{"took":106,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":13,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"8873581","_score":34.616737,"_source":{"product":"Credit card","complaint_what_happened":"I was given the reason that synchrony bank close my account was due to multiple cards high balances and not having real estate assets. The fact of the matter is, Ive significantly paid down my credit cards debt and outstanding medical bills. My credit score has gone up in the past 30 days I believe a factor they close my account is due to MYAGE. I paid off my XXXX XXXX  card, and Lowes credit card with synchronicity in the last 60 days Synchronicity decided To recently close my Lowes card After it was paid in full, they also close my CareCredit account and my Crate & Barrel account. I was not past due on paying my credit cards, but because I had auto pay set up, they attempted to withdraw a payment several times From an old bank account within the same pay Period when I didnt have funds available. \n\nI enjoyed having the cards open and appreciate them extended credit to me. They are A major factor at driving down my credit score, driving up my interest rates Making it that much harder to reduce my debt with other credit card providers. \n\nAgain, I am a woman of a certain age that doesnt own real estate that has a steady six figure employment. Age and sec is playing a factor here which is discrimination. Their analytics programs should be investigated and my credit score should have any negative impact reversed by the credit bureaus.","date_sent_to_company":"2024-04-28T01:28:57.000Z","issue":"Closing your account","sub_product":"Store credit card","zip_code":"30067","tags":null,"has_narrative":true,"complaint_id":"8873581","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"SYNCHRONY FINANCIAL","date_received":"2024-04-28T01:03:31.000Z","state":"GA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Company closed your account"},"highlight":{"complaint_what_happened":["Again, I am a woman of a certain age that doesnt own <em>real</em> <em>estate</em> that has a steady six figure employment. Age and sec is playing a factor here which is discrimination. Their <em>analytics</em> programs should be investigated and my credit score should have any negative impact reversed by the credit bureaus."]},"sort":[34.616737,"8873581"]},{"_index":"complaint-public-v1","_id":"14353404","_score":32.6957,"_source":{"product":"Mortgage","complaint_what_happened":"It seems we are describing a complex and potentially distressing situation involving a property, a wrongful foreclosure, and a large number of heirs, with several financial institutions and a XXXX company mentioned. This was broken down for us by XXXX XXXX of the National Justice Center and was written and received on Friday XXXX XXXX Let 's break down the entities and concepts involved : XXXX XXXX XXXX is a leading global provider of property information, analytics, and data-enabled solutions. Headquartered in XXXX, California XXXX XXXX, they specialize in collecting, maintaining, and integrating a vast amount of real estate-related data. Their services are used by a wide range of clients, including : Real estate professionals : For property valuations, market analysis, and insights. \nFinancial institutions : To assess risk, manage mortgages, and make informed lending decisions. \nInsurance carriers : For property risk assessment and underwriting. \nGovernment agencies : For various property-related services. \nIn essence, XXXX acts as a data and analytics backbone for the real estate and mortgage XXXX name appears in our investment investigation as well. They don't typically directly foreclose on properties themselves. Instead, they provide the data and tools that financial institutions, like banks or mortgage servicers, use in their operations, which can include foreclosure processes. \nThe is an true statement for a Wrongful Foreclosure The XXXX Case description points to a \" wrongful foreclosure '' involving \" XXXX XXXX XXXXXXXX '' as owners and an additional \" XXXX Heirs. '' This suggests a situation where : Wrongful Foreclosure : The foreclosure may have occurred illegally or improperly, potentially due to errors in process, lack of proper notification, or other legal violations.\n\nMultiple Heirs : The presence of 99 heirs indicates a property that was likely inherited, and potentially, the ownership structure or inheritance process was not clearly established or communicated to all parties involved. In the XXXX, where XXXX is located, dealing with a proposed inherited property with multiple beneficiaries can be complex, often requiring unanimous agreement or court intervention ( like a partition action ) if there's a dispute among heirs. I was assigned the XXXX Case and Lenders are generally required to notify all parties with an interest in the property during a foreclosure, even if they aren't personally liable for the XXXXXXXX XXXX XXXXXXXX XXXX were the only party to Own the residential of XXXX XXXX XXXX XXXX Georgia XXXX when transferred to BofA XXXX XXXX XXXXXXXX XXXX XXXX who sold their Property to XXXX XXXX XXXX XXXX In which we mention a \" sale of property control number assigned XXXX by BofA XXXX XXXX XXXX XXXX XXXXXXXX to XXXX XXXX XXXX XXXX in XXXX XXXX. '' BofA XXXX XXXX XXXX XXXXXXXX XXXX : This refers to a part of Bank of America XXXX XXXX a major global financial institution. As a large bank, they would be involved in various financial activities, including potentially holding or selling distressed assets, which could include properties or mortgage-backed securities. \nXXXX XXXX XXXX XXXX : This appears to be a private property entity in XXXX, XXXX. The \" control number XXXX '' suggests a specific identifier for this transaction or asset. \nConnecting the dots : It appears that BofA XXXX XXXX XXXXXXXX XXXX XXXX sold the property ( or the debt associated with it ) to XXXX XXXX, and this transaction led to the