged, Mortgage Electronic Registration Systems, Inc. as nominee for American Home Mortgage
Acceptance, Inc., whose address is 6501 Irvine Center Drive, Irvine, CA 92618, does by these presents
hereby grant, bargain, sell, assign, transfer, convey, set over and deliver unto AMERICAN HOME
MORTGAGE SERVICING, INC., a DELAWARE CORPORATION, F/K/A AH MORTGAGE
ACQUISITION CO., INC., whose address is 6501 Irvine Center Drive Irvine, CA 92618, the following
described mortgage, securing the payment of a certain promissory note(s) for the sum listed below, together
with all ri erein and thereto, all liens_created or secured thereby, all obligations therein described, the
mone ue and to due th on with in est, and pl nghts accrue to ac e On suc rtgage7
gi er(s): RIG BE E RO
Ori nalMortga c: O TG GEELE R ICR IS S STE S,I C., N INEE
F AMERICA2 O E ORTGAGE CC PTA CE,INC.
Da e of Mortgage: 07/ 0 ; Lo t: 5 ,850.00
Re ording Date: 08/04/2 4 Book: 2035 P ge: 1 87 Document . 2454536
(Mi Comments: GA D CRIPTIO : L GAL ESQRII×rION: THE NORT HA F OF LOT 2
D OT 2, B C L LA P CCORDING HE T
H OF AS RF RDED LAT B, 10, P GE(S) 4, OPJHE PUBLI RECORDS O ST.
LUCIE CO Y, FLORDIA.
and recorded in the otTicial records of the County of St. Lucie, State of Florida affecting Real Property and
more particularly described on said Mongage referred to herein.
IN WITNESS WHEREOF, the undersigned has caused these presents to be executed on this date of
10/21/2008.
Mortgage Electronic Registration Systems, Inc. as nominee for
American Home Mortgage Acceptance, Inc.
Execution of the Assignments
The Banks
appointed
individuals to
execute the
assignments
Example
Appointments
through a
Limited Power
of Attorney for
executing
Assignments
Many individuals who executed the

assignments knew nothing about the
documents they were signing, these
individuals are referred to as “robo-signers”
Individuals included bank employees, law

firm employees (lawyers, paralegals, and
even secretaries) and document preparation
and processing company employees
Thousands and thousands and thousands of
assignments . . . signed weekly.
Fraudulent Practices come in all shapes and sizes
Robo-signers
Fake witnesses
Fake notaries
Fake documents
False affidavits
Problems with Assignments
Not executed by the authorized person

Signatures not witnessed properly by
the “witnesses”
Signatures not properly notarized by a
notary
Forgeries m Assignments
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Sample One Sample Two

Who is the Real Linda Green?
American Home Mortga e Servicing, Inc. as Amtrust Funsing Servicies, Inc., by American Homc
successor-in-interest to . ion One Mortgage Corporation Mortgage Servicing, Inc as Att ney-in-fact.
Linda Green Linda Green

Vice President Vice President
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.

AS NOMINEE FOR AMERICAN BROKERS CONDUIT merican Home Mortgage Servicing, Inc. as
uccessor-in-interest to Option One Mortgage Corporation
Linda Green
Vice President Lind reen
-Vicet Presidew
-- zu mem presents t a he exec u:ed on th ts chte of 01/29/2007

MOR GAGE LECTRONIC REGISTRATION SVSTEMS,)NC. MORTGAGE ELECTRONIC REGISTRATION
ASNOMINEElòRAMERICAN ROKERS ON IT SYSTEMS.INC.
NDA GREEN
Li da Greeir VK E PRESI DEYr
Vide President
Linda Green
Linda Green’s “signature” appears on

hundreds of thousands
of mortgage assignments.
She is listed as an officer of dozens of

banks and mortgage companies.
A Few of Linda Green's Many Job Titles
- Vice President, American Home - Vice President, Mortgage Electronic

Mortgage Servicing, Inc. Registration Systems, Inc. (MERS), as
Nominee for American Home
042Vice President, Amtrust Funding
Mortgage Acceptance
042
Vice President, Argent Mortgage
Company - Vice President, MERS, as Nominee for
Family Lending Services
- Vice President, American Brokers
Conduit 042Vice President, MERS, as Nominee for
HLB Mortgage
042
Vice President, Bank of America
042Vice President, Option One Mortgage
042
Vice President, Citi Residential Corporation
Lending
042Vice President, Sand Canyon
042
Vice President, First Franklin, a Corporation
Division of National City Bank of
Indiana 042Vice President, Seattle Mortgage
Company
- Vice President,Wells Fargo Bank, N.A.
Scott Anderson, Ocwen employee
MORTGAGE ELECTRONIC REGISTRATION | MORTGAGE ELECTRONIC REGISTRATION

SYSTEMS, INC. ACTING SOLELY AS NOMINEE FOR SYSTEMS, INC. ACTING SOLELY AS NOMINEE FOR
DELTA FUNDING CORPORATION | FIDELITY MORTGAGE A DIVISIO A
FUNDING CORPORATION
By:
Name: Scott W. Anderson By:
Title: Vice President Name: Scott Anderson
Title: Vice President
MORTGAGE ELECTRONIC REGISTRATION MORTGAGE ELECTRONIC REGISTRATION

DE FU D NG C R , SYSTEMS, INC. ACTING SOLELY AS NOMINEE FOR
DELTA FUNDING CORPORATION
By:
Ti I V ce President
Forgeries by Mortgage Servicers
O
Who s TywannaThomas? Who is Jessica Ohde?
T a Thomas Je si a Ohde
Asst. Vice President
Vi sident --
Asst. Vice President

T nna Thomas
t. Secretary
Vice President
Jessica Oh
Tywan Thomas Asst. Secretary
Asst. S cretary
A Mortgage Servicing Company
Mortgage servicing companies help banks

obtain foreclosure by preparing documents
necessary to facilitate the foreclosure in
Court.
These companies hire robo-signers who
execute the documents by the tens of
thousands per month.
Mortgage Servicing Companies
DocX had offices employing dozens of workers

producing thousands of fraudulent assignments.
Lender Processing Services produced 2,000
assignments each working day.
GMAC (including its first famous robo-signer,
Jeffrey Stephan) also produces 2,000 assignments
every day.
Nationwide Title Clearing out of the Tampa area also
produces 2,000 assignments every day.
Forgeries in Other Documents
O
Ptupared by:
Deed Dan 2.73Let
Istang 1.5EAes
nox 7 !Íbhrem R. Beck,CLEBR & CEMPTRERA.ER
rem amar - 2ases saw
ImunNumber: 561005223 042 SemdogNamber 0020B0902-6 ··. Dae 02/03/06
ALLONGE TO NOTE
40 ....... (INVESTOR)
SS" AI LONGE TO NOTE
042 042rm-
n=a (INVESTOR)
Deed Dec 2,738.08 .. c. ms. .
Intag 1,5ELet
Ilbkre R. Beck,CLERE & CMPTBtt1R
Pts 12 - 1848; (14pgs)
Forgeries in Other Documents
O
imasuisissanssuasis||
WHEN RECORDED MAIL T LFN 20060092890
GR BK 19933 PG 1827
Prepared by
RECORDED 02/ 15/ 2996 88 : 27 :
& 70
Pa u , orida
ART 789, ese. 98
Deed Doc 2, 738. 09
Loan Number: 561005223
Intang 1, 568. 99
Servicing Number: G02080902 Sharan R. Bock, CLERE & CORPTROLLER
Pge 1827 - 1848; (14pgs)
MORTGAGE
on February 33, 2006 .The mortgagor is
MORTGAGE
whose address is 8268 MAN -D iSR RD , ?AIA BEAQ GARDENS. FL 23418-
(" Borrower").
Examples of Bogus Documents
T he Grantee is identified as "Bogus Assignee."

4%lt.N.%Il %I of MORTr. ga.4
It PM G000 4%D 4 4LE 4 BLE < 0%MDIR.4 |10%. t va . ." . e .
a'am:NJed %IORIL 4CF i LH TRO.%K' RtGl%TM4 I!O% ½ %14 45%.1%( nyl%I p Fetk
Mt RK 4% anaMR4 CO%DL IT www .4Jncs. r. s§en er e, e ene,c sp...r, en . pu s . .
tN,creewt kriq pu hepe win eiy :re.mc.-nse vs-.sc w.h· r....BO(,,q%
fr. toui%IPM4}%LNG 4%fT\ arv d"-as , \\\\\\%\\\%%%
. .v.Nd w.cge. %sg the pera . t a ccnue reon.s...<s r,.ro a L.e du e.,4 . . ..
.*nal i,,N:.trwrcorai;.co., ,rtg_,,srcs.es.rw.n.l.4-et .. .5:,,n.<., n .J. .
(w ..I h..urr.sr M4%LILGO3241.EL.4%I4HNIEDPfMso%

in. ..isLwnee %IORTd.4t.FFl.FCfkO%ic RtGisTk4T16%ustpMs,t%<
f t pR OtERIE 4% itk( phi R5 1 0%Dt II
lh.a½ng.apr 612'Jeu6 l.w: g...y... m2.ts0enti
t·UK GOOD AND VALUABLE CONSIDERATION, the rcccipt and sufficiency of which is hereby
acknowledged. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
AMERICAN BROKERS CONDUIT, whose address is 6501 f rvine Center Drive, Irvin
hv these nrersents harnhw uront h,rn-.in call ar i'_'a transfer, convey. set over and dehver u BOG LS |
ASSIGNEE FOR INTERVENING ASMTS, shose address is XXXXXXXXXXXXXXX
aiu promissory note(s) for the sum listed below. together
with all rights therein and thereto, all liens created or secured thereby, all obligations therein described, the
money due and to become duc thereon with interest, and all rights accrued or to accrue under such mortuaue.
The Grantor is identif ed as "A Bad Bene."
(N WITNESS WHEREOF, the undersigned has caused these presents to executed on this d
04/27/2009.
A BAD BEN
Witness: Dawn Williams K cli Harp

Vice President
Witness: Christina Huang
Korell Harp and Tywanna Thomas, known to me (or

) that they are the Vice President and Asst. Vice Pres
pharmatkrea Merl
are 4.ese assM. a say r. er. e6
FOR GOOD AND VALUABLE CONSIDERATION, the receipt and sufficiency of which is hereby
acknowledged, Amerlcan Home Mortgage Acceptance, Inc, whose address is
does by these presents hereby grant,
bargain, sell, assign, transfer, convey, set over and deliver unto BOC US ASSIGNEE FOR INTERVENING
BOC US ASSIGNEE FOR INTERVENING ASMTS,

=.=.: with Interest, and all rights accrued or to accrue under such mortgage.
Original Borrower(s): MARIA MORALES A SINGLE WOMAN AND SANTIAGO AZAHEL GARCI
Original Mortgagee: AMERICAN HOME MORTG AGE ACCEPTANCE, INC.
Date of Mortgage: 07/05/2005 Loan Amount: $158,000.00
Recording Date: 07/IS/2005 Book: 23578 Page: 260-283
O
The effective date is in the year 9999.
un.>4Laired, Amereren Ilesie MereNase Sencrig lac, ·..bsc a:J v naMN [nime Centrr Drnc,
rtgagee: HOMEBANC MORTGAGE CORPORATION

tgage: 05/03/2007 Loan Amount: $
>ate: 0 Book: N/A Page: N/A Docu · 200
ients. ASSIGNM ENT EFFECTIVE DATE 9/9/9999
SCRI ONDOMINIUM PARCEL: . A-1
NIUM DESCRI ECLARATIC
AS RECORDED IN OFFICIAL RECORDS BOOK 231, 1
042ITIONS
AND AMENDENTS TO SAI D DECLARATION
The blank line, witnessed and notarized.

IN WITNESS WHEREOF. the undersigned has caused these presems to be executed on this date of
11/25/2008
American Horne Mortgage Servicing, Inc. as succeswr-in-interest
to Option One Mortgage Corporation
W9hess Kerell Ha . Lin ja reen

Vic : resident
,Tywanne Thoma
.. ard er.4: s.s#J rhyus axacu® ér mq *ttJ ts.hre --..w.qw .. Asst Vice PreMdent
hadao uget ramerJ 8Je wwrwhg 6.s <wp raN6 see6 N t
I 2 41 a n. L_________________________________________________________________
u arche m > twY duk 4 trea e · 042w
M NeaN - c·< W-
Assignment of Mortgage
C FN __2ûO9-Rû3.6._4085
,QR-W26871 Ps 17473 (irsT''N
( RECORDED 05/19/2009 12:08:00
ASSIGNMENT OF MORTGAGE wr =r+ c tu ou=
ftIAMI-DWDE- COUNTTTTLO9IDA
LAST PAGE
FOR VALUE RECEIVED, on or before October 04, 2008, the undersigned, MORTGAGE ELECFRONIC
REGISTRATION SYSTEMS INCORPORATED AS NOMINEE FOR LITTON LOAN SERVICING, LP,
("Assignor") whose address is 1818 Library Street, Suite 300, Reston. VA 20190 assigned, transferred and
conveyed to. LrITON LOAN SERVICING LP, AS SERYlCER FOR GSAA HOME EQUlrY TRUST 2007-
2, ("Assignee") whose address is 4828 Loop Central Drive, , Houston, TX 77081-2226, its successors and/or
FOR VALUE RECEIVED, on or before October 04, 2008, the undersiped. MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS INCORPORATED AS NOMINEE FOR LITION LOAN SERVICING, LP,
("Assignor") whose address is 1818 Library Street, Suite 300, Reston, VA 20190 assigned, tramiened and
conveyed to Ll'ITON LOAN SERVICING LP, AS SERYlCER FOR GSAA Il0ME EQUIFY TRUST 2007-
2, ("Assignee") whose address is 4828 Loop Central Drive, , Houston, TX 77081-2226, in successors and/or
MORTGAGE ELECTRONIC REU!STRATION

SYSTEMS INCORPORATED AS NOMINEE FOR
d Name Patricia H
Ty ame YamelAHemandez
Corrective Assignment of Mortgage
|||||11||||||||||||||||||||||||||||||||||ll||
faFB 27 - - - - - -- __
RECCRDE LI ..-Ar 9 '. 4 9 2 ( 1 p9 )
o ECERDED 01/O'/ 0 0 11:38:35 )
TtMVELSUVIb, (LERK OF EllM
I AF I - 3Alf--füÜ¯ÑTTí--f 575DA
CORRECTIVE ASSIGNMENT OF MORTGA A I PAGE
FOR VALUE RECEIVED, om er before October M, 20O6, the edemiged MORTGAGI
REGISTRATION SYSlEMS INCORPORATED AS NOMINEE FOR *AXIOM FINANCnAL 5Env10t4.
FOR VALUE RECEIVED, on er befwe October N, 2006, the admip4 MOR1EAGE ELECTRONIC
REGISTRA110N SYSTEMS INCORPORATED AS NOMINEE FOR *AXIOM FINANCIAL SERVICES.
CAssigW) whose addres is _ __ ___
mip4 hufend and conveyed to: 'DELTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE FOR GSAA HOME EQUITY 11UST 2007-2, ASSET-BACKED
CERTIFICATES, SERIES 20M-2, ('Asäpee") whme addas is 4828 Imp Cenal Dnve, , Homton, TX
hPUA =====ta
Prun Narre
Filing Lis Pendens Without Standing
11|I|||||||||||111||||||||||||||||||||||||||
CFN 2OOBRO811447
DR Bk 26596 Ps 3771; (1ps)
RECORDED 10/03/2008 15:54:10
RVEY RUVI CLERK_OF COURT
IN THE CIRCUIT COURT OF THE ELEVENTH
JUDICIAL CIRCUlT IN AND FOR DADE COUNTY, FIDRIDA
CIVIL ACTION
CFN 2r -oggt
US BANK NATIONAL ASSOCIATION AS SUCCESSOR TRUSTE
OR Bk 26 6 Ps 3771; ( ip s )
TO WACHOVIA BANK, NA, AS TRUSTEE IM)R WFASC 2005-
AR13.
RECORD D 10/03/2008 15:56:10
HARVEY N, CLERK OF CDU
F1IANI-DADE
NOTICE OF LISEENDENS INES PRINE; THE UNKNOWN
LAST PAGE
MING BY, THROUGH, UNDER,
AND AGAINST THE HEREIN NAMED IND]VIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE
DEAD OR ALIVE, WHETHER SAID UNKNOWN PARTIES MAY CLAIM AN INTEREST AS SPOUSES,
HEIRS, DEVISEES, GRANTEES, OR OTHER CLAIMANTS; WELLS FARGO BANK, NA; THE
GRANDVIEW PALACE CONDOMINIUM ASSOCIATION, INC.; TENANT #1, TENANT #2, TENANT
#3, and TENANT #4 the names being fictitious to account for parties in possession
Defendant(s).
NOTICE OF LIS PENDENS

To the above-named Defendant(s) and all others whom it may concem:
You are notified of the institution of this action by the above-named Plaintifi; against you seeking to foreclose a
mortgage recorded in Official Records Book 23278, Page 3642, on the following property in DADE County, Fkh
UNIT NO. 407, THE GRANDVIEW PALACE CONDOMINIUM, ACCORDING TO THE
DECLARATION OF CONDOMINIUM THEREOF, AS RECORDED IN OFFICIAL RECORDS
BOOK 21423, PAGE 3980, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FIDRIDA,
TOGETHER WITH ANY AND ALL AMENDMENTS TO THE DECLARATION AND ANY
UNDIVIDED 1 REST IN E COM MON ELEMENTS OR APPURTENANCES THERETO.
Dated this W xiay of 5 e 4m 4 C , 2008.
Florida Default Law Group, P1
P.O. Box 25018
Tampa, Florida 33622-5018
(813) 251-4766
Assignments After Lis Pendens
||1||||||||||N1I||||11|||lll||1||||||||l|||
||||||||I|||lNR R|||11||||||111||||||I11||1
ASSIGNMENT OF MORTGA CFM 08RO9541
OR 26663 Ps 27296 (los)
R 11/25/2008 20:16:35
ASSIGNMENT OF MORTGAGE HA RWIN, CLERK OF COURT
NIANI-
and haerust of Ansigant in and to dut certaia Martyne (the
15, 2005 hi Official Raocsds Book 23273 m Pass 3642 e
042¼ LAST PAGE
enaattberingthe foDowingaSesertMrealproperty:
UNIT NO. 407, IllE GRANDVIEW PALACE CONDUMMIUM, ACCURDING TO THE
DECLARATION OF CONDOMINIUM THEREOF, AS RECORDED IN OFFICIAL
RECORDE BOOK 21423, PAGE 3900, OF THE PUBLIC RECORDS OF MIAMI-DADE
CDUNTY, FIORIDA, TOGETHER WITH ANY AND ALL AMENDMENH TO THE
DECLARATION AND ANY UNDIVIDED INTEREST IN THE (X)MMON ELEMENTS
OR APPURTENANCES THERE10.
as the sanne may have been emunded from time to tirer; together with the Note and mdebiedenis secured thereby.
MORTGAGOR(S): ROBERT PRINE, and INES PRINE
IN WHEREOF, As has excetnad and deEvered his hutrument an
WELLS F NA
Patdcla Hutchens
T A in-Fat
Ta
Filing Lis Pendens Without Standing
IN THE CDtCUIT COURT OF THE ELEVENTH
O CFN 997
JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY,
FLORIDA OR 771 Ps 4057; (1ps)
CIVIL ACTION ECORDED 03/03/2009 09:49:18
HARVEY RUVIHr CLERK OF COURT
CHASE HOME FINANCE LLC, ANI-DADE COUNTYr FLORIDA
Plaintiff, 0 9 - 1 5 3 3 7 Ch 0 ! L GE
VS.
CASE NO. S'^ 442
" 442 442 442'®³*
DIVISION
cADunQ A Dn1AS. MWIFA NAVnD- AMV AND AI.L UNKNOWN PARTIES CLAIMING BY,
D INDIVIDUAL DEFENDANT(S) WHO ARE
D UNKNOWN PARTIES MAY CLAIM AN
i, OR OTHER CLAIMANTS; JPMORGAN
NOTICE OF LIS PENDENS 5, and TENANT #4 the names being fictitious to
NOTICE OF LIS PENDENS

To the above-named Defendant(s) and all others whom it may concern:
You are notified of the institution of this action by the above-named Plaintiff, against you seeking to foreclose a
mortgage recorded in Official Records Book 25587, Page 712, on the following property in MIAMI-DADE County,
Florida:
LOT 39, IN BLOCK 2, OF SHOMA HOMES AT TAMIAMI H. ACCORDING TO THE PLAT
THEREOF AS RECORDED IN PLAT BOOK 145, AT PAGE 71, OF THE PUBLIC RECORDS OF
MIAMI-DADE COUlVrY FLORIDA
Dated this M day of M1A () , 2009.
Florida Default Law Group, P.L.
P.O. Box 25018
Taen C1dAm 134Y) CA10
Assignments After Lis Pendens
CVN 296
OR 6814 Ps 49511 (los
ASSIGNMENT OF MORTGAGE ECORDED 04/03/2009 08:59:0
HARVEY RilVIN, CLERK OF COURT
fil-DADE COUNTY, FLORIDA
FOR VALUE RECEIVED. on or before February 18, 2009, the und LA
ed
ASSIGNMENT OF MORTGAGE Dinterest of Assignor in and to that certain
mungsgc puc mungags i uncu ng n av, avvi anu iswivm m.y v3, 2007 in Official Records Book 25587 at
Page 712 of the pubhc records of MIAMI-DADE County, Florida, encumbering the following-described real
property
LOT 39, IN BLOCK 2, OF SHOMA HOMES AT TAMIAMI II, ACCORDING TO THE

PLAT THEREOF AS RECORDED IN PLAT BOOK 145, AT PAGE 71, OF THE
PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA
as the sarne may have been ameraded from time to time, together with the Note and indelsedness secured thereby
MORTGAGOR(S); CARLOS A. ROJAS, and NEIFA NAYOR
IN WITNESS HEREOF, Assignor has executed and dehvered this instrument on