wrongful foreclosure of XXXX and XXXX 's property, without the knowledge of the XXXX heirs who also had an interest.This group of XXXX Heirs were paying the taxes on the property without any knowledge by XXXX and XXXX XXXX Key Issues Implied Based on our statement, the critical issues at play would likely be : Legitimacy of the Foreclosure : Was the foreclosure process legally sound, especially given the presence of numerous heirs and their alleged lack of knowledge about the sale? \nNotification to Heirs : Were all XXXX owners ( XXXX, XXXX, and XXXX heirs ) in which XXXX and XXXX were not properly notified of the mortgage, default, with the XXXX and subsequent sale/foreclosure? In cases of inherited property, determining and notifying all legal heirs can be a significant challenge for lenders. \nProperty Ownership and Inheritance Law : The specifics of how the property was inherited and the legal status of each heir 's claim would be crucial. XXXX property law regarding inherited estates with multiple beneficiaries can be complex. \nRole of XXXX : While XXXX isn't typically a foreclosing entity, the data and services they provide might be relevant to how the bank or servicer managed the mortgage and identified ( or failed to identify ) all parties with an interest in the property. \nIn summary, XXXX is a data and analytics provider for the real estate industry, not a direct participant in foreclosures in the same way a bank or mortgage servicer would be. The situation you describe points to a potential case of wrongful foreclosure with significant complications due to multiple, potentially unnotified, heirs and a sale between financial entities in the XXXX. \nGiven the complexity and the legal nature of this situation, it would be absolutely critical for XXXX, XXXX, and even the other heirs to seek legal counsel specializing in property law and wrongful foreclosures in XXXX also. \nGrace Unto The XXXX Family XXXX XXXX of the National Justice Center","date_sent_to_company":"2025-06-28T23:13:18.000Z","issue":"Struggling to pay mortgage","sub_product":"VA mortgage","zip_code":"302XX","tags":"Older American, Servicemember","has_narrative":true,"complaint_id":"14353404","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"BANK OF AMERICA, NATIONAL ASSOCIATION","date_received":"2025-06-28T22:17:58.000Z","state":"GA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Foreclosure"},"highlight":{"complaint_what_happened":["In essence, XXXX acts as a data and <em>analytics</em> backbone for the <em>real</em> <em>estate</em> and mortgage XXXX name appears in our investment investigation as well. They don't typically directly foreclose on properties themselves. Instead, they provide the data and tools that financial institutions, like banks or mortgage servicers, use in their operations, which can include foreclosure processes."]},"sort":[32.6957,"14353404"]},{"_index":"complaint-public-v1","_id":"1763627","_score":24.17206,"_source":{"product":"Mortgage","complaint_what_happened":"In XXXX, I requested American Home Mortgage Servicing , Inc. to provide evidence that they had the right to foreclose on our primary residence. I received a letter from XXXX XXXX, Loan Administration Research Specialist, on XXXX/XXXX/XXXX. Per my request, she included a copy of the executed Note and Deed of Trust from the closing of our loan. She also stated the owner and Note holder for the loan is Option One Mortgage Loan Trust. The documents provided by XXXX XXXX did not include an allonge or any assignments or transfers of our Note or Deed of Trust to a securitized trust. We did a title search in XXXX XXXX. The title search revealed that our original lender, Option One Mortgage Corporation, was in XXXX lien position. \nIn XXXX XXXX, XXXX f/k/a Option One Mortgage Corporation filed a fraudulent assignment of Deed of Trust in XXXX XXXX. XXXX XXXX retroactively attached our mortgage to a securitized trust that was closed and sold to investors 5 years earlier, the bank violated a Texas law that prohibits fraudulent real estate filings. \nDeclaration from President of XXXX XXXX XXXX from XXXX states that XXXX XXXX XXXX is no longer engaged in the servicing of residential mortgage loans. XXXX XXXX has no servicing rights and does not own any residential real estate mortgages. \nAffidavit from XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX, states that XXXX XXXX, person who signed the Assignment of Deed of Trust, is a listed on XXXX Property Analytics Approved Robo-signers list. \nOOMLT XXXX was contractually closed from conducting business after the closing date of XXXX/XXXX/XXXX. Any attempt to assign the subject loan to the trust after the cut-off date would be in direct contravention of the laws governing the Trust ( PSA ) and thus rendering the fraudulent assignment of deed of trust filed in XXXX XXXX in the XXXX XXXX XXXX XXXX office void. \nWe filed a lawsuit against AHMSI in XXXX XXXX. Discovery with AHMSI revealed troubling discrepancies including but not limited to the authenticity of the loan documents, the transfer of ownership of the loan, the alleged inclusion of the loan into the securitized trust, the limitations imposed by the securitized trust, and payments made on the loan. During discovery, AHMSI 's attorney produced an exhibit on XXXX/XXXX/XXXX that was to be a true and correct copy of the Note and Deed of Trust that was executed on XXXX/XXXX/XXXX that relates to our Loan and Property. We could not admit that this exhibit was a true and exact copy of the Note and Deed of Trust that was executed on XXXX/XXXX/XXXX because the exhibit included a blank allonge that was not present during our closing. \nThen on XXXX/XXXX/XXXX, their attorney claims to have the original wet ink promissory note. At this time, they have produced an allonge that is now stamped to provide a special endorsement in favor of \" XXXX, as Trustee. '' The allonge is dated the same day as our loan closing. We were able to examine the loan file a short time after. The purported allonge was not affixed to the Promissory Note and was not notarized. The allonge did not mention the securitized trust. It is unclear when the alleged allonge was changed to specially endorse the note in question to the trustee, but it does raise questions as to the veracity of the alleged special endorsement via allonge. There were also copies of XXXX assignments of deeds of trust that were not assigned to the trust. \nWe made a request to Ocwen in XXXX XXXX, to provide the collateral documents that give them the authority to foreclose on our home. Ocwen submitted the Note with the alleged stamped allonge and an assignment of lien that does not reference the Deed of Trust that was signed on XXXX/XXXX/XXXX, which is recorded in Doc # XXXX. Ocwen also claims they are unable to provide the original wet ink documents.","date_sent_to_company":"2016-01-29T10:18:48.000Z","issue":"Loan modification,collection,foreclosure","sub_product":"Other mortgage","zip_code":"78628","tags":null,"has_narrative":true,"complaint_id":"1763627","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Ocwen Financial Corporation","date_received":"2016-01-29T10:18:46.000Z","state":"TX","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["XXXX XXXX retroactively attached our mortgage to a securitized trust that was closed and sold to investors 5 years earlier, the bank violated a Texas law that prohibits fraudulent <em>real</em> <em>estate</em> filings. \nDeclaration from President of XXXX XXXX XXXX from XXXX states that XXXX XXXX XXXX is no longer engaged in the servicing of residential mortgage loans. XXXX XXXX has no servicing rights and does not own any residential <em>real</em> <em>estate</em> mortgages."]},"sort":[24.17206,"1763627"]},{"_index":"complaint-public-v1","_id":"16219330","_score":18.289253,"_source":{"product":"Debt collection","complaint_what_happened":"I act as Attorney-in-Fact for XXXX XXXX XXXX under a valid Limited Power of Attorney. Under Maryland Estates & Trusts 17-113, I am legally required to act with care, competence, diligence, loyalty, and in the best interests of my principal. \nThis correspondence serves as formal notice that I have filed complaints with regulatory authorities, specifically the Securities and Exchange Commission ( SEC ), the Commodity Futures Trading Commission ( CFTC ), and the Maryland Office of the Attorney General, Consumer Protection Division.\n\nThe filings concern systemic fraud by XXXX XXXX XXXX XXXX XXXX ( XXXX ), XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, and XXXX XXXX XXXX XXXX XXXXXXXX directly partnered with XXXX under the XXXX Analytic Products and Services Master Contract, while XXXX  XXXX XXXX XXXX XXXX and XXXX XXXX XXXX directly participated in the formation of XXXX XXXX, XXXX in XXXX. XXXX third purported owner, XXXX XXXX XXXXXXXX XXXX, never lawfully existed due to fatal defects in XXXX corporate lineage, rendering its claimed 33 % ownership void and fatally undermining the legality of XXXX formation. \nSupporting evidence consists entirely of public records, including Georgia Secretary of State filings, FTC findings, federal statutes, and contracts. All exhibits have been cryptographically hashed and anchored to the XXXX XXXX, with verification recorded in the XXXX  XXXX XXXX. The full legal analysis is contained in The Illegality of XXXX and XXXX, which documents the unlawful corporate lineage of XXXX  XXXX XXXX, the void formation of XXXX XXXX XXXXXXXX XXXX, and the illegal contracts underlying both XXXX and XXXX. The record is also preserved on the XXXX XXXX XXXX ( XXXX ) with timestamped XXXX  certificates. Thus, the evidentiary record is permanent, immutable, and legally incapable of alteration or rebuttal by any party, including your institution. \nAny reporting of this debt to a credit bureau necessarily contaminates my Principals consumer credit file and its scoring output. Because both XXXX and XXXX are void ab initio, no lawful scoring system exists to assign predictive value to reported tradelines. Accordingly, any attempt by Debt Collectors to publish an insurance debt into the credit reporting system fabricates consequences based on a score that does not legally exist. \nDebt collection activity is governed by the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq., and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq. Under these statutes, debt collectors may not attempt to collect or report void or fraudulent obligations.\n\nIn addition, under U.C.C. 3-303 ( b ), an instrument issued without value is unenforceable, and under U.C.C. 3-305 ( a ) ( 1 ) ( ii ), enforcement of a negotiable instrument is barred where real defenses such as fraud in factum and illegality apply. Caine & Weiner Company , Inc. can not qualify as holder in due course under U.C.C. 3-302 because they take alleged obligations by assignment, not as bona fide purchasers for value.","date_sent_to_company":"2025-09-27T21:23:36.000Z","issue":"Attempts to collect debt not owed","sub_product":"I do not know","zip_code":"20019","tags":null,"has_narrative":true,"complaint_id":"16219330","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"CAINE & WEINER COMPANY, INC.","date_received":"2025-09-27T20:48:01.000Z","state":"DC","company_public_response":null,"sub_issue":"Debt is not yours"},"highlight":{"complaint_what_happened":["The filings concern systemic fraud by XXXX XXXX XXXX XXXX XXXX ( XXXX ), XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, and XXXX XXXX XXXX XXXX XXXXXXXX directly partnered with XXXX under the XXXX <em>Analytic</em> Products and Services Master Contract, while XXXX  XXXX XXXX XXXX XXXX and XXXX XXXX XXXX directly participated in the formation of XXXX XXXX, XXXX in XXXX."]