2009.
Affidavit of Amounts Due
AritmM
IN THE CIRC1R CD4 IRT OF 11EE SEVENTIEPrTN JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVILACHDN
US BANK NA T10NAL ASSOCIA TION AS TRE5TEE

FOR RFM51200nt,
FIsadN.
CASE l40.z CACE89022986
vs. DIVISION:09
ERIC SITERSON.et al,

Dehudame(ak
AFUDAVTT A510 AMOt DUE ANDOWING

STATE OF
COUNTY OF
Jeffrey Stephan
AFFIDAVIT AS TO AMOUNTS DUE AND OWING

GMAC MGRTGA GV, LI f ts the o h of the loma O MAC %eOR TGAGE. LLC e 1espannsMe for the collectum M
tholoane-4=andpia.sui:ofamy dehnquencyimpeymeras Jamhmdiar wuh:netonbefa.-countandhave
eumend al1%e'as.recteds.end&arneon keptby GMAC MORTCAGE.11Cearserneg±etuniacdomsaustodin
the Counph-sn. AP ofthese backs. ricar.s and cocarnents se kept by GMAC MORTG AGE, LLC m the reguhr r.ourse
of its buseman an serwcw M the loor, uanseenco and are made as or near the une by . und than cJbrmaban tranandred
by . perwas widi pernomal ka® Mgs of to facts such as your Amaat. h is the reguir prec1ice of GMAC
MORTGAGE, LLC to and keep these beob, mads. and documents. The boor.s, records, ed docunnects u¾ch
Affidavit of Amounts Due
Arit20M
IN THE CIRC1R COURT OF 'IIIE SEVENTIEPrTN EDICIAL CDtCUIT
CIVILACHDN
US BANKNAHONALASSOCIATION ASTRL'5TEE
FORRFM51200nt,
FIsindff,
CASE fv0.zCACE89022986
vs. DIVISION:09
ERICSITERSON,etal,
Dehdeme(ak
AFUDAVTT A510 AMOt DUE ANDOWING

STATE OF
COUNTY OF
Jemey Stephan
411 ÍnEnku W! E h Ok.5 . is (Oullt Ed bis e
of its buseman an serwcw M the loor, iranseenco and are made as or near the une by . und than c.lbrmaban tranandred
by . perwas we pernomal ka® Mgs of ihe facts such as your Amaat. h is de reguir prec1ice of GMAC
MORTGACÆ, LLCtoinskmandkeep' beob, mads. a
TypeN Jeffrey tephan

limited Signing OfScer
Withdrawal of Affidavits of Amounts Due
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
CIVIL ACTION
U.S. BANK NATIONAL ASSOCIATION AS

TRUSTEE FOR RFMSI 2007S1,
Plaintiff, CASE NO.: CA CE-09-022986
vs. DIVISION: 09
NOTICE
, uma,un .o n ,- ,, . v Professiona! Conduct of the Rules Regulating The Florida Bar, the undersigned
law firm hereby notifies the Ceurtas follows:
An affidavit of indebtedness was ser ved tn the above-styled matter in support ofPlaintiffs motion for
s'ammary judgment, ("the Afödavit").
2. The undersigned law firre. has recently been notified that the infonnation in the Afúdavit may not have
been properly verified by the affiant; and accordingly, the Affidavit is hereby withdrawn.
3. The undersigned law finn was not awa-·c ofthe foregoing information when the Affidavit was fled
whh the Court.
4. The undersigned law ñrm dr afted the Affidavit based Uoon the information and business records
prodded by its client, ud to :ne best of its knowledge and :nfonnattori, believes, in good faith, that the amoun'.s
reflecting -he indebtedness contai-:ed therein accurately refle:!cd he information provided by is client and were believed
:o be correct wher Sled.
5. A new, properly verified affidavit will be filed when and as appropriate.
Withdrawal of Affidavits of Amounts Due
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
CIVIL ACTION
U.S. BANK NATIONAL ASSOCIATION AS

TRUSTEE FOR RFMSI 2007S1,
Plaintiff, CASE NO.: CA CE-09-022986
vs. DIVISION: 09
ERIC SIVERSON, et al,
Defendant(s).
NOTICE
Pursuant :o Rule 4-3.3, Ru:es of Professiona! Conduct of the Rules Regulating The Florida Bar, the undersigned
law firrn hereby notifies the Ceurtas follows:
w:in ||'e tourt.
4. The undersigned law ñrm dr afted the Affidavit based Uoon the information and business records
prodded by its client, ud to :ne best of its knowledge and :nfonnation, believes, in good faith, that the amoun'.s
reflecting -he indebtedness contai-:ed therein accurately refle:!cd he information provided by is client and were believed
:o be correct wher Sled.
5. A new, properly verified affidavit will be Oled when and as appropriate.
1. Note the address of the --~~"---
Assignor, Home Savings FOR vALuE mECEsvED, .. er hane. - in, maa es ..&sup.d. nOuE sAvneGs OF
of America F. A. (HSA) mEmCA Fx <-- - - m 042
I I + ...merr.d .mi s....yed = meORGAN CHA$E
is blank. HSA was BAMK, NATIONAL ASSOCIAT90N, (*A ") whoes addrums is 72$$ Beysumedent Way. Meltmop Jana
acquired in 1998 by 2035, e ne, FL 32256, sus asser ammys, mal of the nghi, nula, sad unserest of Assignor in med to
that cerman Monpas (das "Manpgs") demd August 26, 1985 and reconled 254 06, 1988 un OMicual
Wahington Mutual Bank Records Book 5495 m Paes lité of te pubhc receeds of HILLSBOROUGH Coussy. Flonds, encuenbenag the
fonowing-dummeed real property·
(WAMU) they no longer
exist. LOT & BLOCK G, REVISED MAP OF BAY CITY. ACODRDBMG TO MAP OR PLAT
THEREOF AS RECORDED IN FIAT SOOK 3, PAGE 54. OF THE FUBI.JC RECORDS
OF HitMIBOROUGR COUNTY, Fl£REDA. TOGETNER WITE THE MORTH 3/2 OF
CLOSED 14A0 FOOT ALLEY ABUTTING ON THE SOUTR.
as the smene eney have base asnanded boss tisms to tiens, angsuher wie en Naas and indsheedems ancwed eerstry.
MORTGAGOR($): GRADY B SYKES 11

........ , .. . . . . s.a n...........e......m.w.. .w . . n. s.. . . a m..y 3 Note the signers
ctosso iue FOOT AM2Y Amurfrec OM mE $0UTH.
for the Assignar.

I lame Savmgs of
2 Note the date of the r4 "'"*"'"*"*"'"*"""" Amenca F A
assigrunent, December .P (llSA) They are
22, 2008 wluch is after not employed by
thclawstut was filed on "°°" C^' I lame Savmgs.
December 18, 2008 - -- they are employed
-- 1,,,, ww. e
by the Plaintiff. J P
4 Notice the Notary. D l''' Morgan I lome
Pekusic and the witness. w... . Savmgs was
Rushir Causevic, both acqtured m 1998
attesting to the fact that, by Wanlungton
known to them. Patncia Mutual 13ank
Miner is an Asst Vice ATuo, R'nen (WAMt ) they no
President of IISA and that longer exist
Ann Garbis is a Vice " '" "F ir""'
President of IISA IIome ===a--====be n.-*====en.
hru turned er kwamma m m Adv nhy .ad e
- =: = .a m-,
em Amr m A. Aw me a.d omd
Savmgs was acqturedm |.tnomyorAmanicAr a.. fr. d.r.t ae2 / -mass
1998 by Washmgton - /,/,,
Mutual 13ank (WAMl;) -+ hv
they no longer exist rapn.e inev * 2co'
N.ndye c.b.us
F1.rtd. Dehuh Law G.map, FL
e o a..neis
Te hreda tuit.ela
W49.9.010ist.UTLAL hfe AS TOI., JT 4
Sample Notice of Lis Pendens
... . This space is for recording purposes only
lN THE CIRCUIT COURT OF THE 15TH JUDICIAL

CIRCUlT, IN AND FOR PALM BEACH COl;1,NTL
FLORIDA -a1..
GENERAL JURISDICTION DIVISION

(- CASE NO: 040
.
US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR MASTR
ASSE 1 BACKED SECURITlÈS-TRUST 2006-NCl
PLAINTIFF
VS.
VICTORIA R. MUNNILAL, UNKNOWN SPOUSE OF VICTORIA R.

MUNNILAL IF ANY; ANY AND ALL l)NK.NOWN PARTlES CLAIMING
BY, THROUGH, UNDER, AND AGAINSITHE HEREIN NAMED
INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE DEAD
OR ALIVE , WHETHER SAID UNKNOWN PARTIES MAY CLAIM AN
'NTERES I AS SPOUSES, HEIRS, DEVISEES GRANTEES OR OTHER
CLAIMANTS- THE TRAll.S AT ROYAL PALM-BEACH, INCa JOHN
DOE AND JANE DOE AS UNKNOWN TENANTS IN POSSESSION
DEFENDANT(S)
NOTICE OF LlS PENDENS
1. TO The above named Defendants, AND ALL OTilERS WHOM IT MAY CONCERN: . . .. . ,.
2. YOU ARE NOTIFIED of the instdution of this acnon by the Plaintiff against you seeking to foreclose the Note
and Mortgage encumbering the described property and the decrecing of a sale of the property under the direction of
the court in default of the payment of the amount found to be due the Plaintiff under the Note and Mortgage, and for
other. further and general relief set forib in the Complaint.
3. The property involved is that certain parcel, lot or unit situale, lying and being in PALM BEACH County,
Florida, as set forth in the mongage recorded in Official Records Book 19434, at Page 1244, more particularly
described as follows: ·rt s'', I t-'ll I
Stamped signature on Assignment of Mortgage
. '11 -r. . f. Ifrt t turfu
A%R NMi¯ T 01 MORTGAGE

f·21 r_ JD 1 1- 0421
t 1 .'
hihw -. ET T l ": h .N h . r n .IJ-_ IE FI(LFWY'T . A 5' t N r Em .i r. Lri ». farsari -. m
s. · d he ..pet.f.¿;p i .'.s 1 aage .u.-A-at 6.o
i.44a. le.4.' h6· -4'-r .ret.. ra.1 stad a 6art Marenf
1 e64si· . iltang.
». .., , : .r,.r · s 2. . . .... . N . -.. 1-. r -t. qe - : :e
-s.m. a........).s a.- en

Stamped Signatures
This forrn was prepared by New Century Mortgage Corporation
add.-ess 18400 von Karman, Ste 1000
Irvine, CA 92612
For value Received, the undemgned holLler of a Mortgage (herein "Assignor" ) whose address is 18400 Von Karman,
suite 1000, Irvino, CA 92612
dut-s hereby prant sell, asùu,n. tranger and eenvev, unto O 6&n k. Na+. wW Ash-i n+ °n , a s tr-ueA ec
te A½et.. - P>öc26ed ros<-. th0üzjn £ 254#4,ficæ4cS..
fe,ed e5 zoo4
a corporation organized and existing under the laws of (herem "Aoignee"1.
whse add res> ls
a cenaul Mortgage dated July .11, 2006 , made and executed by
CHRISTIAN J CASSINI and RIE A BAIDAL, Husband and Wife
le itnd in favor of New Century Mortgage Corporation upon the

fbilowing descobed property situated 01 PalmL Beach Coun State of Honda
See Legal Description Attached Mereto and Made a Part Hereof
.such Mortgage havmg been given to secure paynient of TWO HtJNDREI

(S 280,000 00 )
042
|rit it.3|t 11- t .¿1t Iir ,-i ppl Arrmt.r1
No àOLfD , at page (orm Nú

Palm Beach County, State of F1
described and the money due and to become due thereon with mterest, 1 - - -
TO HAVF AND TO HOID 1hc same umo Assignee, its succes
conditions of the above-desenbed Mortgage
lN WITNESS WlERl'OF, the undessigned Assignor i
July 24, 2 6
c Stephen I, Nagy / V P \Records Management
Seal
State of Cahfornia
County of Orange
Stamped Signatures
¿·. 1.f ·J = n p- -d Er. r utture lori n e f er geratha
at1. rr¬i |1400 Katr..s-· te 3DD0
Tr-str-e CA 924L2
AS$1GNMENT Ol· MORTGAGI

I - . I o.. . .¬L tte b ·· ed a &c il a M r act ut.-.11 í·.s ,-1.-r t s- 61.re--* - Vori pt n
tunt.a 3DOO. Izvirte, CA BJt]2
s-aLwtH-sy.e c· ber *. 2605 -3. - c .1 .

·lt---t÷r.a p sqw ;st . A 3:14., wiser
i · --p- ir ein·. - art Cc.g·p-.rat- .r p· ·

r... .....'-d-.va.- -r..su. .Pata aew. 1.u-r. sair -- a,
see lege. Eest·rtptat.r Att2- 1 not 'e sti1l lende a Fart S
*>.' '-L d'64-r 6 ..1 P - 1· w. 6rr ·.·.1r..ii, i CNN
rela u.a.».
.-.t-.J sr.!1 .· IT..+r. 16, c...s¬r. i- g;.c
h l II.I H. l [. sr ...rrr- arp- i t.:.,
..' h di scJrc rJ '. --
.. £orporati on
Stephen L. Nagy / A.V.P.Wault Services

). --
5t 042s:han
i Na r .· A y r .v sarh-ea ,* .
F ha ng·.
Affidavit of Correction due to assignment of a
mortgage that had been fully paid (St. Lucie Co.)
Affidavit of Correction due to an assignment of mortgage
that had been fully paid. (Palm Beach Co.)
Affidavits of Correction due assignments of mortgage that had
been fully paid (Broward Co. and Palm Beach Co.)
$164k Question
At i E n :inte.g. Fi<wr T-.
wt nry _ nc* Signature Title

.toleil. --.- vm:i 8456W L;DelmhjhAw
i. Mr..,.Itui" I cu - "Mn Rimpa 4 33625
yn Atsi.ir -Ih6i L6er Fier firewomg t>ssa.
WRS hemr ll*C N.eMt J e Sé

MORTGAG F.
OF F''NEWNS
lTlls t .P f. 5 2542Si}II§
042:d
Ús|5 CCClifI)cilt sif il1[ _ .ind c#t.T wcire.s irt Jcf rr:c .T1 3.·c-·isiiis .l. I.1 I b.
Al "Secertly Instrument" rr sru *his dccumetTI. which it, lir..+d JULY 26. 29h. 1,:gethcr th irl: Rt irr "11s incrx-.:¢ti
IR1 'Betriswer" i. KARL.E%E I.L.Dw1G, A $11NGl.I PERM.1N anil Al.FREDH. EANrlLLR %INGLE PERMIN.
B._comer ±s the roxy.ipt miJr das security Irmrent
K I "MERS" n hpge Ehvtr.e>: R.·giseruh..e S±·>m. Iw N1E11s n . upruic r. nuen r.wp n utmg wicl:. y >.
nrit.uc rtir ..r ú:r ce l.:r.dcr> :mu-an iiid .mtgrx MEN.N ts the mortgagee liasler thin Sectarity Instrtiment \llM ,
i i i f t'. 71
(E) "Note" means the promissory note signed by Borrower and dated JULY 26, 2006. The Note states that Borrower owes
Lender ONE HUNDRED SIXTY-FOUR THOUSAND NINE HUNDRED AND 00/100ths Dollars (U.S.$164,900.00) plus
interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than AUGUST
1, 2036.
fGi Luan" mtun : Jmt4|tter»;eJb th Nec phis rcf. .svprcp,wmemch .Dd 1 C c ir E 7CCf E
I:yrr= Jc. .rdr.,Ibn¼ccirityIe.r,c".piv.mtcr.co
rH Riders" .1 .ut. <l Rs.h-> t. the. New.5. Muumort h: ac e..».uted :., Har:.wer 11-e iatic ry R.trs..ret,:.n
a_t.jitc hv !b rr:wt: ct,cck b: c n gr'.c.shle I:
. ··..thidil! 4. .lt't·f +ilqJl . .L'ait L lt Cf
R.dl..vPuh- IIPla,cal k.chrpmciaR..ki

Flect Reite Rttk
And you thought your mortgage was high?
Preparce ny ROSHNi SUVAR
Ccwer toen Semceg -LC
W,i Wm!ne,ger- R:e m,* 1%
West Fairr hr1 FL L4r29
FrowNutter ½les24!LB
ALLONGE
BORROWERS: KARLENE LUDWlG AND ALFRED H, EASTBUEN
PRt.SINTOWNfH AND HOLDER. MORTGAGE ELECTRONIC REGISTRATION

SYSTEMS. INC. ACTING SOLELY AS NOMINEE FOR SEBRING CAPITAL PARTNERS.
LIMITED PARTNERSHIP
NOTE EXECU TION DAT1. JULY 26, 2006
NOTE AMOUNT 542,214,400.00
i hs almoe shai te amexeri :n me crainal Nere ior to a ccpy of t,c Note wth a ( ost
"° BORROWERS: KARLENE LUDWIG AND ALFRED H. EASTBUEN

REGISTRATk
PRESENTOWNER AND HOLDER: MORTGAGE ELECTRONIC REGISTRATION
SOLELYASP SYSTEMS, INC. ACTING SOLELY AS NOMINEE FOR SEBRING CAPITAL PARTNERS,
LIMITED P
Date MARCI
OTE EXECUTION DATE: JULY 26, 200
NOTE AMOUNT: $42,214,400.00
EQUITY LOAM TRUST 2007-HE1 ASSET BACKED PASS- OUGH
CERTIFICATES, witho t 'eccurse representatio an'y
e. - tti s 741H c5 , .te
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC

ACTtNG SOLELY AS NOMINEE FOR SEBRING CAPITAL
PARTNERS, UMITEDfARTNERSHIP
Nanie Scan Arev_r

TiJe wePrese
OFD Laan N.nr.w 80280977

Assignment for Defunct Assignee
Repwd by ar×1 Reruariu, RECORDED 68/99/2810 14:e7se2
4-irrn Ihriluk, ¾hneste, Palm Beech County, Florida
4 VG Highlaw Trel, Sue M Sharon R. Bock, CLERR & COMPTROLLER
N4.ady5prim,riA vi35a Pgs 1144 · 1145: 42pge>
Fec5wNurnte 123 989
-- Assiennent of Mortrare
Assignor. Mongage Electrumt Regatration Systems hr. as nomirwe for AMLKlC AN
Assignèr;Mortgage Electronic Registration Systems Inc., as nominee for AMERICAN

BROKERS CONDUIT, whose address is e/o CitiMortgage, Inc., 1000 Technology Dr., O'Fallon,
M063368d r /
iv, aAm, recoraca among me I,ano kecorus at F ALM Bt.AL H Lounty, Honda m bk Sm7,
Page 0677. as htstrarmit a 2iK 153 t 22 in the original prmeipic amomu of $222,203.(X)
Property Addreu· 3201 RENAISSANCE WAY, bü
Property Addres-sT3-20FRENW15$ANCE WAY, BOYNTON BEACH, FL 33426

wimess um ch 3 CM C ,---'
Witness this Î£ h ÚÚOI D

Mongage c Reg ---------------------
àn ui-. öäOK£natunutui
Scott Schemer. Assistant Secretary

American Brokers Conduit BANKRUPT
8 7 2007
Official Form 1 (04/07)

United States Bankruptcy Court . .
DISTRICT OF DELAWARE Voluntary Petition
Name of Debtor (if individual, enter Last, First, Middle): Name of Joint Debtor (Spouse) (last, First, Middic).
Amencan Home Mortgage Holdings, Inc.
All Other Names used by the Debtor m the last 8 years All Other Names used by the Joint Debtor in the last 8 years
(include married, maiden, and trade names): (include married, maiden, and trade names)·
fo digits of Soc. Sec JComplete EIN or other Tax 1.D. No. (if more than one, I ast four digits of Soc. Sec/Complete EIN or other Tax I.D. No. (if more than
one, state all);
Street Address of Debtor (No. and Street, City, and State): Street AdÃess of Joint Debtor (No. and Street, City, and State):
538Broadhollow Road
Melville, NY
CountyofResidenceoroftfu
Suffolk, NY W TI-IE WITED STATES BM'KRUPTCY COURT
MailingAdd essofDebtor(i: FOR TIIE DISTRICT OF DELAWARE
Location of Principal Assets (
---------------------------------------- ------- ---- X
fC In re: : Chapter 11
(Check on
AMERICAN HOME MORTGAGE HOLDINGS, INC., : Case No. 07-11047 (CSS)

2 Corporation (indudes L
0 Partnership a Delaware corporation, et al.,
° Joint Administration Pending
Debtors.
_----_-___------_-_------------ ----- --------------------- X
AGENDA OF MATTERS SCHEDULED FOR FIRST DAY HEARING ON
A U GUST 7, 2007 AT 3:00 P.M. (ET)
Assignment by a defunct institution
. Sharon R. Bock, LERE & C0
I'his Instrument Prepared B) Pgs 1839 - 1941: 139081
And Returned To:
Dannel C. Comuegra, Esquire
9204 King Palm Drive
Tampa, FI 33619-1328
OWB-OneWestBank.FSB s. Gunerret Lnel & Fs ette

File No. 8l10
Loan No.. 1007SS936 I
COMES NOW. MORTGAGl l.L LCl RON!( REG151 RA FION SYSTEMS. INC.. AS
NOMINEE FOR INDYMA( BANK, F.S.IM'aereinafter assignork and further in consideration of the
sum of -- {SBC B
USA. gaech pr
INDYMAC BANK, F.S.B.(hereir