},"sort":[18.289253,"16219330"]},{"_index":"complaint-public-v1","_id":"2255785","_score":16.540932,"_source":{"product":"Mortgage","complaint_what_happened":"I would like Wells Fargo to provide an explanation of the role that FHA INSURANCE plays from the collection of data, to the approval of said data, and subsequent usage of facts obtained from the data provided within the FHA application. I do know that I pay a MIP ( Monthly Insurance Premium ) as well as other servicing fees. I believe that I have been paying Insurance premiums based on a fraudulent lender FHA Insurance. I believe that I was approved for the HECM scam due largely in part to the fraudulent XXXX Application. The fraudulent application from Con-Man Wells sales rep, XXXX XXXX XXXX XXXXXXXXXXXX based on an invasive Credit Report along with intrusive access to my income tax history.. The very first information that is listed on the FHA XXXX Application clearly state my intentions for my HECM. Obvioulsy, just like every other senior in the world who obtains a Reverse Mortgage, I applied so I could receive ADDITIONAL INCOME. The next choice indicates that I have apllied for my ADDITIONAL INCOME to be disbursed as a LINE OF CREDIT. \nYour underwriter 's job is to assess the borrower 's ability to pay for the requirements of a HECM. He/She would know my anuual salary. He/she obviously would have noticed the ratio of median income as opposed to the amount of disposable income. That underwriter knew I was the perfect Wells Fargo \" muppet '. That what teh underwriter was assessing. Demographics, No Husband or C0-Borrower to help maintain the property taxes and Home insurance, Uneducated, Trustworthy and about to lose the last {$35000.00} I had to my name. And most importantly, my credit history/score was Extremely Poor. A slimy sales rep was right there every step of the way along with help from the Wells Fargo HECM assembly line that walks the senior down each path of the scam. never deviating from the plan by allowing or encouraging the senior to follow the laws of counseling. \n\nEXREMELY POOR CREDIT, NO SAVINGS, INSURMOUNTABLE DEBT, and recovering FROM XXXX = PAINTING THE PERFECT PICTURE to Wells Fargo as a person who WILL DEFAULT on her taxes, home insurance, etc. A home that ( we ) Wells Fargo will be owning in a matter of a few years. All for a disbursement of \" allegedly {$180000.00}. '' I 'm sure Wells Fargo 's market analytics knew that real estate would be booming again from 2011 and on. So Wells Fargo pretty much knew that \" their appraiser 's '' price of {$300000.00} ( Which will also play a part in this scheme ) would only rise over the next few years. \n\nNormally, with a traditonal HECM, the lender wil invest roughly 58 % into liquidty conversion for the senior and pay it out in a Lump Sum or Line of Credit. The remaining 42 % of equity will be disbursed monthly ( Totaling Roughly $ XXXX-Just like a mortgage payment ) for MIP and additional service charges while accruing interest. Within no time, the senior spends the money. ( I wanted to be responsible and let WF disburse my XXXX for taxes. It 's just a matter of time before the remaining 42 % is sucked up through what amounts to monthly mortgage payments. Another classic Reverse Mortgage advertisement pitch \" You 'll never have to pay a mortgage again '' Wells Fargo used the FHA to insure the loan so Once that elderly person dies, the house can not be sold because it may be under water in excess of {$100000.00}. In comes Wells Fargo to cash in on their risk free investment, take possession of the home and recoup any and all losses associated with depreciation or monthly MIP and service fees. All because the FHA Insured the HECM. We 've all seen the ads \" A Government Insured Reverse Mortgage ''.","date_sent_to_company":"2016-12-19T15:38:57.000Z","issue":"Application, originator, mortgage broker","sub_product":"Reverse mortgage","zip_code":"02155","tags":"Older American","has_narrative":true,"complaint_id":"2255785","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"WELLS FARGO & COMPANY","date_received":"2016-12-19T15:38:56.000Z","state":"MA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["All for a disbursement of \" allegedly {$180000.00}. '' I 'm sure Wells Fargo 's market <em>analytics</em> knew that <em>real</em> <em>estate</em> would be booming again from 2011 and on. So Wells Fargo pretty much knew that \" their appraiser 's '' price of {$300000.00} ( Which will also play a part in this scheme ) would only rise over the next few years. \n\nNormally, with a traditonal HECM, the lender wil invest roughly 58 % into liquidty conversion for the senior and pay it out in a Lump Sum or Line of Credit."]},"sort":[16.540932,"2255785"]},{"_index":"complaint-public-v1","_id":"1987168","_score":16.436749,"_source":{"product":"Mortgage","complaint_what_happened":"Nationstar ' response, XXXX XXXX, XXXX provides no explanation or investigation into facts or requests presented them and confirms Nationstar ' ( NSTR ) incorrect conclusion alleging they performed an NPV test under DOJ when clearly decline is based on a XXXX review, based on the provided chart in the XXXX/XXXX/XXXX. Nationstar provided an email communication between XXXX XXXX and XXXX XXXX of NSTR, with no underlying documents other than the letter itself. ( Attached ) The complaint simply requests VERIFICATION that the XXXX/XXXX/XXXX decline letter for DOJ program was is in fact correctly underwritten for the DOJ program and for NSTR to provide conclusive confirmation that this was a DOJ decision and not a XXXX decision that disallows loans with balances greater than XXXX. NSTR ' continuing references to prior letters, have not addressed this specific complaint are non-responsive and assert that the file was declined, by restating the very letter that is in question, thereby engaging in an effectively circular argument. We are requesting validation under DOJ of XXXX performed by NSTR : This complaint is based on XXXX ' letter of XXXX/XXXX/XXXX and addressed to XXXX CA XXXX. wherein NSTR claimed that my file was evaluated under the DOJ Program. ( DOJ/XXXX ) & resulted in a negative NPV. This statement is materially