V (C
mer unto the said assignee hat certain indemo?e of mortgage bearing tae date June 26. 200(
hy l RIFl. GUTIFRREZ, IVET 1 F Gl 1ERRbl. and :ecorded in BOOK 20581, PAGE 15
pubhc records of Palm Beach Coumy. I LORIDA .pen the follow mg desc:òed pici e or pm -
situate und being in Palm Heach County. FLORIDA. to w t

day of 2010.
IndyMac, out of business CLOSED July 2008
Federal regulators seize crippled IndyMac Bank

A run on the Pasadena thrift ends in one of the biggest financial failures ever.
Doors will reopen Monday.
July 12, 2008
July 12, 2008|Kathy M. Kristof and Andrea Chang | Times Staff Writers
The federal government took control of Pasadena-based IndyMac Bank on

Friday in what regulators called the second-largest bank failure in U.S.
history.
***
The bank's 33 branches will be closed over the weekend, but the Federal
Deposit Insurance Corp. will reopen the bank on Monday as IndyMac
Federal Bank, said the Office of Thrift Supervision in Washington.
Assignment for Defunct Assignee
Prepared by and Return DED 99/99/201 14:97I92
½xtn.Wrdal.khneider Palm Beach County. Florida
6303nginowr Tod. Sune 3t3 Sharon R. Rock,CLERE & COEPTROLLER
¼ndyspringwGA 30LVI Pgs 1142 - 1143; (2pge)
EdtLNn Number. 7705'C06
Assienment of Mortenec
Assignor: Mortgage E]ectronic Registration Systenn Lnc., as nomince for LEHMAN

BROTHERS BANK. F58. A FEDERAL SAVINGS HANK, whw address is e/o C:nMortgage,
Inc.. ItX)0 Technology Dr.. O'Fallon, MO MM8
Assigno ortgage Electronic Registration Systems Inc., as nominee for LEHMAN

BROTHEllS BANK, FSB, A FEDERAL SAVINGS BANK, whose address is c/o CitiMortgage,
Inc., 1000 Técl3nology Dr., O'Fallon, MO 63368
Assignee: CitiMortgage, Inc., whose address is 1000 Technology Dr., O'Fallon, MO 63368
Witness thLs
Witness this
r LEHMAN B )TIlERS HANK. F511. A l¯EDERAL
a ùf.iGS B
Scott Scheiner. Asetan1 Secretary

Lehman Brothers
dh(ÄtWjjork Wrs
O
Search Business Finanq-ial Tools More in Bus.ness
f.30
1.chman I iles for Hankniptcy; Merrill is Sohl
in.frvie huwrLies. .. .. ·· .. .ri s.
Lehman Files for Bankruptcy; Merrill Is Sold

W ROSS 50RKlh
Notar Issues
ASSIGNML%T OF NH)HT('AGE
los r,4|ou op n m oi s a omsntM rio%.·tir . nc..r.3 oe m.+ n etry <tri.,ar.ip-.- trv

1-niptc_-. %IOptin..gGF FLFi-TRONti' RI-.4,1%TRAIH>N M%TIMs. INC. As NOMINFF FOR
f %) L OR BE AN AND MHt I WM %tOR1GAGE < 031POR.4TION. WHOM: ADDRE½ IN PO. Bom
212.4 Phies. MI ail91 ;U:4,i4%NH,NipHp. tn v.« þ e 1. a..-. ..r .r.. wit. w aware. irato-ei ar. ·,·i
IMDSí. SDDRL½ lh 111 MLitt. n.%1ILE DKl L FOR I ½%OX1H, 11 %L1L ITS SIECE_½OILN OR
AN%)G%%.ii½lG%tLi hWM a. I k hs JtMEMJ DOUkt 254
R...d =n .ohl n4.. . al
W.-- r- .r tr +4 ¬ri .sæs .. . . -:.wi,.r .#.t. .till... IP.J1' 17,n iit'.'.. - ii s
p.i tir 7. per·. . .-.-.] ri ..o.: hiw armi i nir, a, --crr . , A-u,tr.: - m.1¬or
%14tRTr,46F li ti-fkri%rr itpi,1%TH4tHIN%)N15%IN.1%t- WNOMINfE FUW l-4)l.ON MF%N

ANil ½ HIT4 ki-Jt MOR IG4GL c e BNPOR % TION
TION SYSTEMS, INC. AS NOMINEE FOR TAYLOR BEAN

.. ON, a corporation, and that she/he acknowledged executing the
vested in him/her by said corporation. WITNESS my hand and o
his 02nd day of June in the year 20I0
Christopher Jones
G Notary Public, State of Florida
Commission # 00 811078
Expires August 03, 2012
Bonded Through National Notary Assn.
liHlu i . u··%· s N i.n Fe.
/NTC, 2100 Alt. 19 North, Palm Harbor, FL 34683 (800)346-9

1.rrri 3Y.f l i
IHllHillHEEllllEllH ; m295coco7588191 MERS PHONE l-8R8-679-MERS

Impossible Notaries- Stamps are only good for
four years in Florida
Impossible Notaries
Assú,imvr#MonräuW
on 411strsarmestmSEM-
He..:a,-.,_uJ,1. . Ik6''.. \li S IlV, 1. l. . .I'-E '-'[ H|[.ll',N|7.It½l'216 -- '.'iN'.I W --. \fN
C-i ren ,1:ums.-J o n, .r. Iir- .c n ..r-, .) -sa.1: ul :Sc ul S I -. lït. .i ai. ·m .-.- : trd I ,rl-.
SI ATE OF
COUNTY O
PERSONAI l.Y APPEARED HEl ORE ME. the undersigned authority in and for the aforesaid county and state, on this
the day of . 20p}, within my lurisdiction, the within named C\A4A ____ w ho
acknowledged to me that s)he is ASSISTANT SECRETARY and that for and on behalf of MORTGAGE El.ECTRONIC
REGISTRATION SYSTEMS. INC. and as its act and deed (s)he executed the above and foregoing instrument, aber first having been
duly authorized by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC to do so.
WITNESS my hand and oftkiat seal in the County and State last aforesaid this dav of 2003
NOTARY PUB1 lC
MICHELLE LCAMACHO
MY COMuis310N 8 DD760715
Impossible Notaries
AS$WAntËNTOFN10RTGAGE · ·
KNOW AU. MF,W BY THE5E PRESENT5: ¯-
TH4 T MOHIGAGF ELECRONIC REGSTkA f!ON SY

Signed in the presence of MOR'I GAGE ELECTRONIC REGISTRAT YSTEMSd4NC.
La,24:aFE-JMI-CO%E1NG FL%.4NLli!.LLL-.O'
44.' -er:us dr.ipnsol £. dr unwar 'ut ..d i . .uso-w.o
enters.scr, uc rus-q 042=tset
ULL 19:11: 14A%
0421 i. b:ir+rp asAsern.lpd. Jim
llti si I-(IMM'O AMERKAí A.
042 ATI'EST: 3Y÷
[lN9N1:i: LJ.s-.·lNt MI-k]illAN<-k(L½ihi..NTF :ti,MIN PRINT NAME
nm..rgdµ esrum] hr ! RMlJL Ml.J i 4 MAN.Jt ||| %f4
CE4RI (_·'Ti- -_-:sirry. FPr>is H t=xk W*. .v pqr "C rn-arri WITNESS: . TITLE: ASSISTANT SECRETÁR
Ixir ?, BLOW lilf, PUNT4 GORDA BELE5. SECT]ON 23,
N.4 I ß(*)K 12.P4GFS2A Hilla GH 2Z4]. OF THE P13
d i=Ahhikähltp-lunein -th5 p*p-f=3N' -
Print Name: /½ l. . o
.-m,a., ec . STATEOF
.- s . . COUNTY OF
. PERSONA LY A EARED BEFORE ME, the undersigned authority in and for the resaid nty and state, on this
the (.A day of , 20 ithin my jurisdiction. the within named (A /'l vis [ who
ack edged to me th (s)he is ASSISTANT SECRETARY and that for and on behalf of M TGAGE ELECTRONIC
u s REGISTRATION SYSTEMS, INC. and as its act and deed (s)he executed the above rst having
. . x-g been duly authorized by MORTGAGE ELECTRONIC REGISTRATION S S, INC. to do so.
y and State last aforesaid a day of , 20___
ad '(
NOTARY PUBLIC
rawÁ
d
==
060 Y COMMissgo
ACHO acso
e, XPIRES
CSlHBOHV Of I alTLH11C LOU Í\apuSta
Testimony of Tammie Lou Kapusta,
former employee of Law Offices of David J. Stern, P.A.
Q Would these notaries be there watching her [Cheryl Samons] as

she signed?
A No.
Q She would just sit there and sign stacks of them?
A Correct. As far as notaries go in the firm I don't think any
notary actually used their own notary stamp. The team used
them.
Q There were just stamps around?
A Yes.
Q And you actually saw that?
A I was part of that.
ANSIC% MÞ N1 OF hlORIG4 254,F
rwns . r errest ruer m y vn
. . · % a6 i PJ .I s I al led F 6 t iF i e 1 ste I4 I . +
swd. 'N
MORTGAGEl-LECMb' r GISTR IUN S 570STI

M INC
I 1 ASSIST AN Rt IAR
t
Testimony of Tammie Lou Kapusta,
Q So this was an assignment signing table?

A Correct. Assignments or Affidavit A's that she was signing.
Q What's an Affidavit A?
A The indebtedness affidavit.
Q Okay.
A I think that's all Cheryl signed for. I think Beth signed for the rest. There's your Exhibit
E's. We had different exhibits. That's how they signed them. When Cheryl was out of the
office Tammie would sign them or Beth would go sign them.
Q Beth would sign but it would say Cheryl Samons?
A Correct.
Q And Beth would be the signer?
A Correct.
Q Or Tammie Sweat?
A Right.
Testimony of Kelly Scott,
Testimony of Kelly Scott,
Q. Other than Cheryl going around twice a day to sign the documents that she was reading, was there
anyone else that did that, as well?
A. Only Cheryl. And only when Cheryl was out of town, that she would go on vacation, there was
someone else that would sign on her behalf. Who was it? I really don't know.
Q. But they signed Cheryl's name?

A. Yes.
Q. And when you said those were the papers that were up on the long table on the four floors, what types
of documents were those?
A. Motions for Summary Judgment and Assignments of Mortgage.
***
Q. But whatever was on those long tables, nobody was reading? They were just putting their names on
them?
A. Yes, they were just putting their names.
Q. Yes, there was no one reading them?

A. Yes, there was no reading them.
Cheryl Samons "signature"
Purs I Sec. 689 tes.. ihe ^= a T has the prottet.

conserw and to sell. or to lease. or to encumber. or otherwise to unanage and dispose of the above-described mongage and the real
Property mumbcred therchy.
In IVdmesr WAmust the said Assignor has hercumo sei his hand and kiaTor shese to be ' by its corporate
omeers and its corporate seal to be hereto amned.
Signed in the presence of. MOR AGE EI.EL ISTRATION SYSTEMSjlNC.
ATIEST
PRI . ERYLSAMONS
WINESS TITLÉÍASS NT T
Prim N
C
C N Y OF Övrm;n em£l \
N A 042B - 042 the for inc ar - ty . on this

the I day ofSepiember. 7, with r jantamction, within CHERYL S who wiedged to me t (s)he
in ASSI SFOR RY and that for l'ofMORTG ,, JC REGISTRAT . . INC. and
as its act and deed (s)he executed the above and foregoing insirumenL aßer first hav ly authorized by MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS. INC. to do so.
wtmliss my hand and official seal in the County and State lasi aforesaid ihis .__ day of 20£7
NOTAR I.lc
Purs I Sec. 6:9 tes.. Ihc »Ma a T has the protect.

conserve and to sell. or to lease, or to encumber. or otherwisc to manage and dispose of the above-described mongage and the real
PIOperty anmbcred therchy.
" """ * In U7emens Whereof the said Assignar has hereunm see his hand and seal or caused these presents to be signed by its proper corporate
officers and its corporate seal to be hereto airised . thid day of _, 2009. bus effective as of the 17th day ofJuly,
si8ned in the paq 2008.
ATTEST
(COR RATE SEAL)
WINESS
PrimN
wi a PRINT NA . RYL SAMO
TI SSISTANT T RY
SA OF STATEOFFLORIDA
C N Y Of COUNTY OF BROWARD - -· - -
PERSONALLY APPEARED BFFORE ME. the undersagned suihority in and for the aforesaid county and stau, on this
theh day of _, 2009, within my jurisdiction, the within named CHERYL SA MONS who is personally known
os iis aci and de to me and who a nn to rne that (s)he is ASSISTANT SECRETARY and that for and on behalf of MORTGAGE
ELiiCTRONIC I ELECTRONIC REGISTRATION SYSTEMS, INC. and as its act and deed (søe executed the above and firugoing instrument, alkr
wimriss my h first having been duly euthorized by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. to do so
WITNESS my hand and official seat in the County and Saase last aforesaid this day of _. 2009.
// // V-......
Purs I Sec. 6a9 tes.. Ihc Wa ====d T has the protect.

conserve and to sell. or to lease, or to encumber. or otherwisc to snanage and dispose of the above-described mongage and the real
Propcsty mmmbcred thereby.
Pursuan pro f Sec. 6 Flori named T has the and authority prosces. as o lie 1 ay by
conserve and to sell, or ib icam or to encumber. or tse to manage of the abovealescribed mongage and the real
property encumbered thereby.
Is Mosess FAareof; the said hereunto set and seal or caused these be by its proper corporate SYSTEMS,
officers and its corporate to be hereto a , this day of , 20 eff as of the 3rd day of LL)
January , 2008.
Signed in the presence of: MORT E ELECTRONIC REGISTRA N SY S. INC.
ATTEST --P-
. RINTNAME:
E: ASSISTA SE
d county and state, on this

TrN S:
S who is personally known
rint ame A44Ab3DA . 042 L i behalf or MORTGAGE
firugoing instrument, aller
TA 'OF . to do so
WITNES$ my hand and official seat in the County and Saase last aforesaid this day of _. 2009.
// // V-....
conserve and to sell. or to h

propeny cncumixred Mursuant to the provisions of Sec. 689.071. Flonda Statuses, the whnin named Trustee has she power and authority to preteel,
onserve and to sell. or to lease, or to encumbes. or ciberwise to ampage and dispose of the above mortgage and the rest
in sement Ishv ,- 042=goperty eneumsbered thereby, -·
Pursuan pro o
conserve and to sell, or ib lensp h MM k add Assign has home set his hand aml mi ar these iments to be si cosem
propeny encumbered &creby fRcers and ils corporate seal to be herete affhed . this day of . 20sj_, but effective as 14 of
maary. 2009
Is Mosess FAareof; the said /
officen and its corporate seal - -MoltIQAGE ELECTilott|C REGISTRATION SYSTEMS C.
January . 2008. (CORPORATE SE AL)
Signed in the presence of: . _ _ . --

E ERYL SAMONS
ATTEST: TITLE: ASSIST SECRETARY
'TATE OF FLORIDA
UUNTY OF BROWARD
ame
V a county ano siane, on uno
S who is personally known
behalf or MORTGAGE
regoing instrument, aller
TA OF .todoso
WITNES$ my hand and official seat in the County and Sante last aforesaid this day of _. 2009.
// // V--...
conserve and to sell. or to h

propcsty accueil×red Mursuant to the p
pleservt and to se is m7tnm IF1wreef tlw said Aeógrmr has hereunto set his band and seat or cused thewpftfinis ú» htyyaqd by is propa corymrnte
in semesr WAns ,- -noperty ened omeen and its corporate seal to be hercio afthed. .
Pursuan pro of 060gned
in the pr oT MORTCAGE ELE ' RONIC RIN1S FRA i10 M ISC
conserve and to all, or ib les 8''
property encumbered thereby
maary. 2009 ATfEST. )
hr Mosess FAareof; the said / {© PRINT.NAME.CHERYl.SAMONS
officers and its corporate seal WrfNESS _.' TlTLE ASSISTANT SECRETARY (
January . 2008.
nt Sam /
}
Signed in the presence of:
WIT SS
ATTEST: Pri tN .
TE F .
'TATE OF FLOI NT 0!2 f-.A-TV O ,
UUNTY OF BIt
ame PE . ' bt APP ARE Mui..M .. the -rsi Aho . or the i twi ' on th
he yof ._ willunmy Ju wtion.Ih withinnarmd who
TrN S: acknmücdge at (sihe is ASSIS f ,': RI?TARY sat¾ t>ehal(MT MOR . .. ONIC
REGISTRATION SYSTt.MS. dKC ami as its act and dccd {ùhe exccused the above and l'oregoing insimmem. aAcr litu havmg been
rint 'ame . 4 Juh authorized bv Molt TGAGE ELECTRONIC REGIST RA TION SYS fh'M ' NC to do sa
TA ' OF IdA WI TNESS rny hand and ulTscial seal in the County and SI3EC F351 albresad thr. h_ day of _ 2
WITNE3$ my hand :
errft: "rrpier-._I My
Esa skar IIIIB-%2·¹3ttB
aw-w nrr.-eth-d Mrtia, t·--
leX 1
I a l l alderuman Ik.
Naudi 339
41.bere·1ta.GA 311635
4H e h22SIslb
< w9ameo
Ildte (pT900 042-Pe
sef1get«tiin ¢n+
rnstrreracr.us. Hun
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Misuse of Falsified Assignments
Improper assignments were recorded in the county land

records offices
Improper assignments were submitted to the Court in
support of foreclosure motions
Improper assignments were accepted by the Court as
valid assignments that substantiated the foreclosure
Homeowners were foreclosed upon based upon falsified
assignments, by a bank who was not the true holder of
the note.
If the foreclosure judgment is obtained by a bank that
does not hold the note, then the homeowner risks a
second lawsuit by the real note holder, and possibly a
having a second judgment against them on one property.
IN THE CIRCUlT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY. FLORIDA
CIVIT,ACTION
DEUTSCHE BANK TRUST COMPANY

AMERICAS AS TRUSTEE,
Plaintiff, CASE NO.: 50-2008-CA-0183S1
vs. DIVISION: AW
MICHAEL PETERS, et al,
Defendant(s).
MOTION TO RATIFY FINAL SUMMARY JUDGMENT

OF MORTGAGE FORECLOStrRE NUNC PRO TUNC
COMES NOW Plaintiff. DETTTSCHE BANK TRUS E CCMPANY AMERICAS AS TRUSTEE ("Plaintiff'), by and
through the undersigned comsel and files this Motionto Ratif Final Summary Judgment ofMortgage Foreclosure Nunc
Pro (the "Motion") and in suppen thereof states as follows:
~ BACKGROUND FACTS
1. On May 24 2010 this Court entered a Ffnal Summary Judgment ofMortgage Foreclos ure in favor of
Plaintiff. A judicial sale is schedulea for December 30, 2010.
2. The undersigned law firm has recently been advised that the information contai-ed in the Affidava os
lo Amounts Due and Owing submitted in support of Plaintiffs Motion for Stunmary Judgment taay not have be.en
p··operly verified by the afliant.
3. A Notice to this effect has been filed with the Court by the undersigned law iirm.
4. Plaintiff has also submitted a new, properly verified affidavit by affiant which shows that the amounts
reflecting the indebtedness contained in the original affidavit were accurate when nled. (The r.ew, properly veriñed
afñdavit is attached hereto and incorporated by reference as Exhibit "A").
5. Based on the foregoing Plairtiff has sought to norify the Court of the foregoing veri#ication issues and
now seeks the ratification of the Fina' Summary Judgment ofMortgage Foreciosure nunc pro tunc as an additional
r easonable remedial measure.
6, For the reasor. more fully set forth below, Plaintiff believes that entry of an Order granting this Motion
in its enti-ety is appropriate.

IN THE CIRCUlT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY. FLORIDA
CIVIT,ACTION
DEUTSCHE BANK TRUST COMPANY

AMERICAS AS TRUSTEE,
Plaintiff, CASE NO.: 50-2008-CA-0183S1
vs. DIVISION: AW
MICHAEL PETERS, et al,
Defendant(s).
MOTION TO RATIFY FINAL SUMMARY JUDGMENT

OF MORTGAGE FORECLOStrRE NUNC PRO TUNC
COMES NOW Plaintiff. DETTTSCHE BANK TRUS E CCMPANY AMERICAS AS TRUSTEE ("Plaintiff'), by and
through the undersigned comsel and files this Motionto Ratif Final Summary Judgment ofMortgage Foreclosure Nunc
Pro (the "Motion") an:1 in suppen thereof states as follows:
~ BACKGROLWD FACTS
2. The undersigned law fire has recently been advised that the infonnation contained in the Affidavit as
to Amounts Due and Owing submitted in support of Plaintiffs Motion for Summary Judgment may not have been
properly verified by the affiant
reflecting the indebtedness contained in the original affidavit were accurate when nled. (The r.ew, properly veriñed
afñdavit is attached hereto and incorporated by reference as Exhibit "A").
5. Based on the foregoing Plairtiff has sought to notify the Cow·t of the foregoing verincation issues and
now seeks the ratification of the Fina' Summary Judgment ofMortgage Foreciosure nunc pro tunc as an additional
r easonable remedial measure.
6, For the reasor. more fully set forth below, Plaintiff believes that entry of an Order granting this Motion
in its enti-ety is appropriate.