false and NSTR ' incorrect justification for decline. ( Attached ) A letter of complaint has been sent to XXXX. of CA XXXX XXXX by XXXX XXXX, XXXX/XXXX/XXXX which has not been responded to by XXXX in any fashion. ( Attached ) NSTR confirmed that \" NSTR only facilitated documentation creation for DOJ program and an actual calculation of data was run by prior servicer, the previously enclosed DOJ letter of declination, XXXX/XXXX/XXXX, provides the inputs used in the review. \" This further confirms NSTR ' absent investigation into facts, and apparent negligent reliance on a XXXX review in XXXX XXXX, performed by prior servicer, and only facilitated by NSTR. No comprehensive or analytical research was conducted as required under the XXXX Model XXXX, Supplemental Directive and DOJ guidelines as required under Successor Servicer obligations under Stipulated Judgment when a homeowner provides an Appeal on issues of NPV and erroneous inputs. This is clearly a XXXX underwriting chart that includes only XXXX correction which was the Appraised Value of {$680000.00}, however the chart makes no offsetting provisions for current outstanding loan balance as {$860000.00} ( field # 16 ) thereby rendering this particular run as ineligible since it exceeds the XXXX program limit of {$720000.00}. NSTR is using disqualifying and erroneous inputs without understanding their results or the proper methodology for proper NPV evaluations or the difference between DOJ and XXXX NPV modeling. This declination can not be based on the input fields pertaining to mark to market and principle reduction which are shown on the chart and labeled as \" null '' and considered valid. NSTR created a fail for an altogether different program and uses this as justification for the decline. NSTR even fails to understand based on the income in the file from XXXX that under the 42 % debt-to-income guideline, it is impossible to fail the DOJ program which was designed as \" retest until pass program '' as outlined in DOJ Stipulated Judgement, Exhibit I, Page XXXX that addresses XXXX XXXX In all cases, the adjustments must be limited so as to provide a positive NPV, with the calculation based on Treasury NPV model outcome. Therefore, we continue to request under \" Qualified Written Request '' the Real Estate Settlement Procedures Act, codified as Section XXXX ( XXXX ) of Title XXXX of the United States Code. ( XXXX XXXX XXXX XXXX XXXX XXXX. I am requesting : 1 ) All runs-of-record for NPV modeling conducted by both Nationstar and XXXX XXXX XXXX, 2 ) Run Dates 3 ) Code version of runs 4 ) Any error codes results.","date_sent_to_company":"2016-06-28T12:22:18.000Z","issue":"Loan modification,collection,foreclosure","sub_product":"Conventional adjustable mortgage (ARM)","zip_code":"91001","tags":null,"has_narrative":true,"complaint_id":"1987168","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"NATIONSTAR MORTGAGE LLC","date_received":"2016-06-27T21:49:49.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Therefore, we continue to request under \" Qualified Written Request '' the <em>Real</em> <em>Estate</em> Settlement Procedures Act, codified as Section XXXX ( XXXX ) of Title XXXX of the United States Code. ( XXXX XXXX XXXX XXXX XXXX XXXX. I am requesting : 1 ) All runs-of-record for NPV modeling conducted by both Nationstar and XXXX XXXX XXXX, 2 ) Run Dates 3 ) Code version of runs 4 ) Any error codes results."]},"sort":[16.436749,"1987168"]},{"_index":"complaint-public-v1","_id":"1929674","_score":15.846407,"_source":{"product":"Mortgage","complaint_what_happened":"This complaint is based on Nationstar 's ( NSTR ) letter of XXXX XXXX, XXXX, XXXX to the Office of California Attorney General. NSTR claims that my file was evaluated under the DOJ Program ( DOJ/HMS ), and resulted in a negative NPV. This is a false statement and is their justification for decline. Therefore we are requesting validation under DOJ of the NPV performed by NSTR. \nNSTR response continues to provide no viable explanations or investigation into facts which have been presented to them. It also confirms NSTR incorrect conclusion, alleging they performed an NPV test under DOJ when clearly the decline is based on a MHA/HAMP review. In this reply NSTR also confirms that, \" Nationstar only facilitated documentation creation for the DOJ program and an actual calculation of the data was run by the prior servicer, the previously enclosed DOJ letter of declination, dated XXXX XXXX, XXXX, provides the inputs used in the review. \" This further confirms NSTR lack of any investigation into facts, their negligent reliance on a XXXX review from XXXX XXXX ( performed by prior servicer ) which was only facilitated by NSTR. No comprehensive or analytical research has been conducted as required under the MHA Model v5.02, Supplemental Directive and DOJ guidelines as required under their Successor Servicer obligations under the Stipulated Judgment when homeowners submit Appeals on issues of NPV and erroneous inputs. \nThis is clearly a HAMP underwriting chart that includes only XXXX correction, the Appraised Value of {$680000.00}. The chart makes no offsetting provisions for current outstanding loan balance as {$860000.00} ( field # XXXX ) thereby rendering this particular run ineligible since it exceeds the HAMP program limit of {$720000.00}. NSTR is using disqualifying & erroneous inputs without acknowledging these incorrect results. It appears they do not understand the proper methodology for correctly implementing NPV evaluations, as well as, seemingly not knowing the difference between DOJ, MHA/HAMP & NPV modeling. This declination can not be based on input fields pertaining to mark to market and principle reduction, shown on the chart and labeled as \" null ''. NSTR created a fail for an altogether different program & uses this as justification for the decline. NSTR evens fails to acknowledge that based on the income in the file from XXXX that under the XXXX % debt-to-income guideline, it is impossible to fail the DOJ program which was designed as \" retest until pass program ''. \nExcerpt from the DOJ Stipulated Judgement, Paragraph vi that addresses NPV. Exhibit XXXX, Page XXXX XXXX A Settlement Loan Modification is a modification made according to the following priority : vi ) In all instances, the adjustments must be limited so as to provide a positive NPV, with the calculation based on the Treasury NPV model outcome. If, following the priority above, the modification produces a negative NPV, the steps in the priority will be adjusted ( in reverse order ) to produce successive XXXX % increases in DTI ( but in no event higher than XXXX % ), and the NPV model will be re-run after each 1 % payment adjustment. Modifications will be offered at the lowest DTI solution that is NPV-positive .... \nNSTR XXXX XXXX, XXXX letter draws conclusion on a XXXX % DTI claiming negative NPV even at the limits which is not mathematically possible based on income and a correct Mark-to-market loan value based on Appraised value of {$680000.00} as mention by NSTR themselves. \nTherefore, in addition please consider this a \" Qualified Written Request '' under the Real Estate Settlement Procedures Act, codified as Section 2605 ( e ) of Title 12 of the United States Code. ( 12 USC 2605 ( e ) ) .Once again I am requesting : 1 ) All runs-of-record for the NPV modeling conducted both by NSTR and XXXX , 2 ) Run Dates 3 ) Code version of runs 4 ) Any error code results.","date_sent_to_company":"2016-05-18T12:36:24.000Z","issue":"Loan modification,collection,foreclosure","sub_product":"Conventional adjustable mortgage (ARM)","zip_code":"91001","tags":null,"has_narrative":true,"complaint_id":"1929674","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"NATIONSTAR MORTGAGE LLC","date_received":"2016-05-17T22:07:01.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Therefore, in addition please consider this a \" Qualified Written Request '' under the <em>Real</em> <em>Estate</em> Settlement Procedures Act, codified as Section 2605 ( e ) of Title 12 of the United States Code. ( 12 USC 2605 ( e ) ) .Once again I am requesting : 1 ) All runs-of-record for the NPV modeling conducted both by NSTR and XXXX , 2 ) Run Dates 3 ) Code version of runs 4 ) Any error code results."]},"sort":[15.846407,"1929674"]},{"_index":"complaint-public-v1","_id":"2736046","_score":14.371948,"_source":{"product":"Mortgage","complaint_what_happened":"XX/XX/XXXX                                                          XXXX XXXX XXXX XXXX, XXXX\n\n\nXXXX XXXX, General Counsel\nGeneral Law & Ethics\nXXXX  XXXX, Deputy General Counsel\nLitigation & Oversight\nXXXX XXXX, Deputy General Counsel\n\nConsumer Financial Protection Bureau\nXXXX XXXX XXXX XXXX XXXX, XXXX. XXXX\n\nDear Friends : \n\nPlease join me in litigation against Select Portfolio Services and XXXX County Tax Assessor for Property Tax Fraud  Home Affordable Modification Program. I would like to recover over $XXXX in excessive property tax non-market assessments payments and damages from XX/XX/XXXX to XX/XX/XXXX. I understand that a class action litigation may be more applicable.\n\nTIMELINE EVENTS\nSelect Portfolio Services modified my mortgage in XX/XX/XXXX. After the Modification I questioned why the annual property taxes exceeded the monthly principal and interest.\n\nProperty Tax Payments > Principal and interest = an Uneconomic  Relationships \n\nThis uneconomic inequality destroys home ownership and  downgrades homeowners to the economic status of  renters of the mortgage holder and local government property tax authority.\n\nI challenged Select Portfolio Services to contact XXXX County on what appeared to be a non-market collaboration to defraud homeowners with a non market property valuation.\nThe XXXX County valuation assessment was publically stated to be based on Comparable Values. This did not include internal and other close examples of the homes. It was apparent a search for the highest priced home in close proximity. In the New Home markets there are many micro and/or unique factors that challenges comparable assessments; for example,  Golf Course , Other Recreation  Access, Schools, historical and cultural preservation, and the XXXX XXXX effect.\n\nMOTIVES\nSelect Portfolio Services motives to conspire with XXXX Counties local Fraud:\n\tServicing fees earned of a Inflated Non Market Mortgage Principal Valuation\n\tInterest earned on the Property Tax Escrow Deposits\n\n\n\n\n\n\n\n\n\nFAILURE IN LOCAL GOVERNMENT GOVERNANCE AND INTEGRIDTY\nXXXX County actually increased my property assessment valuation during the Great Recession of XX/XX/XXXX from $XXXX to $XXXX. This was during a general market decline of 30%. XXXX County Tax Assessments have been immune to market factors. The XXXX  County Tax Appeal Process is invalid and may be illegal\n\nI appealed this tax assessment in XX/XX/XXXX. A small reduction was made from the $XXXX.\nwhich remained a fraudulently high non market tax assessment . The tax assessment increased  and returned to $XXXX in XX/XX/XXXX. The XXXX County Tax Appeal process\nlacks integrity and analytical validity. XXXX  actually increased property spending in XX/XX/XXXX and XX/XX/XXXX during the peak of the Great Recession.\n\nRecently the Georgia Governor has demanded that XXXX County cease and desist billing property tax payers XX/XX/XXXX taxes because XXXX County does not a valid property tax methods.\n\nThe failure of XXXX County and numerous other local government property tax authorities to adjust Post Great Recession property valuation assessments to the fair market declines is the key factor in home modification failures. When Principal and Interest was reduced  non market valuations property taxes were not.\n\nI am requesting that a private second accounting and appraisal firm be retained to review that current and historical. XXXX County Tax Assessor valuation Methodology and the outsourcing of this function.