Notices to Court of Improper Affidavits
I.an Omces of Das id J. Stern, P.A.
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Notices to Court of Improper Affidavits
O
l.an Omces of Das id J. Stern, P.A.
Pursuant to Rule 4-3.3, Rules of Professional Conduct of the Rules Regulating the Florida
Bar, the undersigned law firm is filing the attached notice in the court file and providing a
courtesy copy to your Honor in accordance with its ethical obligation of candor toward the
tribunal.
I As outlined in the attached notice, the undersigned law firm has recently been informed
that the information contained in the Affidavit in support of Plaintiffs Motion for Summary
Judgment may not have been properly verified by the affiant.
Real Estate in Flcrrida (in pictures)
Real Estate in Flcrrida (in pictures)
Real Estate in Florida (in pictures)
Solutions for Foreclosures in Florida???
Any solution must include:

Assuring the integrity to the judicial foreclosure process
Documents submitted must be true and accurate
Affidavits must be proper in substance and form
Assignments must be properly executed and accurate
Due process rights to the foreclosed homeowners
Proper service of process on the homeowner
Proper standing to sue by the plaintiff Bank
Substantive review of paperwork prior to foreclosure
Foreclosures will have to go forward and there will be many
more next year, but they need to done within the law.
Filing # 21840608 Electronically Filed 12/19/2014 05:36:28 PM
Florida Attorney General - Active public consumer-related investig... http://myfloridalegal.com/pages.nsf/Main/0BABAE79CD95E3F4...
ATTORNEY GENERA
PAM BONDI
FLORlDA OFFICE or me ATT0ltNIW GENiillAL
Consumer Protection
Active public consumer-related investigations
The Attorney General's Office investigates and litigates civil cases involving certain Florida Statutes,
including civil theft and deceptive trade practices. We receive hundreds of telephone calls and letters daily
from businesses and individuals seeking public record information on commercial enterprises with which
they are conducting -- or might conduct -- business. The listing that follows is intended to offer these
businesses and individuals an alternative communications source for such information which, under
Florida's Government in the Sunshine laws, is public record and available to any citizen for inspection.
To continue, click ½
Some consumer complaints are administered by the state Division of Consumer Services under the direction
of Agriculture & Consumer Affairs Commissioner. Complaints may be registerd against those entities
regulated by the Division. For a list of those entities and a complaint form click here..
Florida Toll Free Numbers:

- Fraud Hotline 1-866-966-7226
- Lemon Law 1-800-321-5366
1 of 1 8/20/14 4:13 PM
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WS®¶asked OUManS
theme The Third Met rie 9 ay TORA FREE CLASS

August 19, 2014
BUSINESS
William Alden [email protected] LikeGET UPDATES FROM William
Secome a fan of this reporter 17° Florida AG Pam Bondi
Pressured By Targets Of Investigations To Soften Approach,

Critics Say
Posted: 10/12/11 06:34 PM ET
FORT LAUDERDALE, Fla. -- Last December, when she was still investigating foreclosure fraud
as a top lawyer in the Florida attorney general's office, June Ciarkson gave a PowerPoint
presentation to a legal association.
Her presentation amounted to an indictment of Lender Processing Services, or LPS, a
company near the center of ongoing state investigations into claims that foreclosures have
been rushed en masse through the legal machinery, without proper documentation. She
flashed images of paperwork on a screen under the heading "forgeries," asserting that LPS'
former subsidiary, Docx, had produced phony documents to justify unlawful foreclosures.
The legal association later sent Clarkson a thank-you note, calling her tutorial "invaluable."
Word of her presentation reached New York, where a state Supreme Court judge cited it in a
harshly worded ruling that a bank lacked the right to foreclose on a Brooklyn home.
But the Jacksonville-based LPS was furious, particularly about one slide in the presentation: an
image of the children's board garne Candyland, a satirical reference to the mortgage
securitization process. The following month, a lawyer for LPS sent a letter to Clarkson and Theresa Edwards -- a colleague who
co-authored the presentation -- calling their PowerPoint display "irresponsible" and "inflammatory," adding: "The legitimate question at
this point is whether you are stili capable of conducting this investigation."
Upper management in the attorney general's office, which also received a copy of the LPS complaint, ultimately answered that question
in the negative. The incoming director of the division of economic crimes admonished the two assistant state attomeys general, they
say. In May, Clarkson and Edwards resigned under threat of being fired, according to the attorney general's office.
Florida has some of the highest rates of foreclosure in the country, and is home to many of the companies accused of improper
document handling, yet the state's enforcement apparatus has treated many of these companies with striking lenience, according to
former state prosecutors and lawyers who represent Florida homeowners.
Many cite the forced departure of Clarkson and Edwards as a vivid example of how mortgage companies and law firms successfully
exploit connections to Florida's attorney general to soften legal probes, insulating themselves against the consequences of alleged
law-breaking.
"The division of economic crimes has long fostered an atmosphere in which, as Clarkson and Edwards found out, and as I have found
out in seven-and-half years of having one effort after another squelched, bold action is rare," declared Andrew Spark, a former assistant
attorney general in Florida, in a blistering memo he released publicly before resigning in August. "The people of the State of Florida
have the right to better, but under its current management, the situation can only get worse."
"Like the Securities and Exchange Commission ignoring Bernard Madoff's scams, our office -- like so many agencies -- was asleep at
the wheel while the future of the state's economy was being ravaged by mortgage fraud -- when it really mattered," Spark continued.
Florida Attorney General Pam Bondi, through spokeswoman Jennifer Meale, declined repeated requests for comment. But Meale
dismissed assertions that the agency has softened its enforcement against improper foreclosure practices. "We aggressively prosecute
wrongdoing regardless of the subject of the investigation," Meale said in an email.
Bondi has drawn criticism from local lawyers for accepting campaign contributions from companies the attorney general is investigating.
LPS and its former parent Fidelity National Financial -- which is under investigation by the attornev qeneral, as part of the LPS probe --
together contributed at least $2,000 to Bondi's campaign last year, according to the National Institute on Money in State Politics.
Executives of ProVest, a Tampa based company that notifies homeowners of a foreclosure, and which is being investigated by the state
attorney general, also made personal contributions to Bondi's campaign. Chief executive and founder Scott Strady, president James
Ward and executive vice president Victor Draper each contributed $500 to Bondi's campaign, according to the National Institute on
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Money in State Politics,

"No amount of campaign contributions" affects Bondi's commitment to fulfilling her duties, Meale said in an email.
As the news of Clarkson and Edward's forced depadures spread through Florida this summer via local blogs and newspaper reports,
the resulting public outcry challenged the notion that the state was really looking out for homeowners. Official explanations from the
attomey general that the pair had been ousted for poor job performance did not appear to win over many skeptics.
"It felt like finally someone was listening," said attorney Matthew Weidner, who represents homeowners in foreclosure. "That's why the
announcement of the firings was such a punch to the gut."
State Sen. Eleanor Sobel, a Hollywood, Fla., Democrat, along with another state lawmaker, wrote to U.S. Attomey General Eric Holder,
asking that the terminations of Clarkson and Edwards be "reviewed by an investigatory agency not directly associated with the State of
Florida in an effort to get the most neutral review."
As pressure mounted, Bondi herself calied for an investigation into the ouster, even as her office maintained the personnel decision was
"mundane." A Florida agency, the Department of Financial Services, opened an investigation in August, DFS Inspector General Ned
Luczynski, who is conducting the probe, declined to comment on it.
"Here we finally have two superstars, and they get the axe," Sobel said. "They got fired for doing a good job."
A FAMILIAR COMPLAINT
Among some of those who have recently worked in the state attorney general's office, such complaints seemed only to confirm the
ways of the institution as they knew lt -- one vulnerable to the influence of politically-connected outsiders.
"They don't want to be aggressive toward corporations," said a former assistant state attorney general who asked not to be named
because of concerns about his current job, "If they were as aggressive as they could be, or wanted to be, they would double the size of
the economic crimes division," he added, noting that the division is funded by recoveries from its cases.
The office seems to be guided by an attitude of "don't push too much," this former employee said.
Spark, the former assistant attorney general who penned the critical memo, worked in the Tampa bureau. He said the office suffered
from what he termed "litigation-phobia," describing several cases in which top-ranking officials pushed for what he viewed as premature
resolutions, before a full investigation could take place.
In one case, Spark opened an investigation into an auto dealership that was using deceptive advedising, he said. It turned out that a
lawyer who represented the auto dealership, Robert Shimberg, had served on Bondi's transition team. According to Spark, his superiors
noted that Shimberg was the dealership's counsel as they urged Spark not to pursue a full investigation.
In his memo, Spark cites an email he received from Richard Lawson, director of the division of economic crimes, which said that
Shimberg was a lawyer for the "very prominent" business. "You should be aware of this in case the [attorney general] has any
questions," Lawson said in that email, according to Spark's memo,
Meale, the attorney general's spokeswoman, declined to comment on Spark's memo, citing the existence of an internal investigation
into the former employee. Shimberg called Spark's portrayal "ridiculous."
Other developments at the attomey general's office have provoked charges that the agency is often intertwined with companies it ought
to be aggressively prosecuting. Two high-ranking employees recently left their posts for jobs at companies under investigation. Joe
Jacquot, former deputy attomey general, left govemment service for a job as senior vice president of govemment affairs at LPS, the
company announced in June.
Jacquot recused himself from discussions and actions involving LPS, as of late October of last year. He told a repoder from the News
Service of Florida that he had nothing to do with the investigations of foreclosure firms initiated under the previous attorney general, Bill
McCollum,
Mary Leontakianakos, formerly director of the division of economic crimes, this year went to work for the Fort Lauderdale-based
foreclosure law firm Marshall C. Watson, which the state attorney general was investigating. Edwards, who was working the Marshall
Watson case with Clarkson, said the $2 million settlement with the company in March was less than the $7 million she had wanted.
Leontakianakos, now chief counsel at Marshall Watson, said through a spokeswoman that she was not at all involved with the
settlement with the law firm.
"I am very proud of my service at the Florida Attorney General's office," she said through the spokeswoman.
A REPRIMAND FROM ON HIGH
Clarkson and Edwards say the first clear sign of trouble came in February, courtesy of a visit from Lawson, the director of the division of
economic crimes -- the first time they met him. He quickly signaled that he was fielding a lot of negative reports about them back in the
state capital, they recalled.
According to Clarkson and Edwards, Lawson told them: "I expected to come down here and find a couple of coyotes."
Reached on his cellphone, Lawson declined to be interviewed for this story.
Lawson said he didn't want to hear any more complaints about the two attomeys, according to Clarkson and Edwards.
"I said to him, 'How can we stop opposing counsel from contacting you?"' Clarkson said. "The way he was talking to us, I thought there
was nothing he would do but fire us."
Only one month earlier, Joan Meyer, a lawyer at Baker & McKenzie who was representing LPS, had written the letter of complaint,
asseding that Clarkson and Edwards had unfairly impugned the company in their PowerPoint presentation.
LPS provides software to banks to manage mortgages, and to law firms that process foreclosures for banks. The company has come to
dominate the foreclosure industry: More than half of all American modgages in foreclosure are processed with its software, according to
the company.
In addition to the allegations that its Docx unit fabricated foreclosure documents, LPS has confronted accusations from plaintiffs,
including a trustee for the U.S. Department of Justice, that the company engaged in illegal fee-splitting -- accepting kickbacks from law
firms that win foreclosure business. LPS chief executive Lee Kennedy said the fee-splitting charges were "without merit" and noted
during a conference call this summer that three of these cases had been either dismissed or resolved in the company's favor.
The PowerPoint presentation featured assignments of mortgage -- which are crucial in proving the right to foreciose on a home -
bearing the signature of Linda Green, a former Docx employee who signed as a "vice president" of a host of companies she did not
work for, including Bank of America, Wells Fargo and American Home Mortgage Servicing.
Several Docx employees signed the name Linda Green -- as officers of these companies - resulting in various "Linda Green"
signatures that differed markedly, the presentation suggested.
"Who is the real Linda Green?" the PowerPoint asked.
In her letter to Clarkson and Edwards, Meyer -- the LPS attorney - argued that the practice of signing as a "vice president" of a
company was approved by the various institutions involved.
And LPS has said it ended the policy that produced the apparently differing signatures. When LPS discovered that multiple employees
were signing as Linda Green, it fired the manager who was responsible and shut down Docx last year, the cornpany has said.
Meyer lamented that Clarkson and Edwards had "already acted as judge and jury with written publications of your conclusions," adding:
"We have already contacted your supervisors in the Florida Attomey General's Office in Tallahassee to request an investigation of your
conduct."
The attorney general's office initially defended the PowerPoint, which bears the seal of the office on its first page.
Mark Hamilton, who was interim director of the division of economic crimes in the weeks before Lawson took that job, told Meyer in a
letter that the PowerPoint was intended for educational purposes, and that the documents used were publicly available.
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"First and foremost the presentation was provided as a general overview of the types of documents our office has received from third
parties as a result of the foreclosure crisis," he wrote. "The investigation by our office into the issues surrounding the foreclosure crises
is ongo.ing in nature and the presentation should not be viewed as intended to comrnent on the liability of any particular company."
Two days before Hamilton wrote that letter, a senior official in the attomey general's office -- who ranked above Clarkson and Edwards
-- gave a similar presentation to the Florida Senate. Trish Conners, associate deputy attomey general, used some of the very same
documents that appeared in the earlier PowerPoint presentation.
But the attorney general's office concluded that the presentation by Clarkson and Edwards crossed a line. This particular use of those
LPS documents - even though they were obtained from third parties - was inappropriate, said Meale, the spokeswoman for the
attorney general.
A difference between the presentation by Clarkson and Edwards and the presentation by Conners was that Conners "did not draw any
conclusions" about an ongoing investigation, Meale said. Using words such as "fraud" and "forgery" is "completely inappropriate until an
investigation is complete and wrongdoing has been substantiated," Meale added in an email.
LPS spokeswoman Michelle Kersch said the company did not play a part in the dismissal of Clarkson and Edwards.
"The Florida Attomey General's decision to dismiss Ms. Clarkson and Ms. Edwards was not requested by LPS nor were we consulted in
the matter," Kersch said in an emailed statement. "From the very start of these inquiries, LPS has only been interested in ensuring a fair
and transparent process. This letter was sent in pursuit of that goal and did not request that any employee be terminated from the
Florida Attorney General's office."
'SITTING ON YOUR HANDS'
Clarkson and Edwards' aggressive tack on foreclosures garnered enemies beyond LPS. Shapiro & Fishman, a law firm based in Boca
Raton that the attorney general accused of using fabricated documents to speed through foreclosures, took issue with a subpoena the
attorneys served last year. The order was "outrageously broad" and "totally sloppy," said attorney Gerald Richman, president of the firm
Richman Greer, who represents Shapiro & Fishman.
Richman's complaints extended beyond the subpoena to the conduct of Clarkson and Edwards. "They acted very unprofessionally in
the way they treated us, and the way they treated the investigation," he said, calling them "arrogant." He went over their heads to
complain to their supervisor, he said.
Clarkson and Edwards dismissed that characterization. "If you don't bow down to him, you're arrogant," Clarkson said. Edwards
explained that her aggression toward opposing counsel comes with the job description: "That's when you.get your best deals, when you
push them really hard," she said.
But Richman ultimately claimed victory. He said his interactions with Clarkson and Edwards were a factor in the attorney general's
decision to force them out.
"I think the experience with us, along with other things, led to the firing," he said. "In my opinion, the firing was totally justified based on
how they treated people."
Meale, the spokeswoman for the attorney general, said that "no one group or subject of an investigation has any ability to make a
personnel decision in the attorney general's office."
A judge ultimately sided with Richman on his complaint about the subpoena, ruling in October to quash the attorney general's demand
for documents. Palm Beach County Judge Jack Cox called the subpoena "vague," "invasive" and "unduly burdensome" in his ruling.
Critics including Clarkson and Edwards noted that Cox was subsequently nominated as a candidate for a seat on the prestigious Fourth
District Court of Appeal by a commission that included Richman.
McCollum, the attorney general at the time, filed a motion for a rehearing, arguing that the court's "fundamental premise" in its decision
to quash the subpoena was "mistaken."
But Judge Cox stuck with his initial decision. In April, while Bondi was in office, the Fourth District Court of Appeal ruled that the
attorney general could not investigate Shapiro under the statute it was using.
Bondi's office never appealed that ruling. And the attorney general has not filed any new subpoenas against foreclosure law firms since
the ruling, Meale acknowledged.
"What our office is doing right now is considering all possible strategies for moving forward," she said.
Others have a different view, accusing the attorney general of stalling in the interest of letting the malefactors off the hook.
"Are you just sitting on your hands?" asked April Charney, an attorney at the nonprofit Jacksonville Area Legal Aid, who defends
homeowners and trains other lawyers. "Have you been so co-opted and infiltrated you're just helping them run the statue of limitations?
As far as I can tell, that's what's happening."
'SO MUCH MORE'
Clarkson and Edwards are in the process of starting a new law firm that will represent homeowners. Before moving to their new office in
Fort Lauderdale, they temporarily occupied a cramped space in a two-story building in nearby Hollywood, the walls adorned with Joan
Miro reproductions.
On a damp August morning, the phone rang. A man claiming to be a whistle-blower was on the line, detailing what he saw as a pattern
of fraud at his former employer. Clarkson and Edwards scribbled notes as they listened.
"I can't get any lawyers involved," the man said through the phone. "They're all scared because of what happened to you guys."
Clarkson and Edwards are keen to stay in the game, they say, even as they come to terms with the reality that they will be unable to
take on wrongdoing on a large scale, deprived of the attorney general's office as a platform for prosecution.
"People are still contacting us," Clarkson said. "They think we're still lawyers on the case, and we're not. But they know we know things
that probably won't ever get out now."
"There's so much more to expose, is the problem," she added, "There's so much more."
3 of 3 8/19/14 11:25 AM
UNITED STATES OF AMERICA
DEPARTMENT OF THE TREASURY
COMPTROLLER OF THE CURRENCY
)
In the Matter of: )
) AA-EC-11-12
Bank of America, N.A. )
Charlotte, NC )
)
)
CONSENT ORDER
The Comptroller of the Currency of the United States of America ("Comptroller"),
through his national bank examiners and other staff of the Office of the Comptroller of the
Currency ("OCC"), as part of an interagency horizontal review of major residential mortgage
servicers, has conducted an examination of the residential real estate mortgage foreclosure
processes of Bank of America, N.A., Charlotte, NC ("Bank"). The OCC has identified certain
deficiencies and unsafe or unsound practices in residential mortgage servicing and in the Bank’s
initiation and handling of foreclosure proceedings. The OCC has informed the Bank of the
findings resulting from the examination.
The Bank, by and through its duly elected and acting Board of Directors ("Board"), has
executed a Stipulation and Consent to the Issuance of a Consent Order, dated April 13, 2011
(“Stipulation and Consent”), that is accepted by the Comptroller. By this Stipulation and
Consent, which is incorporated by reference, the Bank has consented to the issuance of this
Consent Cease and Desist Order ("Order") by the Comptroller. The Bank has committed to
taking all necessary and appropriate steps to remedy the deficiencies and unsafe or unsound
practices identified by the OCC, and to enhance the Bank’s residential mortgage servicing and
foreclosure processes. The Bank has begun implementing procedures to remediate the practices
addressed in this Order.
ARTICLE I
COMPTROLLER’S FINDINGS
The Comptroller finds, and the Bank neither admits nor denies, the following:
(1) The Bank is among the largest servicers of residential mortgages in the United States,
and services a portfolio of 13,500,000 residential mortgage loans. During the recent housing
crisis, a substantially large number of residential mortgage loans serviced by the Bank became
delinquent and resulted in foreclosure actions. The Bank’s foreclosure inventory grew
substantially from January 2009 through September 2010.
(2) In connection with certain foreclosures of loans in its residential mortgage servicing
portfolio, the Bank:
(a) filed or caused to be filed in state and federal courts affidavits executed by its
employees or employees of third-party service providers making various assertions, such as
ownership of the mortgage note and mortgage, the amount of the principal and interest due, and
the fees and expenses chargeable to the borrower, in which the affiant represented that the
assertions in the affidavit were made based on personal knowledge or based on a review by the
affiant of the relevant books and records, when, in many cases, they were not based on such
personal knowledge or review of the relevant books and records;
(b) filed or caused to be filed in state and federal courts, or in local land records
offices, numerous affidavits or other mortgage-related documents that were not properly
notarized, including those not signed or affirmed in the presence of a notary;
2
(c) litigated foreclosure proceedings and initiated non-judicial foreclosure
proceedings without always ensuring that either the promissory note or the mortgage document
were properly endorsed or assigned and, if necessary, in the possession of the appropriate party
at the appropriate time;
(d) failed to devote sufficient financial, staffing and managerial resources to
ensure proper administration of its foreclosure processes;
(e) failed to devote to its foreclosure processes adequate oversight, internal
controls, policies, and procedures, compliance risk management, internal audit, third party
management, and training; and
(f) failed to sufficiently oversee outside counsel and other third-party providers
handling foreclosure-related services.
(3) By reason of the conduct set forth above, the Bank engaged in unsafe or unsound
banking practices.
Pursuant to the authority vested in him by the Federal Deposit Insurance Act, as
amended, 12 U.S.C. §1818(b), the Comptroller hereby ORDERS that:
ARTICLE II
COMPLIANCE COMMITTEE
(1) The Board shall maintain a Compliance Committee of at least three (3) directors, of
which at least two (2) may not be employees or officers of the Bank or any of its subsidiaries or
affiliates. In the event of a change of the membership, the name of any new member shall be
submitted to the Examiner-in-Charge for Large Bank Supervision at the Bank (“Examiner-in-
Charge”). The Compliance Committee shall be responsible for monitoring and coordinating the
3
Bank’s compliance with the provisions of this Order. The Compliance Committee shall meet at
least monthly and maintain minutes of its meetings.
(2) Within ninety (90) days of this Order, and within thirty (30) days after the end of
each quarter thereafter, the Compliance Committee shall submit a written progress report to the
Board setting forth in detail actions taken to comply with each Article of this order, and the
results and status of those actions.
(3) The Board shall forward a copy of the Compliance Committee’s report, with any
additional comments by the Board, to the Deputy Comptroller for Large Bank Supervision
(“Deputy Comptroller”) and the Examiner-in-Charge within ten (10) days of receiving such
report.
ARTICLE III
COMPREHENSIVE ACTION PLAN
(1) Within sixty (60) days of this Order, the Bank shall submit to the Deputy
Comptroller and the Examiner-in-Charge an acceptable plan containing a complete description
of the actions that are necessary and appropriate to achieve compliance with Articles IV through
XII of this Order (“Action Plan”). In the event the Deputy Comptroller asks the Bank to revise
the Action Plan, the Bank shall promptly make the requested revisions and resubmit the Action
Plan to the Deputy Comptroller and the Examiner-in-Charge. Following acceptance of the
Action Plan by the Deputy Comptroller, the Bank shall not take any action that would constitute
a significant deviation from, or material change to, the requirements of the Action Plan or this
Order, unless and until the Bank has received a prior written determination of no supervisory
objection from the Deputy Comptroller.
4
(2) The Board shall ensure that the Bank achieves and thereafter maintains compliance
with this Order, including, without limitation, successful implementation of the Action Plan.
The Board shall further ensure that, upon implementation of the Action Plan, the Bank achieves
and maintains effective mortgage servicing, foreclosure, and loss mitigation activities (as used
herein, the phrase “loss mitigation” shall include, but not be limited to, activities related to
special forbearances, modifications, short refinances, short sales, cash-for-keys, and deeds-in-
lieu of foreclosure and be referred to as either “Loss Mitigation” or “Loss Mitigation
Activities”), as well as associated risk management, compliance, quality control, audit, training,
staffing, and related functions. In order to comply with these requirements, the Board shall:
(a) require the timely reporting by Bank management of such actions directed by
the Board to be taken under this Order;
(b) follow-up on any non-compliance with such actions in a timely and
appropriate manner; and
(c) require corrective action be taken in a timely manner for any non-compliance
with such actions.
(3) The Action Plan shall address, at a minimum:
(a) financial resources to develop and implement an adequate infrastructure to
support existing and/or future Loss Mitigation and foreclosure activities and ensure compliance
with this Order;
(b) organizational structure, managerial resources, and staffing to support
existing and/or future Loss Mitigation and foreclosure activities and ensure compliance with this
Order;
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(c) metrics to measure and ensure the adequacy of staffing levels relative to
existing and/or future Loss Mitigation and foreclosure activities, such as limits for the number of
loans assigned to a Loss Mitigation employee, including the single point of contact as hereinafter
defined, and deadlines to review loan modification documentation, make loan modification
decisions, and provide responses to borrowers;
(d) governance and controls to ensure compliance with all applicable federal and
state laws (including the U.S. Bankruptcy Code and the Servicemembers Civil Relief Act
(“SCRA”)), rules, regulations, and court orders and requirements, as well as the Membership
Rules of MERSCORP, servicing guides of the Government Sponsored Enterprises (“GSEs”) or
investors, including those with the Federal Housing Administration and those required by the
Home Affordable Modification Program (“HAMP”), and loss share agreements with the Federal
Deposit Insurance Corporation (collectively “Legal Requirements”), and the requirements of this
Order.
(4) The Action Plan shall specify timelines for completion of each of the requirements of
Articles IV through XII of this Order. The timelines in the Action Plan shall be consistent with
any deadlines set forth in this Order.
ARTICLE IV
COMPLIANCE PROGRAM
Comptroller and the Examiner-in-Charge an acceptable compliance program to ensure that the
mortgage servicing and foreclosure operations, including Loss Mitigation and loan modification,
comply with all applicable Legal Requirements, OCC supervisory guidance, and the
6
requirements of this Order and are conducted in a safe and sound manner (“Compliance
Program”). The Compliance Program shall be implemented within one hundred twenty (120)
days of this Order. Any corrective action timeframe in the Compliance Program that is in excess
of one hundred twenty (120) days must be approved by the Examiner-in-Charge. The
Compliance Program shall include, at a minimum:
(a) appropriate written policies and procedures to conduct, oversee, and monitor
mortgage servicing, Loss Mitigation, and foreclosure operations;
(b) processes to ensure that all factual assertions made in pleadings, declarations,
affidavits, or other sworn statements filed by or on behalf of the Bank are accurate, complete,
and reliable; and that affidavits and declarations are based on personal knowledge or a review of
the Bank's books and records when the affidavit or declaration so states;
(c) processes to ensure that affidavits filed in foreclosure proceedings are
executed and notarized in accordance with state legal requirements and applicable guidelines,
including jurat requirements;
(d) processes to review and approve standardized affidavits and declarations for
each jurisdiction in which the Bank files foreclosure actions to ensure compliance with
applicable laws, rules and court procedures;
(e) processes to ensure that the Bank has properly documented ownership of the
promissory note and mortgage (or deed of trust) under applicable state law, or is otherwise a
proper party to the action (as a result of agency or other similar status) at all stages of foreclosure
and bankruptcy litigation, including appropriate transfer and delivery of endorsed notes and
assigned mortgages or deeds of trust at the formation of a residential mortgage-backed security,
7
and lawful and verifiable endorsement and successive assignment of the note and mortgage or
deed of trust to reflect all changes of ownership;
(f) processes to ensure that a clear and auditable trail exists for all factual
information contained in each affidavit or declaration, in support of each of the charges that are
listed, including whether the amount is chargeable to the borrower and/or claimable by the
investor;
(g) processes to ensure that foreclosure sales (including the calculation of the
default period, the amounts due, and compliance with notice requirements) and post-sale
confirmations are in accordance with the terms of the mortgage loan and applicable state and
federal law requirements;
(h) processes to ensure that all fees, expenses, and other charges imposed on the
borrower are assessed in accordance with the terms of the underlying mortgage note, mortgage,
or other customer authorization with respect to the imposition of fees, charges, and expenses, and
in compliance with all applicable Legal Requirements and OCC supervisory guidance;
(i) processes to ensure that the Bank has the ability to locate and secure all
documents, including the original promissory notes if required, necessary to perform mortgage
servicing, foreclosure and Loss Mitigation, or loan modification functions;
(j) ongoing testing for compliance with applicable Legal Requirements and OCC
supervisory guidance that is completed by qualified persons with requisite knowledge and ability
(which may include internal audit) who are independent of the Bank’s business lines;
(k) measures to ensure that policies, procedures, and processes are updated on an
ongoing basis as necessary to incorporate any changes in applicable Legal Requirements and
OCC supervisory guidance;
8
(l) processes to ensure the qualifications of current management and supervisory
personnel responsible for mortgage servicing and foreclosure processes and operations, including
collections, Loss Mitigation and loan modification, are appropriate and a determination of
whether any staffing changes or additions are needed;
(m) processes to ensure that staffing levels devoted to mortgage servicing and
foreclosure processes and operations, including collections, Loss Mitigation, and loan
modification, are adequate to meet current and expected workload demands;
(n) processes to ensure that workloads of mortgage servicing, foreclosure and
Loss Mitigation, and loan modification personnel, including single point of contact personnel as
hereinafter defined, are reviewed and managed. Such processes, at a minimum, shall assess
whether the workload levels are appropriate to ensure compliance with the requirements of
Article IX of this Order, and necessary adjustments to workloads shall promptly follow the
completion of the reviews. An initial review shall be completed within ninety (90) days of this
Order, and subsequent reviews shall be conducted semi-annually;
(o) processes to ensure that the risk management, quality control, audit, and
compliance programs have the requisite authority and status within the organization so that
appropriate reviews of the Bank’s mortgage servicing, Loss Mitigation, and foreclosure activities
and operations may occur and deficiencies are identified and promptly remedied;
(p) appropriate training programs for personnel involved in mortgage servicing
and foreclosure processes and operations, including collections, Loss Mitigation, and loan
modification, to ensure compliance with applicable Legal Requirements and supervisory
guidance; and
9
(q) appropriate procedures for customers in bankruptcy, including a prohibition
on collection of fees in violation of bankruptcy’s automatic stay (11 U.S.C. § 362), the discharge
injunction (11 U.S.C. § 524), or any applicable court order.
ARTICLE V
THIRD PARTY MANAGEMENT
Comptroller and the Examiner-in-Charge acceptable policies and procedures for outsourcing
foreclosure or related functions, including Loss Mitigation and loan modification, and property
management functions for residential real estate acquired through or in lieu of foreclosure, to any
agent, independent contractor, consulting firm, law firm (including local counsel in foreclosure
or bankruptcy proceedings retained to represent the interests of the owners of mortgages),
property management firm, or other third-party (including any affiliate of the Bank) (“Third-
Party Providers”). Third-party management policies and procedures shall be implemented within
one hundred twenty (120) days of this Order. Any corrective action timetable that is in excess of
one hundred twenty (120) days must be approved by the Examiner-in-Charge. The policies and
procedures shall include, at a minimum:
(a) appropriate oversight to ensure that Third-Party Providers comply with all
applicable Legal Requirements, OCC supervisory guidance (including applicable portions of
OCC Bulletin 2001-47), and the Bank’s policies and procedures;
(b) measures to ensure that all original records transferred from the Bank to
Third-Party Providers (including the originals of promissory notes and mortgage documents)
remain within the custody and control of the Third-Party Provider (unless filed with the
10
appropriate court or the loan is otherwise transferred to another party), and are returned to the
Bank or designated custodians at the conclusion of the performed service, along with all other
documents necessary for the Bank’s files, and that the Bank retains imaged copies of significant
documents sent to Third-Party Providers;
(c) measures to ensure the accuracy of all documents filed or otherwise utilized
on behalf of the Bank or the owners of mortgages in any judicial or non-judicial foreclosure
proceeding, related bankruptcy proceeding, or in other foreclosure-related litigation, including,
but not limited to, documentation sufficient to establish ownership of the promissory note and/or
right to foreclose at the time the foreclosure action is commenced;
(d) processes to perform appropriate due diligence on potential and current Third-
Party Provider qualifications, expertise, capacity, reputation, complaints, information security,
document custody practices, business continuity, and financial viability, and to ensure adequacy
of Third-Party Provider staffing levels, training, work quality, and workload balance;
(e) processes to ensure that contracts provide for adequate oversight, including
requiring Third-Party Provider adherence to Bank foreclosure processing standards, measures to
enforce Third-Party Provider contractual obligations, and processes to ensure timely action with
respect to Third-Party Provider performance failures;
(f) processes to ensure periodic reviews of Third-Party Provider work for
timeliness, competence, completeness, and compliance with all applicable Legal Requirements
and supervisory guidance, and to ensure that foreclosures are conducted in a safe and sound
manner;
(g) processes to review customer complaints about Third-Party Provider services;
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(h) processes to prepare contingency and business continuity plans that ensure the
continuing availability of critical third-party services and business continuity of the Bank,
consistent with federal banking agency guidance, both to address short-term and long-term
service disruptions and to ensure an orderly transition to new service providers should that
become necessary;
(i) a review of fee structures for Third-Party Providers to ensure that the method
of compensation considers the accuracy, completeness, and legal compliance of foreclosure
filings and is not based solely on increased foreclosure volume and/or meeting processing
timelines; and
(j) a certification process for law firms (and recertification of existing law firm
providers) that provide residential mortgage foreclosure and bankruptcy services for the Bank,
on a periodic basis, as qualified to serve as Third-Party Providers to the Bank including that
attorneys are licensed to practice in the relevant jurisdiction and have the experience and
competence necessary to perform the services requested.
ARTICLE VI
MORTGAGE ELECTRONIC REGISTRATION SYSTEM
Comptroller and the Examiner-in-Charge an acceptable plan to ensure appropriate controls and
oversight of the Bank’s activities with respect to the Mortgage Electronic Registration System
(“MERS”) and compliance with MERSCORP’s membership rules, terms, and conditions
(“MERS Requirements”) (“MERS Plan”). The MERS Plan shall be implemented within one
hundred twenty (120) days of this Order. Any corrective action timetable that is in excess of one
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hundred twenty (120) days must be approved by the Examiner-in-Charge. The MERS Plan shall
include, at a minimum:
(a) processes to ensure that all mortgage assignments and endorsements with
respect to mortgage loans serviced or owned by the Bank out of MERS’ name are executed only
by a certifying officer authorized by MERS and approved by the Bank;
(b) processes to ensure that all other actions that may be taken by MERS
certifying officers (with respect to mortgage loans serviced or owned by the Bank) are executed
by a certifying officer authorized by MERS and approved by the Bank;
(c) processes to ensure that the Bank maintains up-to-date corporate resolutions
from MERS for all Bank employees and third-parties who are certifying officers authorized by
MERS, and up-to-date lists of MERS certifying officers;
(d) processes to ensure compliance with all MERS Requirements and with the
requirements of the MERS Corporate Resolution Management System (“CRMS”);
(e) processes to ensure the accuracy and reliability of data reported to
MERSCORP, including monthly system-to-system reconciliations for all MERS mandatory
reporting fields, and daily capture of all rejects/warnings reports associated with registrations,
transfers, and status updates on open-item aging reports. Unresolved items must be maintained
on open-item aging reports and tracked until resolution. The Bank shall determine and report
whether the foreclosures for loans serviced by the Bank that are currently pending in MERS’
name are accurate and how many are listed in error, and describe how and by when the data on
the MERSCORP system will be corrected; and
(f) an appropriate MERS quality assurance workplan, which clearly describes all
tests, test frequency, sampling methods, responsible parties, and the expected process for open-
13
item follow-up, and includes an annual independent test of the control structure of the system-to-
system reconciliation process, the reject/warning error correction process, and adherence to the
Bank’s MERS Plan.
(2) The Bank shall include MERS and MERSCORP in its third-party vendor
management process, which shall include a detailed analysis of potential vulnerabilities,
including information security, business continuity, and vendor viability assessments.
ARTICLE VII
FORECLOSURE REVIEW
(1) Within forty-five (45) days of this Order, the Bank shall retain an independent
consultant acceptable to the Deputy Comptroller and the Examiner-in-Charge to conduct an
independent review of certain residential foreclosure actions regarding individual borrowers with
respect to the Bank’s mortgage servicing portfolio. The review shall include residential
foreclosure actions or proceedings (including foreclosures that were in process or completed) for
loans serviced by the Bank, whether brought in the name of the Bank, the investor, the mortgage
note holder, or any agent for the mortgage note holder (including MERS), that have been
pending at any time from January 1, 2009 to December 31, 2010, as well as residential
foreclosure sales that occurred during this time period (“Foreclosure Review”).
(2) Within fifteen (15) days of the engagement of the independent consultant described
in this Article, but prior to the commencement of the Foreclosure Review, the Bank shall submit
to the Deputy Comptroller and the Examiner-in-Charge for approval an engagement letter that
sets forth:
14
(a) the methodology for conducting the Foreclosure Review, including: (i) a
description of the information systems and documents to be reviewed, including the selection of
criteria for cases to be reviewed; (ii) the criteria for evaluating the reasonableness of fees and
penalties; (iii) other procedures necessary to make the required determinations (such as through
interviews of employees and third parties and a process for submission and review of borrower
claims and complaints); and (iv) any proposed sampling techniques. In setting the scope and
review methodology under clause (i) of this sub-paragraph, the independent consultant may
consider any work already done by the Bank or other third-parties on behalf of the Bank. The
engagement letter shall contain a full description of the statistical basis for the sampling methods
chosen, as well as procedures to increase the size of the sample depending on results of the initial
sampling;
(b) expertise and resources to be dedicated to the Foreclosure Review;
(c) completion of the Foreclosure Review within one hundred twenty (120) days
from approval of the engagement letter; and
(d) a written commitment that any workpapers associated with the Foreclosure
Review shall be made available to the OCC immediately upon request.
(3) The purpose of the Foreclosure Review shall be to determine, at a minimum:
(a) whether at the time the foreclosure action was initiated or the pleading or
affidavit filed (including in bankruptcy proceedings and in defending suits brought by
borrowers), the foreclosing party or agent of the party had properly documented ownership of the
promissory note and mortgage (or deed of trust) under relevant state law, or was otherwise a
proper party to the action as a result of agency or similar status;
15
(b) whether the foreclosure was in accordance with applicable state and federal
law, including but not limited to the SCRA and the U.S. Bankruptcy Code;
(c) whether a foreclosure sale occurred when an application for a loan
modification or other Loss Mitigation was under consideration; when the loan was performing in
accordance with a trial or permanent loan modification; or when the loan had not been in default
for a sufficient period of time to authorize foreclosure pursuant to the terms of the mortgage loan
documents and related agreements;
(d) whether, with respect to non-judicial foreclosures, the procedures followed
with respect to the foreclosure sale (including the calculation of the default period, the amounts
due, and compliance with notice periods) and post-sale confirmations were in accordance with
the terms of the mortgage loan and state law requirements;
(e) whether a delinquent borrower’s account was only charged fees and/or
penalties that were permissible under the terms of the borrower’s loan documents, applicable
state and federal law, and were reasonable and customary;
(f) whether the frequency that fees were assessed to any delinquent borrower’s
account (including broker price opinions) was excessive under the terms of the borrower’s loan
documents, and applicable state and federal law;
(g) whether Loss Mitigation Activities with respect to foreclosed loans were
handled in accordance with the requirements of the HAMP, and consistent with the policies and
procedures applicable to the Bank’s proprietary loan modifications or other loss mitigation
programs, such that each borrower had an adequate opportunity to apply for a Loss Mitigation
option or program, any such application was handled properly, a final decision was made on a
reasonable basis, and was communicated to the borrower before the foreclosure sale; and
16
(h) whether any errors, misrepresentations, or other deficiencies identified in the
Foreclosure Review resulted in financial injury to the borrower or the mortgagee.
(4) The independent consultant shall prepare a written report detailing the findings of the
Foreclosure Review (“Foreclosure Report”), which shall be completed within thirty (30) days of
completion of the Foreclosure Review. Immediately upon completion, the Foreclosure Report
shall be submitted to the Deputy Comptroller, Examiner-in-Charge, and the Board.
(5) Within forty-five (45) days of submission of the Foreclosure Report to the Deputy
Comptroller, Examiner-in-Charge, and the Board, the Bank shall submit to the Deputy
Comptroller and the Examiner-in-Charge a plan, acceptable to the OCC, to remediate all
financial injury to borrowers caused by any errors, misrepresentations, or other deficiencies
identified in the Foreclosure Report, by:
(a) reimbursing or otherwise appropriately remediating borrowers for
impermissible or excessive penalties, fees, or expenses, or for other financial injury identified in
accordance with this Article; and
(b) taking appropriate steps to remediate any foreclosure sale where the
foreclosure was not authorized as described in this Article.
(6) Within sixty (60) days after the OCC provides supervisory non-objection to the plan
set forth in paragraph (5) above, the Bank shall make all reimbursement and remediation
payments and provide all credits required by such plan, and provide the OCC with a report
detailing such payments and credits.
17
ARTICLE VIII
MANAGEMENT INFORMATION SYSTEMS
Comptroller and the Examiner-in-Charge an acceptable plan for operation of its management
information systems (“MIS”) for foreclosure and Loss Mitigation or loan modification activities
to ensure the timely delivery of complete and accurate information to permit effective decision-
making. The MIS plan shall be implemented within one hundred twenty (120) days of this
Order. Any corrective action timeframe that is in excess of one hundred twenty (120) days must
be approved by the Examiner-in-Charge. The plan shall include, at a minimum:
(a) a description of the various components of MIS used by the Bank for
foreclosure and Loss Mitigation or loan modification activities;
(b) a description of and timetable for any needed changes or upgrades to:
(i) monitor compliance with all applicable Legal Requirements and
supervisory guidance, and the requirements of this Order;
(ii) ensure the ongoing accuracy of records for all serviced mortgages,
including, but not limited to, records necessary to establish ownership and the right to foreclose
by the appropriate party for all serviced mortgages, outstanding balances, and fees assessed to
the borrower; and
(iii) measures to ensure that Loss Mitigation, loan foreclosure, and
modification staffs have sufficient and timely access to information provided by the borrower
regarding loan foreclosure and modification activities;
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(c) testing the integrity and accuracy of the new or enhanced MIS to ensure that
reports generated by the system provide necessary information for adequate monitoring and
quality controls.
ARTICLE IX
MORTGAGE SERVICING
Comptroller and the Examiner-in-Charge an acceptable plan, along with a timeline for ensuring
effective coordination of communications with borrowers, both oral and written, related to Loss
Mitigation or loan modification and foreclosure activities: (i) to ensure that communications are
timely and effective and are designed to avoid confusion to borrowers; (ii) to ensure continuity in
the handling of borrowers’ loan files during the Loss Mitigation, loan modification, and
foreclosure process by personnel knowledgeable about a specific borrower’s situation; (iii) to
ensure reasonable and good faith efforts, consistent with applicable Legal Requirements, are
engaged in Loss Mitigation and foreclosure prevention for delinquent loans, where appropriate;
and (iv) to ensure that decisions concerning Loss Mitigation or loan modifications continue to be
made and communicated in a timely fashion. Prior to submitting the plan, the Bank shall
conduct a review to determine whether processes involving past due mortgage loans or
foreclosures overlap in such a way that they may impair or impede a borrower’s efforts to
effectively pursue a loan modification, and whether Bank employee compensation practices
discourage Loss Mitigation or loan modifications. The plan shall be implemented within one
hundred twenty (120) days of this Order. Any corrective action timeframe that is in excess of
19
one hundred twenty (120) days must be approved by the Examiner-in-Charge. The plan shall
include, at a minimum:
(a) measures to ensure that staff handling Loss Mitigation and loan modification
requests routinely communicate and coordinate with staff processing the foreclosure on the
borrower’s property;
(b) appropriate deadlines for responses to borrower communications and requests
for consideration of Loss Mitigation, including deadlines for decision-making on Loss Mitigation
Activities, with the metrics established not being less responsive than the timelines in the HAMP
program;
(c) establishment of an easily accessible and reliable single point of contact for
each borrower so that the borrower has access to an employee of the Bank to obtain information
throughout the Loss Mitigation, loan modification, and foreclosure processes;
(d) a requirement that written communications with the borrower identify such
single point of contact along with one or more direct means of communication with the contact;
(e) measures to ensure that the single point of contact has access to current
information and personnel (in-house or third-party) sufficient to timely, accurately, and
adequately inform the borrower of the current status of the Loss Mitigation, loan modification,
and foreclosure activities;
(f) measures to ensure that staff are trained specifically in handling mortgage
delinquencies, Loss Mitigation, and loan modifications;
(g) procedures and controls to ensure that a final decision regarding a borrower’s
loan modification request (whether on a trial or permanent basis) is made and communicated to
the borrower in writing, including the reason(s) why the borrower did not qualify for the trial or
20
permanent modification (including the net present value calculations utilized by the Bank, if
applicable) by the single point of contact within a reasonable period of time before any
foreclosure sale occurs;
(h) procedures and controls to ensure that when the borrower’s loan has been
approved for modification on a trial or permanent basis that: (i) no foreclosure or further legal
action predicate to foreclosure occurs, unless the borrower is deemed in default on the terms of
the trial or permanent modification; and (ii) the single point of contact remains available to the
borrower and continues to be referenced on all written communications with the borrower;
(i) policies and procedures to enable borrowers to make complaints regarding the
Loss Mitigation or modification process, denial of modification requests, the foreclosure process,
or foreclosure activities which prevent a borrower from pursuing Loss Mitigation or modification
options, and a process for making borrowers aware of the complaint procedures;
(j) procedures for the prompt review, escalation, and resolution of borrower
complaints, including a process to communicate the results of the review to the borrower on a
timely basis;
(k) policies and procedures to ensure that payments are credited in a prompt and
timely manner; that payments, including partial payments to the extent permissible under the
terms of applicable legal instruments, are applied to scheduled principal, interest, and/or escrow
before fees, and that any misapplication of borrower funds is corrected in a prompt and timely
manner;
(l) policies and procedures to ensure that timely information about Loss
Mitigation options is sent to the borrower in the event of a delinquency or default, including
plain language notices about loan modification and the pendency of foreclosure proceedings;
21
(m) policies and procedures to ensure that foreclosure, Loss Mitigation, and loan
modification documents provided to borrowers and third parties are appropriately maintained
and tracked, and that borrowers generally will not be required to resubmit the same documented
information that has already been provided, and that borrowers are notified promptly of the need
for additional information; and
(n) policies and procedures to consider loan modifications or other Loss
Mitigation Activities with respect to junior lien loans owned by the Bank, and to factor the risks
associated with such junior lien loans into loan loss reserving practices, where the Bank services
the associated first lien mortgage and becomes aware that such first lien mortgage is delinquent
or has been modified. Such policies and procedures shall require the ongoing maintenance of
appropriate loss reserves for junior lien mortgages owned by the Bank and the charge-off of such
junior lien loans in accordance with FFIEC retail credit classification guidelines.
ARTICLE X
RISK ASSESSMENT AND RISK MANAGEMENT PLAN
(1) Within ninety (90) days of this Order, the Bank shall conduct a written,
comprehensive assessment of the Bank’s risks in mortgage servicing operations, particularly in
the areas of Loss Mitigation, foreclosure, and the administration and disposition of other real
estate owned, including, but not limited to, operational, compliance, transaction, legal, and
reputational risks.
(2) The Bank shall develop an acceptable plan to effectively manage or mitigate
identified risks on an ongoing basis, with oversight by the Bank’s senior risk managers, senior
22
management, and the Board. The assessment and plan shall be provided to the Deputy
Comptroller and the Examiner-in-Charge within one hundred twenty (120) days of this Order.
ARTICLE XI
APPROVAL, IMPLEMENTATION AND REPORTS
(1) The Bank shall submit the written plans, programs, policies, and procedures required
by this Order for review and determination of no supervisory objection to the Deputy
Comptroller and the Examiner-in-Charge within the applicable time periods set forth in Articles
II through X. The Bank shall adopt the plans, programs, policies, and procedures required by
this Order upon submission to the OCC, and shall immediately make any revisions requested by
the Deputy Comptroller or the Examiner-in-Charge. Upon adoption, the Bank shall immediately
implement the plans, programs, policies, and procedures required by this Order and thereafter
fully comply with them.
(2) During the term of this Order, the required plans, programs, policies, and procedures
shall not be amended or rescinded in any material respect without the prior written approval of
the Deputy Comptroller or the Examiner-in-Charge (except as otherwise provided in this Order).
(3) During the term of this Order, the Bank shall revise the required plans, programs,
policies, and procedures as necessary to incorporate new or changes to applicable Legal
Requirements and supervisory guidelines.
(4) The Board shall ensure that the Bank has processes, personnel, and control systems
to ensure implementation of and adherence to the plans, programs, policies, and procedures
required by this Order.
23
(5) Within thirty (30) days after the end of each calendar quarter following the date of
this Order, the Bank shall submit to the OCC a written progress report detailing the form and
manner of all actions taken to secure compliance with the provisions of this Order and the results
thereof. The progress report shall include information sufficient to validate compliance with this
Order, based on a testing program acceptable to the OCC that includes, if required by the OCC,
validation by third-party independent consultants acceptable to the OCC. The OCC may, in
writing, discontinue the requirement for progress reports or modify the reporting schedule.
(6) All communication regarding this Order shall be sent to:
(a) Deputy Comptroller for Large Bank Supervision