\n\nXXXX County property taxes valuation methods and assessments are not sustainable. \n\nI estimate an over collections of 40% since the Great Recession due to the failure to adjust property taxes to the decline of Great Recession market prices.\n\nRE: XX/XX/XXXX Georgia Code\nTitle 48 - REVENUE AND TAXATION\nChapter 5 - AD VALOREM TAXATION OF PROPERTY\nArticle 7 - MISCELLANEOUS LOCAL ADMINISTRATIVE PROVISIONS\n 48-5-380 - Refunds of taxes and license fees by counties and municipalities; time and manner of filing claims and actions for refund; authority to approve or disapprove claims\n\nCOMPENSATION OF TAX PAYER PROPERTY\nAfter I sold my home on XX/XX/XXXX for XXXX. XXXX County assessment my home on XX/XX/XXXX  $XXXX XXXX.  This was after an official appeal and the realized market value of a sale.\n\n\tThis evidences my a history of Non Market property tax assessments.\n\tThis evidences a history of an invalid property tax appeals process. \n\tIt evidences that the tax appeal process is used to discourage voters to challenge a hostile process.\nIn order to sale a property with Non Market Property Taxes the home owners must reduce the price of the home to generate a financing that is economic.  This property value is required for\nPRINCIPAL AND INTEREST + PROPERTY TAXES TO REFLECT THE MARKET VALUATION\n\nXXXX County and SPS must compensate me and home owners for this compensation.\nHistorically SPS has  argued that they were only following XXXX Countys information while modifying Principal Payments to reflect a lower market assessment.\n\n\nXXXX County Georgia and many local governments that have become dependent on the market inefficiencies of Non Market Tax Assessments are at great risk that lower Federal tax deductions for local property taxes and interest deductions will create a Post Great Recession Financial Crisis.\n\n\n\n\nI have lost my home. I am a senior citizen. Please help.\n\n\nSincerely,\n\n\n\nXXXX XXXX, XXXX\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\nBACKGROUND\nOn XX/XX/XXXX I received a revised tax Corrected Annual Notice Of Assessment From The XXXX County Tax Assessors office. Please help. I have lost my home due to 10 years and cumulative tax over payments of $XXXX regardless of appeals. I was required to reduce my home price from $XXXX to $XXXX in order to sale the home. The annual tax payments exceed the market principal and interest financing cash flow due to XXXX County Tax Assessors not adjusting the property valuation to the current and fair market prices.\n\nThis Corrected Assessment was received 24 days after the XX/XX/XXXX sales of the \n\nACCOUNT: XXXX\nPROPERTY ID NUMBER:                   XXXX XXXX\n100% APPRAISED VALUE:             $ XXXX\n  40% ASSESSED VALUE                 $    XXXX\n\nHome Sale XX/XX/XXXX                    $    XXXX\n\nI sold Parcel Number XXXX XXXX XXXX XXXX ON XX/XX/XXXX.\n\nORIGINAL PURCHASE                                                       $XXXX XXXX COUNTY TAX VALUATION XXXX 2017     XXXX  \nSALE CLOSING PRICE                              XX/XX/XXXX        XXXX\n\nTAX YEARS XX/XX/XXXX TO XX/XX/XXXX REFUND REQUEST                    XXXX                                                                   INTEREST 5%              XXXX                                                                                                       $XXXX\nLoses due to confiscation of property  due to non market taxes reduced home value\nFor sale principal loss.                                                                  $XXXX                                                                                              \n\nREPLACEMENT VALUATION ADJUSTMENTS\nThere are numerous or alternatives to a comparable valuation:\n= Construction. +  Land \nLand value convention is 50% of valuation and seldom depreciates.\n\n\tHistory will reveal the land size was severely compromised for XXXX County Infrastructure development and an easement for the  XXXX XXXX Acquidauct.\n\n\tThe home actually shakes twice a month (R1 factor)\n\n\tXXXX XXXX is the smallest land lot in XXXX XXXX XXXX XXXX and sits on the busiest thoroughfares in XXXX XXXX .\n\n\tThe home is noisy and  the lot is too small for a family.\n\n\n\n\nDEMAND VALUATION ADJUSTMENT\n\tDue to a rock embedded  under the home the basement is only 25% of the area structure.\n\tThere is no walk out.\n\tThe interior of the home is awkward: rooms remain unfinished  and the second floor bedrooms do not have a private  entry. A VERY INATTRACTIVE FLOOR PLAN\n\nSCRACITY\nScarcity - The finite supply of competing properties continue to grow.\n1.\tThere are four new homes breaking ground on the XXXX XXXX and over 20 new homes for sale in the 4 Block circumference. \n\nTRANSFERABILTY\n-. XXXX XXXX XXXX has been listed each year since XX/XX/XXXX by \n\tXXXX XXXX (the seller)\n\tXXXX XXXX  XXXX\n\tFor Sale By Owner\n\nThe home has not been  has been uneconomic since the day of purchase.\nThe Annual Property Tax Payments exceed the Market Annual Principal and Interest  Financial. The only way to correct this inequality was to decrease the sell price  in order to correct this uneconomic condition\n\nINCOME\n3 BEDROOMS RENTALS LEASE FOR XXXX<  P&I..\n\nCOMPARABLES\nParcel\nNumber\nLocation\nAddress\n\nXXXX County  Assessments XXXX XXXX XXXX XXXX XXXX XXXX \t\n$XXXX\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX XXXX XXXX XXXX XXXX XXXX XXXX\t$XXXX\n\n\n\nSince XX/XX/XXXX buyers have rejected purchasing my home due to  the high taxes.\nI am requesting  $XXXX for principal lost due to the market impact. Excess taxes. \n\n\nBACKGROUND:\nHistorically, the property tax assessments appeals have not been favorable results.\nin the Ad Valorem Tax Valuations for Parcel Number XXXX Property Address: XXXX XXXX XXXX, XXXX, Georgia, XXXX are due to errors in identifying comparable real estate and the examination of alternatives methods. XXXX XXXX, and not the new municipality baring the name is the oldest golf course community in America. Much of the community surrounds the XXXX XXXX XXXX XXXX. The XXXX XXXX XXXX around XXXX XXXX. The land value and/or the demolition of these properties exceed $XXXX. This makes a replacement method valuation often exceeding $XXXX.   