Office of the Comptroller of the Currency
250 E Street, SW
Washington, DC 20219
(b) Examiner-in-Charge, Large Bank Supervision

Office of the Comptroller of the Currency
101 South Tryon Street
Charlotte, NC 28255
ARTICLE XII
COMPLIANCE AND EXTENSIONS OF TIME
(1) If the Bank contends that compliance with any provision of this Order would not be
feasible or legally permissible for the Bank, or requires an extension of any timeframe within this
Order, the Board shall submit a written request to the Deputy Comptroller asking for relief. Any
written requests submitted pursuant to this Article shall include a statement setting forth in detail
the special circumstances that prevent the Bank from complying with a provision, that require
the Deputy Comptroller to exempt the Bank from a provision, or that require an extension of a
timeframe within this Order.
24
(2) All such requests shall be accompanied by relevant supporting documentation, and to
the extent requested by the Deputy Comptroller, a sworn affidavit or affidavits setting forth any
other facts upon which the Bank relies. The Deputy Comptroller's decision concerning a request
is final and not subject to further review.
ARTICLE XIII
OTHER PROVISIONS
(1) Although this Order requires the Bank to submit certain actions, plans, programs,
policies, and procedures for the review or prior written determination of no supervisory objection
by the Deputy Comptroller or the Examiner-in-Charge, the Board has the ultimate responsibility
for proper and sound management of the Bank.
(2) In each instance in this Order in which the Board is required to ensure adherence to,
and undertake to perform certain obligations of the Bank, it is intended to mean that the Board
shall:
(a) authorize and adopt such actions on behalf of the Bank as may be necessary
for the Bank to perform its obligations and undertakings under the terms of this Order;
(b) require the timely reporting by Bank management of such actions directed by
the Board to be taken under the terms of this Order;
(c) follow-up on any material non-compliance with such actions in a timely and
appropriate manner; and
(d) require corrective action be taken in a timely manner of any material non-
compliance with such actions.
25
(3) If, at any time, the Comptroller deems it appropriate in fulfilling the responsibilities
placed upon him by the several laws of the United States to undertake any action affecting the
Bank, nothing in this Order shall in any way inhibit, estop, bar, or otherwise prevent the
Comptroller from so doing.
(4) This Order constitutes a settlement of the cease and desist proceeding against the
Bank contemplated by the Comptroller, based on the unsafe or unsound practices described in
the Comptroller’s Findings set forth in Article I of this Order. Provided, however, that nothing
in this Order shall prevent the Comptroller from instituting other enforcement actions against the
Bank or any of its institution-affiliated parties, including, without limitation, assessment of civil
money penalties, based on the findings set forth in this Order, or any other findings.
(5) This Order is and shall become effective upon its execution by the Comptroller,
through his authorized representative whose hand appears below. The Order shall remain
effective and enforceable, except to the extent that, and until such time as, any provision of this
Order shall be amended, suspended, waived, or terminated in writing by the Comptroller.
(6) Any time limitations imposed by this Order shall begin to run from the effective date
of this Order, as shown below, unless the Order specifies otherwise.
(7) The terms and provisions of this Order apply to the Bank and its subsidiaries, even
though those subsidiaries are not named as parties to this Order. The Bank shall integrate any
foreclosure or mortgage servicing activities done by a subsidiary into its plans, policies,
programs, and processes required by this Order. The Bank shall ensure that its subsidiaries
comply with all terms and provisions of this Order.
(8) This Order is intended to be, and shall be construed to be, a final order issued
pursuant to 12 U.S.C. § 1818(b), and expressly does not form, and may not be construed to form,
26
a contract binding the Comptroller or the United States. Nothing in this Order shall affect any
action against the Bank or its institution-affiliated parties by a bank regulatory agency, the
United States Department of Justice, or any other law enforcement agency, to the extent
permitted under applicable law.
(9) The terms of this Order, including this paragraph, are not subject to amendment or
modification by any extraneous expression, prior agreements, or prior arrangements between the
parties, whether oral or written.
(10) Nothing in the Stipulation and Consent or this Order, express or implied, shall give
to any person or entity, other than the parties hereto, and their successors hereunder, any benefit
or any legal or equitable right, remedy or claim under the Stipulation and Consent or this Order.
(11) The Bank consents to the issuance of this Order before the filing of any notices, or
taking of any testimony or adjudication, and solely for the purpose of settling this matter without
a formal proceeding being filed.
IT IS SO ORDERED, this 13th day of April, 2011.
__/s/__________________
Sally G. Belshaw
Deputy Comptroller
Large Bank Supervision
27
UNITED STATES OF AMERICA
DEPARTMENT OF THE TREASURY
COMPTROLLER OF THE CURRENCY
)
In the Matter of: )
Bank of America, N.A. ) AA-EC-11-12
Charlotte, NC )
)
STIPULATION AND CONSENT TO THE ISSUANCE

OF A CONSENT ORDER
The Comptroller of the Currency of the United States of America (“Comptroller”)
intends to impose a cease and desist order on Bank of America, N.A., Charlotte, NC
(“Bank”) pursuant to 12 U.S.C. § § 1818(b), for unsafe or unsound banking practices
relating to mortgage servicing and the initiation and handling of foreclosure proceedings.
The Bank, in the interest of compliance and cooperation, enters into this
Stipulation and Consent to the Issuance of a Consent Order (“Stipulation”) and consents
to the issuance of a Consent Order, dated April 13, 2011 (“Consent Order”);
In consideration of the above premises, the Comptroller, through his authorized
representative, and the Bank, through its duly elected and acting Board of Directors,
stipulate and agree to the following:
ARTICLE I
JURISDICTION
(1) The Bank is a national banking association chartered and examined by the
Comptroller pursuant to the National Bank Act of 1864, as amended, 12 U.S.C. § 1 et
seq.
(2) The Comptroller is “the appropriate Federal banking agency” regarding
the Bank pursuant to 12 U.S.C. §§ 1813(q) and 1818(b).
(3) The Bank is an “insured depository institution” within the meaning of
12 U.S.C. § 1818(b)(1).
(4) For the purposes of, and within the meaning of 12 C.F.R. §§ 5.3(g)(4),
5.51(c)(6), and 24.2(e)(4), this Consent Order shall not be construed to be a “cease and
desist order” or “consent order”, unless the OCC informs the Bank otherwise.
ARTICLE II
AGREEMENT
(1) The Bank, without admitting or denying any wrongdoing, consents and
agrees to issuance of the Consent Order by the Comptroller.
(2) The Bank consents and agrees that the Consent Order shall (a) be deemed
an “order issued with the consent of the depository institution” pursuant to 12 U.S.C.
§ 1818(h)(2), (b) become effective upon its execution by the Comptroller through his
authorized representative, and (c) be fully enforceable by the Comptroller pursuant to
12 U.S.C. § 1818(i).
(3) Notwithstanding the absence of mutuality of obligation, or of
consideration, or of a contract, the Comptroller may enforce any of the commitments or
obligations herein undertaken by the Bank under his supervisory powers, including 12
U.S.C. § 1818(i), and not as a matter of contract law. The Bank expressly acknowledges
that neither the Bank nor the Comptroller has any intention to enter into a contract.
2
(4) The Bank declares that no separate promise or inducement of any kind has
been made by the Comptroller, or by his agents or employees, to cause or induce the
Bank to consent to the issuance of the Consent Order and/or execute the Consent Order.
(5) The Bank expressly acknowledges that no officer or employee of the
Comptroller has statutory or other authority to bind the United States, the United States
Treasury Department, the Comptroller, or any other federal bank regulatory agency or
entity, or any officer or employee of any of those entities to a contract affecting the
Comptroller’s exercise of his supervisory responsibilities.
(6) The OCC releases and discharges the Bank from all potential liability for a
cease and desist order that has been or might have been asserted by the OCC based on the
banking practices described in the Comptroller’s Findings set forth in Article I of the
Consent Order, to the extent known to the OCC as of the effective date of the Consent
Order. However, the banking practices alleged in Article I of the Consent Order may be
utilized by the OCC in other future enforcement actions against the Bank or its
institution-affiliated parties, including, without limitation, to assess civil money penalties
or to establish a pattern or practice of violations or the continuation of a pattern or
practice of violations. This release shall not preclude or affect any right of the OCC to
determine and ensure compliance with the terms and provisions of this Stipulation or the
Consent Order.
(7) The terms and provisions of the Stipulation and the Consent Order shall be
binding upon, and inure to the benefit of, the parties hereto and their successors in
interest. Nothing in this Stipulation or the Consent Order, express or implied, shall give
to any person or entity, other than the parties hereto, and their successors hereunder, any
3
benefit or any legal or equitable right, remedy or claim under this Stipulation or the
Consent Order.
ARTICLE III
WAIVERS
(1) The Bank, by consenting to this Stipulation, waives:
(a) the issuance of a Notice of Charges pursuant to 12 U.S.C.
§ 1818(b);
(b) any and all procedural rights available in connection with the
issuance of the Consent Order;
(c) all rights to a hearing and a final agency decision pursuant to 12
U.S.C. §§ 1818(b) and (h), 12 C.F.R. Part 19;
(d) all rights to seek any type of administrative or judicial review of
the Consent Order;
(e) any and all claims for fees, costs or expenses against the
Comptroller, or any of his agents or employees, related in any way to this enforcement
matter or this Consent Order, whether arising under common law or under the terms of
any statute, including, but not limited to, the Equal Access to Justice Act, 5 U.S.C. § 504
and 28 U.S.C. § 2412; and
(f) any and all rights to challenge or contest the validity of the
Consent Order.
4
ARTICLE IV
OTHER PROVISIONS
(1) The provisions of this Stipulation shall not inhibit, estop, bar, or otherwise
prevent the Comptroller from taking any other action affecting the Bank if, at any time, it
deems it appropriate to do so to fulfill the responsibilities placed upon it
by the several laws of the United States of America.
(2) Nothing in this Stipulation shall preclude any proceedings brought by the
Comptroller to enforce the terms of this Consent Order, and nothing in this Stipulation
constitutes, nor shall the Bank contend that it constitutes, a waiver of any right, power, or
authority of any other representative of the United States or an agency thereof, including,
without limitation, the United States Department of Justice, to bring other actions deemed
appropriate.
(3) The terms of the Stipulation and the Consent Order are not subject to
amendment or modification by any extraneous expression, prior agreements or prior
arrangements between the parties, whether oral or written.
IN TESTIMONY WHEREOF, the undersigned, authorized by the Comptroller as
his representative, has hereunto set her hand on behalf of the Comptroller.
/s/ April 13, 2011
Sally G. Belshaw Date

Deputy Comptroller
Large Bank Supervision
5
IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting
Board of Directors of the Bank, have hereunto set their hands on behalf of the Bank.
__/s/________________ ____3/29/11_________
Susan S. Bies Date
__/s/________________ ____3/29/11_________
Frank P. Bramble, Sr. Date
__/s/________________ ____3/29/11_________
Virgis W. Colbert Date
__/s/________________ ____3/29/11_________
Charles K. Gifford Date
__/s/________________ ____3/29/11_________
Charles O. Holliday, Jr. Date
__/s/________________ ____3/29/11_________
D. Paul Jones, Jr. Date
__/s/________________ ____3/29/11_________
Monica C. Lozano Date
__/s/________________ ____3/29/11_________
Thomas J. May Date
6
__/s/________________ ____3/29/11_________
Brian T. Moynihan Date
__/s/________________ ____3/29/11_________
Donald E. Powell Date
__/s/________________ ____3/29/11_________
Charles O. Rossotti Date
__/s/________________ ____3/29/11_________
Robert W. Scully Date
7
OFFICE OF AUDIT
REGION VI
FORT WORTH, TX MEMORANDUM OF REVIEW
OFFICE OF
INSPECTOR GENERAL
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Bank of America Corporation

Foreclosure and Claims Process Review
Charlotte, NC
MEMORANDUM NO. 2012-FW-1802 MARCH 12, 2012

U.S. Department of Housing and Urban Development
Office of Inspector General, Region VI
819 Taylor Street, Suite 13A09
Fort Worth, TX 76102
(817) 978-9309 FAX (817) 978-9316

http://www.hudoig.gov
OIG Fraud Hotline 1-800-347-3735
MEMORANDUM NO.
March 12, 2012 2012-FW-1802
MEMORANDUM
FOR: Charles S. Coulter, Deputy Assistant Secretary for Single Family Housing, HU
Craig Clemmensen, Director, Departmental Enforcement Center, CACB
//signed//
FROM: Gerald R. Kirkland, Regional Inspector General for Audit, 6AGA
SUBJECT: Bank of America Corporation

Foreclosure and Claims Process Review
Charlotte, NC
INTRODUCTION AND BACKGROUND
As part of the Office of Inspector General’s (OIG) nationwide effort to review the foreclosure
practices of the five largest Federal Housing Administration (FHA) mortgage servicers (Bank of
America, Wells Fargo Bank, CitiMortgage, JP Morgan Chase, and Ally Financial, Incorporated),
we reviewed Bank of America’s foreclosure and claims processes. In addition to this
memorandum, OIG issued separate memorandums for each of the other four reviews. 1 OIG also
plans to issue a summary memorandum reporting the results of all five memorandums. OIG
performed these reviews due to reported allegations made in the fall of 2010 that national
mortgage servicers were engaged in widespread questionable foreclosure practices involving the
use of foreclosure “mills” and a practice known as “robosigning” 2 of sworn documents in
thousands of foreclosures throughout the United States. 3
Bank of America is a supervised FHA direct endorsement lender that can originate, sponsor, and
service FHA-insured loans. During Federal fiscal years 2009 and 2010, it submitted 36,095
FHA claims totaling $5 billion.4 Bank of America acquired Countrywide Home Loans
Servicing, LP, in 2008 and processed claims using Countrywide’s FHA servicing identification
1
See memorandums 2012-AT-1801, 2012-KC-1801, 2012-CH-1801, and 2012-PH-1801.
2
We have defined the term “robosigning” as the practice of an employee or agent of the servicer signing
documents automatically without a due diligence review or verification of the facts.
3
With respect to foreclosure procedures, there are three variations: those States that require a complete judicial
proceeding, which are referred to as “the judicial jurisdictions;” those that do not require a judicial proceeding;
and those that are a hybrid. For purposes of these reviews, we determined that there were 23 judicial States and
jurisdictions.
4
Properties located in judicial foreclosure States and jurisdictions accounted for $1.3 billion in claims (26 percent
of the claims). Properties located in nonjudicial foreclosure States and jurisdictions accounted for $3.7 billion
in claims (74 percent of the claims). These amounts include all categories of FHA claims.
number during the review period. 5 Approximately 90 percent of its claims during the review
period, totaling more than $4.5 billion, were for loans previously serviced by Countrywide.
In early October 2010, Bank of America stated that it would halt judicial foreclosures while it
reviewed its policies and procedures. On October 18, 2010, it issued a press release reporting
that it had completed its review of judicial foreclosures and while it had identified no problems,
it would resubmit 102,000 affidavits in judicial foreclosure cases that had not yet gone to
judgment. On October 22, 2010, the U. S. Department of Housing and Urban Development
(HUD) issued a notice of violation informing Bank of America that it was considering
administrative actions and civil money penalties based on findings identified in its July 2010
servicing review.
From the beginning of our review in October 2010, Bank of America limited our access to
employees and information. After attempting to conduct interviews within Bank of America’s
established protocols without success, the U. S. Department of Justice (DOJ) assisted us by
obtaining testimony through civil investigative demands (CID). 6 Because we identified potential
False Claims Act 7 violations, in February 2011, we provided DOJ with our analyses and
preliminary conclusions as to whether Bank of America engaged in the alleged foreclosure
practices.
DOJ used our review and analysis in negotiating a settlement agreement with Bank of America.
On February 9, 2012, DOJ and 49 State attorneys general announced a proposed settlement of
$25 billion with Bank of America and four other mortgage servicers for their reported violations
of foreclosure requirements. As part of the proposed settlement agreement, each of the five
servicers will pay a portion of the settlement to the United States and must undertake certain
consumer relief activities. The proposed settlement agreement described tentative credits that
each mortgage servicer would receive for modifying loans, including principal reduction and
refinancing, and established a monitoring committee 8 and a monitor to ensure compliance with
agreed-upon servicing standards and the consumer relief provisions. Once the final settlement
agreement has been approved by the court, OIG will issue a separate summary memorandum
detailing each of the five servicers’ allocated share of payment due as a result of the settlement
agreement.
Our objective was to determine whether Bank of America complied with applicable foreclosure
procedures when processing foreclosures on FHA-insured loans.
METHODOLOGY AND SCOPE
To accomplish our review objective, we
• Obtained an understanding of relevant legislation, program guidance, and criteria related

to FHA single-family mortgage insurance.
5
October 1, 2008, through September 30, 2010
6
DOJ conducted the CID proceedings in Fort Worth, TX, and Washington, DC, between February 28 and
September 20, 2011.
7
31 U.S.C.§ 3729 et.seq.
8
Comprised of representatives of the State attorneys general, DOJ, and HUD
2
• Obtained and reviewed available Bank of America written policies and procedures
regarding its foreclosure process. 9
• Obtained and examined relevant reviews of Bank of America’s servicing and foreclosure
processes.
• Obtained and examined the excerpts of personnel documents that Bank of America
provided for selected employees.
• Obtained and reviewed various court documents related to the foreclosure practices of
Bank of America and law firms that conducted work on its behalf.
• Interviewed Bank of America management and staff, including those involved in the
document execution, notary, foreclosure, and claims processes.
• Worked with DOJ to issue 35 CIDs 10 to compel testimony.
• Attended testimonies given by 17 individuals pursuant to CIDs issued by DOJ. Our audit
and legal staff met with DOJ attorneys and provided information, analyses, and relevant
documentation to prepare for the CID testimony proceedings.
• Coordinated with Bank of America’s legal counsel, our Office of Legal Counsel, and
DOJ attorneys from its Washington, DC, Civil Division Fraud Section and the Northern
District of Texas.
• Identified and reviewed a statistical sample of 118 Bank of America FHA claims
processed by HUD during the review period. The sample universe included 32,699
claims records from HUD’s Single Family Data Warehouse associated with Bank of
America and affiliated entities. We randomly selected an attribute sample using a
presumed error rate of 10 percent, a desired precision range of 10 percent (+/- 5 percent),
and a desired confidence level of 90 percent. The sample did not include claims
processed in the names of Countrywide or Taylor, Bean & Whitaker. However, 100 of
the 118 claims in our sample were previously held by Countrywide. 11
• Reviewed FHA claims and related documents for the 118 claims in our sample.
• Obtained and analyzed FHA claims data from both Bank of America and HUD.
• Obtained and analyzed Bank of America shipping logs 12 that identified documents signed
and notarized during the review period and identified the attorney who prepared the
document. However, as described in the following section, the data were incomplete.
• Issued two Inspector General administrative subpoenas for documents and records.
• Analyzed data for Bank of America FHA claims in the 23 judicial foreclosure States and
jurisdictions.
9
Although we repeatedly requested policies and procedures in effect during the entire review period, Bank of
America would provide only those that generally became effective between May and October 2010.
10
Under 31 U.S.C. § 3733 et.seq., CIDs can be served on a person to give oral testimony whenever the Attorney
General has reason to believe that the person may be in control of information relevant to a false claim
investigation.
11
In August 2009, the Government National Mortgage Association hired Bank of America to service roughly $25
billion in FHA receivables it seized from the firm Taylor, Bean & Whitaker. Our review incorporated loans
previously assigned to Taylor, Bean & Whitaker only if Bank of America filed FHA claims in its own name.
12
Bank of America’s shipping logs included FHA and non-FHA foreclosure documents. While Bank of America
had separate teams that handled FHA and non-FHA foreclosures, it could not explain material differences in the
processing of the foreclosures, and its shipping logs did not distinguish between FHA and non-FHA
foreclosures. Bank of America provided incomplete data, which impeded identification of all affiants, notaries,
and attorneys and the complete volume of documents.
3
During the course of our review and the drafting of this memorandum, Bank of America was
actively engaged in negotiations with DOJ in an attempt to resolve potential claims under the
False Claims Act or other statutes for the conduct we were reviewing. Accordingly, OIG
determined that our work product was privileged and not releasable to Bank of America for any
purpose, including the solicitation of written comments on our findings from Bank of America.
For this same reason, we did not provide Bank of America with a copy of the draft
memorandum. Both DOJ and HUD concurred with our determination that the work product was
privileged.
OIG also issued memorandums reporting the results of the reviews of four other servicers. The
results reported in the five OIG memorandums differ due to various factors. These factors
include (1) the level of information made available to the auditors at the time of the onsite
reviews or that was obtained later through subpoenas or CIDs; (2) variances between review
procedures used, including the analysis of the data, that were governed in part by the amount and
types of information obtained; (3) differences between the foreclosure procedures used by the
servicers; and (4) scope limitations imposed by some servicers.
Our review generally covered Bank of America’s foreclosure and claims processes for its FHA
claims initially processed by HUD between October 1, 2008, and September 30, 2010, including
its procedures for signing and notarizing sworn judgment affidavits. The review included both
judicial and nonjudicial foreclosure States and jurisdictions, which provided a comprehensive
overview of Bank of America’s practices and compliance with requirements. 13 We expanded the
scope as needed to accomplish our objective. We initiated our review on October 15, 2010, and
performed onsite work at Bank of America’s offices in Fort Worth, Plano, and Addison, TX, and
Simi Valley, CA, between October 2010 and January 2011.
Scope Limitation
Our review was significantly hindered by Bank of America’s reluctance to allow us to interview
employees. When interviews were permitted, the presence or involvement of attorneys limited
the effectiveness of those interviews. On a number of occasions, Bank of America’s attorneys
refused to allow employees to answer questions, stopped them in the middle of clarifying
information already provided, or counseled them in private before allowing them to provide a
response. Further, Bank of America would not permit an effective walkthrough of its document
execution process that would have facilitated an understanding of its process.
In addition, we issued Inspector General administrative subpoenas because Bank of America did
not provide information and data in a timely manner or a point of contact who could explain and
clarify data. However, the information and data provided in response to our subpoenas were not
complete. For instance, Bank of America provided only excerpts of subpoenaed personnel files,
did not provide complete foreclosure documents for the items in the sample, provided conflicting
information regarding who its affiants were, and could not identify all authorized notaries. As a
result, it was not possible to know how much information Bank of America omitted that was
relevant to our review. For example, although several employees described Bank of America’s
foreclosure process, it was not until its employees provided sworn testimony that they disclosed
that personnel in India conducted the critical foreclosure function of verifying judgment figures.
13
Analysis of potential False Claims Act liability was limited to claims filed in judicial States and jurisdictions.
4
Further, Bank of America provided FHA insurance claims data for only two of its five servicing
identification numbers. In another instance, it provided data that identified signers, notaries, and
attorneys for each claim for only one-third of its FHA claims records. These omissions impaired
our review because they prevented us from measuring the complete impact of Bank of America’s
foreclosure practices.
In an effort to mitigate the scope limitation, DOJ issued CIDs to Bank of America and 34 current
and former employees to compel testimony. Of those, 1 corporate representative and 16 current
and former employees gave sworn testimony about their knowledge concerning Bank of
America’s operation of and/or reliance upon so-called foreclosure mills or robosigners to process
foreclosures. In addition, DOJ facilitated discussions regarding Bank of America’s response to
our Inspector General administrative subpoenas.
RESULTS OF REVIEW
Bank of America did not establish effective control over its foreclosure process. This failure
permitted a control environment in which
• Affiants 14 routinely signed foreclosure documents, including affidavits, certifying that

they had personal knowledge of the facts when they did not. Specifically, affiants
signed large volumes of foreclosure documents without reviewing the supporting
documentation referenced in them. They also consistently failed to verify the
accuracy of the foreclosure documents they signed.
• Notaries public routinely notarized documents without witnessing affiant signatures.
They also failed to keep required records of the documents they notarized. 15
• It may have allowed attorneys to improperly prepare documents and misrepresent the
work they performed.
Review of 118 FHA claim files showed that Bank of America did not consistently retain legal
documents supporting the foreclosure. Analysis of the mathematical accuracy of seven affidavits
containing judgment figures showed inconsistent per diem interest calculations and discrepancies
in accrued interest totals. Also, in one instance, it conveyed a property to HUD with the
incorrect legal description. This flawed control environment resulted in Bank of America filing
improper legal documents, thereby misrepresenting its claims to HUD and may have exposed it
to liability under the False Claims Act.
Questionable Affidavit and Foreclosure Document Processes
Bank of America failed to follow HUD requirements 16 for properties it foreclosed upon in
judicial foreclosure States and jurisdictions. These provisions required Bank of America to
obtain and convey to the Secretary of HUD good and marketable title to properties. Bank of
America may have conveyed flawed or improper titles to HUD because it did not establish a
14
An affiant is a person who signs an affidavit and attests to its truthfulness before a notary public.
15
On July 11, 2011, we referred the apparent notary violations to the Texas Secretary of State.
16
24 C.F.R. § 203.366(a) and HUD Handbook 4330.4, paragraphs 2-6 and 2-23
5
control environment which ensured that affiants performed a due diligence review of the facts
submitted to courts and that employees properly notarized documents.
Judicial foreclosures were processed through the court system beginning with Bank of America
filing a complaint or petition regarding a mortgage purportedly in default. The formal legal
document stated what the debt was and why the default should allow Bank of America to
foreclose on the property. In many judicial foreclosures, an affidavit was part of the foreclosure
documentation. Generally, a representative of Bank of America swore in a notarized affidavit
that Bank of America owned or held the mortgage in question and that the borrower was in
arrears. As judicial States and jurisdictions routinely resolved foreclosures through summary
judgment, 17 the accuracy and propriety of the documents were essential to ensure the integrity of
the foreclosure process. Bank of America used a flawed process to submit FHA conveyance
claims for judicially foreclosed-upon properties and received FHA claim payments of more than
$1.1 billion 18 during the review period.
Affiants Robosigned Foreclosure Documents
Because Bank of America would not provide us written foreclosure policies and procedures in
effect during the review period, we relied on interviews and CID testimony to gain an
understanding of its foreclosure practices. Employees confirmed that affiants routinely signed
legal documents, including affidavits, without the supporting documentation and without
reviewing and verifying the accuracy of the foreclosure information. Many affiants stated that
they only checked to determine whether the foreclosure documents listed them as the signer. In
an interview, a vice president in the document execution group stated that her department only
checked foreclosure documents for formatting and spelling errors. 19
Further, Bank of America had no effective quality assurance function. For example, employees
who performed quality control auditing and training for the document execution group testified
that their focus consisted of ensuring that name and title stamps on foreclosure documents were
straight and legible. In addition, while giving sworn testimony employees could not explain to
DOJ the process by which personnel in India verified the judgment figures included in
foreclosure documents. 20
When asked about the number of foreclosure documents they signed, employees were unable to
provide DOJ with accurate estimates. However, they acknowledged that foreclosure document
volume increased exponentially over time. For example, one notary testified that daily volume
went from 60 to 200 documents per day to 20,000 documents per day with half being duplicates.
One former employee described signing 12- to 18-inch stacks of documents at a time without
review. Employees also admitted signing large volumes of foreclosure documents during
unrelated meetings without reading them. An employee testified that she was instructed to send
out an email message recruiting affiants because Bank of America needed more signers for
17
A decision made on the basis of statements and evidence presented for the record without a trial. It is used
when there is no dispute as to the facts of the case and one party is entitled to judgment as a matter of law.
18
This amount was calculated based on information in HUD’s Single Family Data Warehouse and excludes
claims for deeds in lieu of foreclosure.
19
We have outlined this vice president’s affiant and notary activities in appendix A, as manager 1.
20
Bank of America did not provide policies and procedures that included its India operations.
6
foreclosure documents. In addition, a former vice president in an unrelated business unit
testified that he was required to sign foreclosure documents.
Many employees testified that they relied on a system to ensure that documents they signed were
accurate. However, none effectively described the system. One manager testified that she was
volunteered to be an affiant. According to the manager, the vice president in charge of
foreclosure told her that the information had been verified and she “just simply needed to locate
the sticky in which it had Sign Here and sign my name.” When asked whether she verified the
information, the manager stated that she trusted that the information had been verified because
the vice president told her so. In addition, managers discussed in performance reviews an
unprecedented volume increase due to high foreclosures, which resulted in Bank of America
hiring additional contractors and new employees to prepare foreclosure documents.
Information provided by Bank of America also reflected an increased volume of foreclosure

documents over the review period and showed that it evaluated employee performance based in
part on metrics for processing high volumes of documents. As shown in figure 1, the total
monthly volume of documents signed varied from 4,000 in November 2009 to more than 64,000
in April 2010, with a total of 809,000 documents during the review period. The 10 most
prodigious affiants signed between 31,000 and 78,000 documents during the review period. 21
Appendix A contains affiant and notary narratives that describe the monthly volume of
documents signed and notarized by selected employees.
Figure 1: Document volume by month
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
Jun 2009
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Jul 2009
Jul 2010
Sep 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Apr 2010
Aug 2010
21
As discussed in the Scope and Methodology section, Bank of America provided incomplete data, which
impeded identification of the complete volume of documents each affiant signed.
7
Bank of America’s foreclosure process during the review period did not ensure that it properly
executed foreclosure documents before submitting them to courts or ensure that it conveyed
good and marketable title to HUD.
Notaries Did Not Witness Signatures or Maintain Required Records
Bank of America did not establish a control environment that ensured that its notaries met their
responsibilities under State laws that required them to witness affiants’ signatures on documents
they notarized. 22 Bank of America employed notaries 23 who notarized signatures on foreclosure
documents, but it could not provide a complete list of these employees. Our sample included
documents with notary stamps from Texas and California. Both States required the notary to
authenticate the signer’s signature and maintain a notary log book detailing specific information,
such as the name of the signer, document notarized, and date. 24
Employees stated that affiants did not routinely sign documents in front of a notary. There was
no indication that Bank of America required them to do so. If a notary did not witness the
signature, the notarization of the document was improper. Two employees specifically testified
that they raised concerns about the notary process to management, but management told them to
continue the process. In CID testimony, one of the referenced managers said she did not recall
any concerns about the notary process being brought to her attention. One notary stated that
Bank of America set a target of notarizing 75 to 80 documents per hour and he was evaluated on
whether he met the target. According to the data provided, the 10 most active notaries each
notarized between 14,000 and 77,000 foreclosure documents during the 2-year review period.
The data also showed that one notary, in violation of Texas law, notarized her own signature on
two documents.
Despite management representations to the contrary, employee performance reviews

demonstrated that Bank of America used defined goals and metrics to evaluate performance
based on production in its document execution group. For instance, the manager progress notes
section of two document execution employees’ 2009 and 2010 performance reviews stated:
• “Your Stats so far this year are as follows: Affidavits 46.97 per hour (standard is 49 per
hour), Assignments 54.74 per hour (standard is 51 per hour) and DocEx 49.67 per hour
(standard is 46 per hour.”
• “Your stats so far this year are as follows: Affidavits 40.11 (standard is 49.00 an hour),
Assignments 43.12 (standard is 51.00 an hour) and DocEx 36.91 (standard is 46.00 an
hour). Your numbers are low but I understand why so they are acceptable.”
• “…maintains the production standards set by the Document Execution group and has
very few errors…numbers are exceptional for department stats: Printing 140.77%,
Prepping 148.08%, Stapling 148.02% and Notarizing 121.81%.”
22
Every State’s notary laws require that the notary personally administer an oath and/or personally verify the
identity of the document signer.
23
These notaries had additional job duties and responsibilities.
24
Texas Government Code, Chapter 406, Notary Public, Commissioner of Deeds, and State of California Notary
Law Section 8200
8
As one of the primary purposes of using a notary was to verify the authenticity of the signer,
Bank of America’s failure to ensure that notaries witnessed signatures was a significant control
weakness. 25 Because this type of deficiency undermined the integrity of the control
environment, the affidavits and other foreclosure documents submitted by Bank of America were
unreliable and inauthentic, and may have exposed it to False Claims Act liability.
Law Firms May Have Engaged in Improper Practices
Bank of America used law firms that may have engaged in questionable practices to process
FHA-insured foreclosures. These practices ranged from allegations of robosigning and
unauthorized practice of law to a judge’s ruling that in an attempt to collect on questionable debt,
a firm filed deceptive documents and one of its lawyers lied in court.
For example, a high-level Bank of America official was referred to in a complaint 26 against
Goldbeck, McCafferty, and McKeever, PC (GMM), a law firm that conducted foreclosure work
for Bank of America. The complaint alleged that nonlawyers in the firm engaged in the
unauthorized practice of law by preparing foreclosure complaints, signing lawyers’ names to
those complaints, and filing those complaints in county courts around the Commonwealth of
Pennsylvania. The plaintiff averred that Bank of America knew of, directed, and profited from
the conduct of the nonlawyers and that the high-level official, an attorney, was present in a
courtroom when Mr. McKeever testified that it was “standard practice” for nonlawyers to engage
in the unauthorized practice of law. The complaint included transcript excerpts from the
December 8-9, 2009, hearing and 27 exhibits containing signatures supporting the allegation that
nonlawyer defendants prepared, signed, and filed hundreds of thousands of cases without
attorney review.
GMM processed 469 foreclosure documents for Bank of America in Pennsylvania and New
Jersey. Of the 118 sample loans, 2 were processed by the firm. As figure 2 shows, it appeared
that at least 5 different individuals signed 13 documents for attorney Michael McKeever for the 2
sample loans. If nonlawyers, on GMM’s behalf, signed and filed documents for FHA-insured
foreclosures, these filings may not have been valid and may have caused Bank of America to file
false claims.
25
According to Bank of America, it implemented new procedures in October 2010 that required notaries to
witness affiants’ signatures on foreclosure documents. However, we did not test the procedures, as Bank of
America limited our review to the stated review period.
26
Loughren vs. Lion, et al., GD-10, Allegheny County, PA
9
Figure 2: Five different signatures of attorney Michael McKeever for two sample loans
In addition, the Chief U.S. Bankruptcy Judge for Western Pennsylvania issued a memorandum
opinion and order 27 and a memorandum order 28 that were “intended to serve as a public
reprimand” 29 of GMM and one of its attorneys, Leslie M. Puida. The judge sanctioned the firm
and its attorney for filing deceptive documents in a foreclosure proceeding and found that
“Puida, and by extension GMM, had not been honest with this Court.” 30 The judge ruled that the
firm filed copies of three key letters created after the fact in an attempt to collect on questionable
debt that were never sent to the homeowner or her lawyer. The judge stated that “the evidence
that Puida lied was considerable” 31 and publicly reprimanded GMM and Leslie M. Puida for
their misconduct and ordered them to report to the Disciplinary Board of the State Supreme
Court.
In another Bank of America example, a notary for Phelan, Hallinan & Schmieg testified in a
deposition that over a 3-year period, “he falsely acknowledged tens of thousands of mortgage
assignments” 32 for the firm, often outside the signer’s presence. The notary also acknowledged
under oath that he notarized documents in New Jersey when he did not hold a notary license in
that State. In addition, a partner was accused of having potential conflicts of interest in the
27
In re Hill, 437 B.R. 503 (Bankr. W.D. Pa., October 5, 2010)
28
In re Hill, 437 B.R. 503 (Bankr. W.D. Pa., November 24, 2010)
29
In re Hill, 437 B.R. 503 pg 8 (Bankr. W.D. Pa., November 24, 2010)
30
31
32
Bank of New York v. Ukpe, pg 6 Docket No. F-10209-08
10
assignment of mortgage notes. 33 It was argued that the partner executed an assignment in his
capacity as a Mortgage Electronic Registration Systems 34 officer while Phelan, Hallinan &
Schmieg was also a vendor for Mortgage Electronic Registration Systems, the assignor. The
notary and partner had both been individually named in proceedings involving questionable
foreclosure practices for servicers other than Bank of America. 35 According to Bank of
America’s records, Phelan, Hallinan & Schmieg processed 931 documents for proceedings in 3
judicial foreclosure States. 36
Our analysis of Bank of America’s shipping logs showed that Bank of America used a small
group of law firms to process foreclosures. As shown in table 1, 10 law firms processed 62 and
81 percent of Bank of America’s judicial and nonjudicial foreclosure documents, respectively.
Many of these law firms had been named in various court proceedings throughout the country,
alleging questionable foreclosure activities.
Table 1: Top 10 law firms that processed Bank of America foreclosure documents
Judicial foreclosure States Nonjudicial foreclosure States
Number of Number of
Law firm documents Percentage Law firm documents Percentage
Feiwell & Hannoy, PC 976 9.81 Prommis Solutions, LLC 4,892 36.77
Phelan Hallinan & Barrett Daffin Frappier
Schmieg 931 9.35 Turner & Engel 1,875 14.09
Reisenfeld and Associates 732 7.35 Millsap & Singer, LLC 788 5.92
Carlisle, McNellie, Rini,
Kramer & Ulrich Co. 680 6.83 Trott & Trott 761 5.72
McFadden, Lyon &
Luper Neidenthal & Logan 610 6.13 Rouse, LLC 580 4.36
Bierman, Geesing, Ward
Pierce and Associates 520 5.22 & Wood 501 3.77
Lerner, Sampson & Martin, Leigh, Laws &
Rothfuss 492 4.94 Fritzlen, PC 479 3.60
Goldbeck McCafferty &
McKeever 469 4.71 Sirote & Permutt, PC 454 3.41
Codilis & Associates, PC 398 4.00 Adams & Edens 274 2.06
Barrett Burke Wilson
Adorno & Yoss 395 3.97 Castle Daffin & Frappier 220 1.65
Subtotal - top 10 firms 6,203 62.32 Subtotal - top 10 firms 10,824 81.36
Subtotal - all others 3,750 37.68 Subtotal - all others 2,480 18.64
Total nonjudicial
Total judicial documents 9,953 documents 13,304
33
Bank of New York v. Ukpe, Docket No. F-10209-08
34
Commonly referred to as MERS
35
U. S. Bank NA v. Sinchegarcia, F-18446-08. Deutsche Bank National Trust Company v. Charlene Smith, No.
08-3089
36
Bank of America provided data that accounted for only about one-third of its FHA foreclosures during our
review period. This lack of data impeded identification of the complete volume of documents each law firm
prepared.
11
On November 16, 2010, the Congressional Oversight Panel released an in-depth report analyzing
the robosigning allegations. 37 Its report concluded that “[t]he foreclosure documentation
irregularities unquestionably show a system riddled with errors” and emphasized “that mortgage
lenders and securitization servicers should not undertake to foreclose on any homeowner unless
they are able to do so in full compliance with applicable laws and their contractual agreements.”
If third-party law firms engaged in questionable practices on behalf of Bank of America, the
foreclosures may not have complied with laws and agreements. These questionable practices
may have exposed Bank of America to liability under the False Claims Act.
Legal Documents Were Not Consistently Maintained
Bank of America’s FHA claim files for the 118 sample loans did not consistently contain
relevant preforeclosure information that supported the legal basis for foreclosure. Therefore,
Bank of America could not demonstrate that it conveyed clear and marketable title to HUD. In
addition, the file reviews identified 23 affiants who signed foreclosure documents on Bank of
America’s behalf but were not authorized to do so by appropriate board resolution as provided
by Bank of America. According to its records, the 23 individuals signed 820 foreclosure
documents during the review period. HUD should require Bank of America to retain in its FHA
claim files legal documents supporting the foreclosure and the underlying supporting business
records for those legal documents.
Affidavits Contained Inconsistencies and Errors
We reviewed the seven affidavits that contained judgment figures in judicial foreclosure States to
determine whether they were mathematically correct. Bank of America calculated per diem
interest charges inconsistently and had discrepancies in accrued interest totals. Specifically, it
calculated per diem interest using a 360-day year in three cases, 365 days in two cases, an
undetermined method in one case, and both methods in different versions of the document in the
last case. Errors in interest calculations ranged from $16 to $470. This error rate indicated that
Bank of America lacked proper controls to ensure that it correctly and consistently calculated
accrued interest charges in documents it filed in courts to support its foreclosure actions.
However, the unpaid principal balance on each affidavit matched the amount on the FHA
insurance claim in all seven cases.
Bank of America Conveyed a Property That Had an Incorrect Legal Description to HUD
Bank of America conveyed a property located in Modesto, CA, to HUD with an incorrect legal
description. 38 California is a two-deed State, requiring a trustee deed and a grant deed. The
grant deed conveying the property title to HUD used a legal description for a property on another
street. Because the legal description was incorrect, Bank of America did not give HUD good and
37
Congressional Oversight Panel, November Oversight Report Examining the Consequences of Mortgage
Irregularities for Financial Stability and Foreclosure Mitigation (November 16, 2010), available at
http://cop.senate.gov/documents/cop-111610-report.pdf (submitted under section 125(b)(1) of Title 1 of the
Emergency Economic Stabilization Act of 2008, Pub. L. No. 110-343)
38
FHA case number 045-6483650
12
marketable title to the property. HUD regulations 39 required Bank of America to convey good
and marketable title as well as satisfactory title evidence. Because its internal controls did not
prevent the error, its foreclosure and later conveyance of title to HUD were improper. HUD
should require Bank of America to remedy the apparent defect in title for this property.
CONCLUSION
Bank of America did not establish an effective control environment to ensure the integrity of its
foreclosure process. Because it failed to establish proper policies and procedures that fostered
compliance with laws and regulations, its affiants robosigned foreclosure documents, its notaries
failed to authenticate signatures, and it used law firms that may have falsified legal foreclosure
documents. As a result of its flawed control environment, Bank of America engaged in improper
practices by not fully complying with applicable foreclosure procedures when processing
foreclosures on FHA-insured loans, thereby misrepresenting its claims to HUD.
During the review period, Bank of America submitted 8,973 conveyance claims 40 totaling $1.1
billion in the 23 judicial foreclosure States and jurisdictions. DOJ used our review and analysis
in negotiating the settlement agreement.
RECOMMENDATIONS
Once the settlement agreement is approved by the court, OIG will issue a separate summary
memorandum to HUD containing recommendations to correct weaknesses discussed in this and
the other four memorandums. Accordingly, this memorandum contains recommendations to
address only specific Bank of America deficiencies.
We recommend that HUD’s Deputy Assistant Secretary for Single Family Housing
1A. Ensure that Bank of America retains appropriate legal documentation supporting all
FHA-insured foreclosures in its FHA claim files.
IB. Require Bank of America to remedy the apparent defect in title for the property it
conveyed to HUD with the incorrect legal description (FHA case number 045-6483650).
We recommend that the Director of HUD’s Departmental Enforcement Center
1C. Pursue appropriate administrative sanctions against notaries who may have violated State
notary requirements.
1D. Pursue appropriate administrative sanctions against attorneys who may have violated
professional obligations related to foreclosures of FHA-insured mortgages.
Appendix:
Appendix A Affiant and Notary Narratives
39
24 C.F.R. § 203.358
40
Excludes deeds in lieu of foreclosure
13
APPENDIX
Appendix A
AFFIANT AND NOTARY NARRATIVES

The affiant and notary narratives in this appendix detail the volumes of documents signed or
notarized by selected affiants and notaries. We selected six examples of the affiant and notary
narratives to include in this memorandum from the 34 employees to whom DOJ served CIDs. 41
As stated in the body of the memorandum, the data Bank of America provided accounted for
only approximately one-third of its FHA foreclosures. Therefore, we have no assurance that the
figures presented in the narratives were complete and reliable.
The narratives also include excerpts from relevant testimony from CID proceedings conducted
by DOJ and excerpts from personnel records provided by Bank of America. In response to our
December 2, 2010, subpoena, Bank of America submitted partial personnel documentation
instead of providing complete personnel records as required. As a result, it was not possible to
know whether Bank of America omitted information relevant to our review. However, the
excerpts demonstrated that document volumes increased during the review period and Bank of
America evaluated employee performance based at least in part on whether employees met
predetermined metrics for processing foreclosure documents. The primary purpose of the
narratives was to assist DOJ in preparing for CID proceedings.
41
Two employees who served as both an affiant and notary, two employees who were affiants, and two
employees who were notaries
14
Manager 1 – Affiant and Notary
Manager 1 signed 12 foreclosure documents for 8 of our 118 sample loans, 2 of which were
potentially presented as evidence in judicial State court proceedings.
Affiant Statistics
According to Bank of America’s shipping logs, manager 1 signed 46,936 and notarized 45
foreclosure documents during the 2-year review period.
Manager 1 signatures by month

Month Documents Month Documents
Oct 2008 449 Oct 2009 3,203
Nov 2008 148 Nov 2009 111
Dec 2008 673 Dec 2009 8
Jan 2009 1,136 Jan 2010 1,681
Feb 2009 1,104 Feb 2010 3,911
Mar 2009 1,187 Mar 2010 5,486
Apr 2009 1,765 Apr 2010 6,098
May 2009 499 May 2010 2,903
Jun 2009 979 Jun 2010 1,812
Jul 2009 664 Jul 2010 2,652
Aug 2009 1,760 Aug 2010 6,213
Sep 2009 1,269 Sep 2010 1,225
Total documents signed 46,936
7,000
Manager 1 signatures
6,000
5,000
4,000
3,000
2,000
1,000
0
Jun 2009
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Sep 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Apr 2010
Aug 2010
15
Manager 1 routinely signed foreclosure documents, including affidavits, certifying that she had
personal knowledge of the facts when she did not. She consistently failed to verify the accuracy
of the foreclosure documents she signed.
CID Testimony
Manager 1 testified that Bank of America’s process did not require her to verify the information
in foreclosure documents before signing. She agreed that the standard industry practice was to
execute affidavits without reading documents. She did not specifically recall reading documents.
She also agreed that it was industry practice to have documents notarized outside the presence of
the signer. In her testimony, manager 1 responded that her direct supervisor, a vice president,
was aware and approved of the industry standard being followed. She assumed her supervisor’s
boss would have approved and been aware of the same.
When asked about a paragraph manager 1 signed stating that she had personal knowledge,
manager 1 said that she “didn’t read the document to read personal knowledge. Again, the
process was just to sign the document.” When asked if she did anything to verify an amount that
was due and owing, manager 1 responded, “No. The process at the time was just to sign the
document.” Manager 1 gave similar answers throughout her testimony. She was also a notary
and testified that she did not typically witness signatures.
Personnel File Excerpt

Manager 1’s supervisor (manager 3) discussed goals, metrics, and a reengineered document
execution process in her 2010 performance review:
• Your group “now has clear goals and metrics by which to evaluate performance. There
exists an opportunity to address poor performance issues more rapidly.”
• “You have completed the re-engineering of the document execution proicess [sic]. This
was a significant initiative you formulated that has enabled your group to rapidly scale up
to match increasing volumes as well as improve turnaround time and communication.”
16
Manager 2– Affiant and Notary
Manager 2 signed foreclosure documents for 4 of our 118 sample loans, 1 of which was
potentially presented as evidence in a judicial State court proceeding. Manager 2 also notarized
one judicial State foreclosure document.
Affiant Statistics
According to Bank of America’s shipping logs, manager 2 signed 67,908 and notarized 1,390
foreclosure documents during the 2-year review period. Bank of America’s records indicated
that manager 2 notarized her own signature on two documents.

Month Count Month Count Month Count
Oct 2008 2,070 Jun 2009 3,471 Feb 2010 178
Nov 2008 590 Jul 2009 3,411 Mar 2010 552
Dec 2008 830 Aug 2009 3,796 Apr 2010 3,345
Jan 2009 1,303 Sep 2009 652 May 2010 5,482
Feb 2009 3,217 Oct 2009 1,068 Jun 2010 7,443
Mar 2009 4,267 Nov 2009 324 Jul 2010 8,884
Apr 2009 5,115 Dec 2009 5 Aug 2010 8,753
May 2009 2,155 Jan 2010 27 Sep 2010 970
10,000
9,000
8,000
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Sep 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Jun 2009
Apr 2010
Aug 2010
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
17
of the foreclosure documents she signed. Manager 2 also routinely notarized documents without
witnessing affiant signatures and failed to keep required records of the documents she notarized.
CID Testimony
Manager 2 acknowledged that she did not have personal knowledge when she signed foreclosure
documents. Further, she would not typically have additional case-related documents available to
her when she signed affidavits, but the information was available in Bank of America’s computer
system. However, she acknowledged that she did not routinely inform herself by looking at the
computer system.
Manager 2 testified that she would read the first paragraph of the document before locating the
“sign here” sticky directing her attention to the particular place she would need to sign. She
estimated that she spent approximately 1½ to 2 hours per day signing documents and spent 2 to 3
minutes on each document. Notaries were not present when manager 2 signed documents, and
other signers in her group did not make a habit of signing with notaries present. Further, as a
notary, she did not typically witness the signing of documents and referred to Bank of America’s
shipping log as an electronic notary log.
Personnel File Excerpt

In her 2009 performance review, manager 2 and her supervisor (manager 1) discussed volume
increases and departmental growth:
• “Your team continues to grow through this time of unprecedented volume.”

• “When assumed the group late in 2006 had no idea, like others, volume would result with
a dramatic increase. Due to the volume group has evolved from 15-20 associates to 30+
and continues to grow.”
• “In order to assist the huge increase in the document request volume, contractors were
hired July-August to assist with the prepping of documents…By 3rd quarter, document
request volume exceeded expectations due to high foreclosure referral volume. To
address increased volume, in addition to the four above new associates and [sic]
additional eight associates were hired.”
18
Manager 3 – Affiant
Manager 3 signed 7 foreclosure documents for 6 of our 118 sample loans, 1 of which was
potentially presented as evidence in a judicial State court proceeding.
Affiant Statistics
According to Bank of America’s shipping logs, manager 3 signed 36,885 foreclosure documents
during the 2-year review period.

Month Documents Month Documents
Oct 2008 0 Oct 2009 2,976
Nov 2008 0 Nov 2009 128
Dec 2008 0 Dec 2009 9
Jan 2009 1 Jan 2010 1,090
Feb 2009 0 Feb 2010 3,835
Mar 2009 1 Mar 2010 4,380
Apr 2009 0 Apr 2010 2,294
May 2009 56 May 2010 696
Jun 2009 2,880 Jun 2010 997
Jul 2009 7,938 Jul 2010 2
Aug 2009 6,456 Aug 2010 2
Sep 2009 3,144 Sep 2010 0
9,000
8,000
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0
Jun 2009
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Sep 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Apr 2010
Aug 2010
19
CID Testimony
Manager 3 testified that documents were checked before they came to her for signature.
However, she acknowledged that she did not verify information or undertake a review of a
specific loan file to give herself “firsthand knowledge of the business records with respect to an
actual loan before signing a document.” She stated that she looked at the document, looked at
the investor, and signed it. While manager 3 stated that sometimes notaries watched as she
signed documents, she acknowledged that generally they did not watch her sign the documents.
Manager 3 explained that as a vice president, she managed four groups: foreclosure group,
quality control group, reporting group, and document execution group. These groups were
managed by three vice presidents and an assistant vice president. For the quality control group,
manager 3 did not recall any written quality control policies or procedures, and she did not
participate in the creation of policies. She acknowledged an increase in document volume and an
expansion of the document execution group because of the increase. She knew that there were a
number of affiants who were not assigned to the document execution group who signed
foreclosure-related legal documents. According to her, the preparation process simply involved
a stamp being placed on a particular document with a sticky identifying the page to be signed.
Manager 3 also testified that recruiting new affiants was an ongoing process and that managers
made recommendations for them. She was not familiar with the process for the review team in
India. In addition, she acknowledged that she understood that courts relied on documents that
she signed in deciding foreclosure cases.
20
Manager 4 – Affiant
Manager 4 signed foreclosure documents for 13 of our 118 sample loans, 5 of which were
Affiant Statistics
According to Bank of America’s shipping logs, manager 4 signed 42,926 foreclosure documents
during the 2-year review period.

Month Count Month Count Month Count
Oct 2008 1,330 Apr 2009 2,533 Oct 2009 3,380
Nov 2008 788 May 2009 4,477 Nov 2009 147
Dec 2008 2,052 Jun 2009 3,927 Dec 2009 220
Jan 2009 3,059 Jul 2009 2,077 Jan 2010 3,179
Feb 2009 2,031 Aug 2009 5,439 Feb 2010 1,156
Mar 2009 3,683 Sep 2009 3,424 Mar 2010 24
6,000
5,000
4,000
3,000
2,000
1,000
0
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Sep 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Jun 2009
Apr 2010
Aug 2010
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
21
CID Testimony
When asked how she went about gaining an understanding of what she was supposed to do with
documents that were brought to her, manager 4 testified, “I don’t recall if anybody – if my
supervisor spoke to me about it, I mean, you know, you just see it. You just, you know.” Her
standard process in signing documents was to scan the document, ensure that her name was
listed, and then sign it. Manager 4 estimated that she would execute 100 documents per day in ½
hour or less. She stated that notaries were not present when she executed documents. Manager 4
stated that she understood that the documents were verified before she signed them, but she did
not recall how she gained that understanding.
22
Notary 1
Notary 1 notarized 7 foreclosure documents for 6 of our 118 sample loans, 3 of which were
potentially presented as evidence in judicial State court proceedings. Notary 1 notarized the
highest volume of documents during the 2-year review period.
Notary Statistics
According to Bank of America’s shipping logs, notary 1 notarized 77,447 foreclosure
documents, containing 94,167 signatures, during the 2-year review period.
Documents notary 1 notarized Signatures notary 1 notarized

Month Documents Month Documents Month Signatures Month Signatures
Oct 2008 3,687 Oct 2009 267 Oct 2008 4,493 Oct 2009 419
Nov 2008 3,370 Nov 2009 0 Nov 2008 4,021 Nov 2009 0
Dec 2008 4,653 Dec 2009 4 Dec 2008 5,817 Dec 2009 4
Jan 2009 5,266 Jan 2010 294 Jan 2009 6,302 Jan 2010 444
Feb 2009 6,769 Feb 2010 1,049 Feb 2009 8,535 Feb 2010 1,160
Mar 2009 9,760 Mar 2010 2,728 Mar 2009 11,880 Mar 2010 3,252
Apr 2009 6,948 Apr 2010 3,584 Apr 2009 9,273 Apr 2010 3,885
May 2009 5,355 May 2010 111 May 2009 7,016 May 2010 120
Jun 2009 2,807 Jun 2010 1,273 Jun 2009 3,493 Jun 2010 1,430
Jul 2009 3,761 Jul 2010 2,960 Jul 2009 4,917 Jul 2010 3,382
Aug 2009 1,188 Aug 2010 8,244 Aug 2009 1,448 Aug 2010 9,031
Sep 2009 616 Sep 2010 2,753 Sep 2009 865 Sep 2010 2,980
Total documents notarized 77,447 Total signatures notarized 94,167
14,000
12,000
Notary 1 statistics
10,000
8,000
6,000
4,000
2,000
0
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Sep 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Aug 2010
Jun 2009
Apr 2010
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
Documents Signatures
23
Notary 1 routinely notarized documents without witnessing affiant signatures and failed to keep
required records of the documents she notarized.
CID Testimony
Notary 1 testified that she did not maintain a notary log book, but Bank of America had an Excel
spreadsheet. She explained that she knew she was required to keep a log as an individual but as
an employee of the bank, she did not feel it was her responsibility. Notary 1 also did not witness
signatures or swear an oath for affiants. She also testified that she observed affiants signing
documents without reading them.
Notary 1 testified that when she began her employment, her department processed 60 to 200
documents per day. It increased to 10,000 to 20,000 documents sitting in an in-box. She stated
that employees wondered how they were going to process them. According to notary 1, half of
the documents were duplicates, and they had a 24- to 48-hour turnaround timeframe, which
notary 1 believed was unreasonable. Notary 1 stated that employees tried to relay the
unreasonableness of the turnaround time to team leaders and supervisors but were told to
continue with what they were doing.
Notary 1 also testified that she and others thought they should be notarizing documents in front
of the affiant. When she raised this issue, she was told that it was acceptable not to be in the
presence of an affiant when notarizing a document if the notary knew the affiant and his or her
signature. Further, she was told by management to stop checking the details on documents such
as assignments, deeds, and affidavits.
Review of Personnel File Excerpts

Although managers represented that Bank of America had no quota system, it appeared that
employees were evaluated based on production. For example, in her 2009 evaluation, notary 1’s
manager made the following comment: “continues to meet the deadlines and complying with the
requirements of the attorneys. She meets the production standards set by the Document
Execution Group.” In addition, notary 1 commented that she had “always been able to meet or
exceed required stats and deadlines,” and her manager commented on notary 1’s understanding
the need to meet the set timelines.
24
Notary 2
Notary 2 notarized foreclosure documents for 3 of our 118 sample loans, 2 of which were
Notary Statistics
According to Bank of America’s shipping logs, notary 2 notarized 27,585 foreclosure
documents, containing 31,236 signatures, during the 2-year review period.
Documents notary 2 notarized Signatures notary 2 notarized

Month Documents Month Documents Month Signatures Month Signatures
Oct 2008 1,356 Oct 2009 502 Oct 2008 1,372 Oct 2009 507
Nov 2008 691 Nov 2009 145 Nov 2008 715 Nov 2009 145
Dec 2008 1,635 Dec 2009 Dec 2008 1,666 Dec 2009 0
Jan 2009 1,272 Jan 2010 26 Jan 2009 1,288 Jan 2010 30
Feb 2009 1,215 Feb 2010 213 Feb 2009 1,268 Feb 2010 229
Mar 2009 1,152 Mar 2010 211 Mar 2009 1,180 Mar 2010 217
Apr 2009 2,182 Apr 2010 457 Apr 2009 2,253 Apr 2010 457
May 2009 2,299 May 2010 305 May 2009 2,814 May 2010 305
Jun 2009 3,278 Jun 2010 902 Jun 2009 3,763 Jun 2010 907
July 2009 4,268 July 2010 16 July 2009 5,299 Jul 2010 16
Aug 2009 4,514 Aug 2010 0 Aug 2009 5,617 Aug 2010 0
Sep 2009 946 Sep 2010 0 Sep 2009 1,188 Sep 2010 0
Total documents notarized 27,585 Total signatures notarized 31,236
6,000
Notary 2 statistics
5,000
4,000
3,000
2,000
1,000
0
Mar 2009
May 2009
Mar 2010
May 2010
Jan 2009
Feb 2009
Sep 2009
Jan 2010
Feb 2010
Jul 2009
Jul 2010
Nov 2008
Apr 2009
Aug 2009
Nov 2009
Jun 2009
Apr 2010
Jun 2010
Dec 2008
Dec 2009
Oct 2008
Oct 2009
Documents Signatures
25
Notary 2 routinely notarized documents without witnessing affiant signatures and failed to keep
required records of the documents he notarized.
CID Testimony
Notary 2 testified that generally he was not present when affiants signed documents and he did
not maintain a notary log book. He stated that this was the normal practice at Countrywide and
Bank of America. In cases of rush documents (approximately 1 percent of the documents), he
would witness signatures. Notary 2 testified that supervisors were aware of his and other
notaries’ practice of not witnessing affiants signing documents. Productivity was monitored by
the team managers, and they would periodically change the performance metrics.
According to notary 2, Countrywide’s instructions on how to notarize documents was nothing

more than where to place the notary stamp and sign the document. He received no other notary
training, written materials, or oral instructions. When he became a Bank of America employee,
his process did not change. To his recollection, Bank of America did not perform an operational
review of his area when it acquired Countrywide.
26

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Filing # 63142758 E-Filed 10/20/2017 05:58:45 PM

IN THE SUPREME COURT OF FLORIDA

vs. THIRD DCA CASE NO.: 3D17-58

U.S. BANK NATIONAL LOWER CASE NO.: 2009-86386 CA 01

APPENDIX TO PETITIONER’S PETITION TO INVOKE ALL WRITS

JACOBS KEELEY, PLLC

BY: /S/ BRUCE JACOBS

Appendix G Office of the Attorney General Economics Crime Division: Unfair,

Appendix I Consent Order from Office of the Comptroller

emailed to [email protected]; [email protected], Nancy M.

Fl 32301 this 20th day of October 2017.

/s/ Bruce Jacobs

JACOBS KEELEY, PLLC

BY : /S/ BRUCE JACOBS

Florida Attorney General investigation

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Asst. Vice President

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T he Grantee is identified as "Bogus Assignee."