The XXXX XXXX XXXX  lot side was reduced below  of an acre and decade prior to the XX/XX/XXXX purchase. This small lot size has the reduce the land value of the valuation formerly by 25%. This property size reduction executed Imminent Domain for the XXXX XXXX XXXX. This Domain Infringement has had an unfavorable impact on property value on properties that border XXXX  XXXX. Directly across the street from my home has a open pit that floods with three feet of water after each rainfall. Our homes rattle around XXXX over 10 times a year from an apparent water release. Compensation for this easement was in adequate\n\nXXXX XXXX XXXX borders a very busy street, XXXX XXXX is an alternative thorough fare to XXXX XXXX, XXXX XXXX has become a cut through street with morning traffic congestion and is located less than 100 meters from the City of XXXX limit. These factors traditionally require a 10% reduction adjustment. \n\n\n\nTHE CASE STUDY: Ad Valorem Tax Valuations for Parcel Number XXXX\nProperty Address: XXXX XXXX XXXX, XXXX, Georgia, XXXX XXXX when the XXXX XXXX was purchased the XXXX County and national home price market was at a peak.\n\nXXXX XXXX XXXX is listed on the real estate market today for $XXXX.  The home was purchased at the peak of the market price boom, XX/XX/XXXXfor $XXXX. The market has not recover from the Great Recession collapse. \n\nHe most recent sales of next-door comparable prices were $XXXX and $XXXX.\nXXXX Countys XX/XX/XXXX tax valuation of $XXXX has historically and today been an impediment to the property sale.\n\nHistorically, tax correction has been requested and taxes reduced only to be increased the following year with no market input.\n\n\n\n\n\n.\n\nA tax appeal was submitted after the XX/XX/XXXX -XX/XX/XXXXGreat Recession after the Great Recession resulted in a Valuation above the peaked market price.\n\nToday XX/XX/XXXX the highest market offer for the property price has been $XXXX.\n\nThe historical errors in the Ad Valorem Tax Valuations for Parcel Number XXXX  Property Address: XXXX XXXX XXXX, XXXX, Georgia, XXXX are due to errors in identifying comparable real estate and the examination of alternatives methods.","date_sent_to_company":"2017-12-06T14:21:28.000Z","issue":"Trouble during payment process","sub_product":"Conventional home mortgage","zip_code":"30338","tags":"Older American","has_narrative":true,"complaint_id":"2736046","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"SELECT PORTFOLIO SERVICING, INC.","date_received":"2017-11-21T22:52:30.000Z","state":"GA","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":null},"highlight":{"complaint_what_happened":["The historical errors in the Ad Valorem Tax Valuations for Parcel Number XXXX  Property Address: XXXX XXXX XXXX, XXXX, Georgia, XXXX are due to errors in identifying comparable <em>real</em> <em>estate</em> and the examination of alternatives methods."]},"sort":[14.371948,"2736046"]},{"_index":"complaint-public-v1","_id":"21869055","_score":12.367711,"_source":{"product":"Mortgage","complaint_what_happened":"In XX/XX/XXXX the mortgage servicer sent a written letter confirming that the XXXX XXXX XXXX XXXX XXXX valued the property at {$640000.00} and that the value had not declined from the original value of {$550000.00}. With an outstanding principal balance of {$470000.00}, this produced a loan-to-value ratio of approximately XXXX percent below the XXXX percent threshold required for borrower-requested PMI cancellation under investor guidelines for XXXX loan between XXXX and XXXX years old. The property qualified for PMI removal based on the servicer 's own valuation system. \nRather than proceeding with cancellation, the servicer ordered a XXXX XXXX XXXX through XXXX XXXX XXXX XXXX XXXX, assigned to a licensed real estate broker, dated XX/XX/XXXX, File Number XXXX. The XXXX returned a value of {$620000.00}. This figure is {$24000.00} below the servicer 's own Fannie Mae XXXX result produced XXXX month earlier on the same property. It is also {$16000.00} below the {$630000.00} threshold required for PMI cancellation at XXXX percent XXXX. The PMI cancellation request was denied by written letter dated XX/XX/XXXX. \nThe {$24000.00} gap between the servicer 's own automated valuation and the BPO produced by its chosen vendor is the central process failure in this complaint. Nothing material changed between XX/XX/XXXX and XX/XX/XXXX. No market event occurred. No damage to the property occurred. The only variable that changed was the source of the valuation. The servicer 's own system said the property was worth {$640000.00}. The vendor the servicer selected said {$620000.00}. The servicer accepted the lower figure without question and without adequate quality control review despite the fact that accepting it meant denying a borrower whose qualification had already been confirmed by the servicer 's own system. \nThe process failure is further documented by the following deficiencies in the XXXX itself, all visible on the face of the report : XXXX All XXXX comparable properties selected are XXXX to XXXX XXXX XXXX than the XXXX new construction subject property. No explanatory commentary was provided for any age difference in any comment field. \nXXXX XXXX comparable is located in XXXX, NC XXXX a different city, zip code, XXXX XXXX from the subject property in XXXX, NC XXXX with no market justification provided. \nXXXX The primary comparable XXXX XXXX tax records as the primary data source despite the preparer holding an active MLS license with access to current market data. \nXXXX All XXXX comment fields contain only the words OVERFLOW SEE ADDITIONAL FIELD TEXT ADDENDA. The addenda contain XXXX marketing descriptions, not analytical commentary. \nXXXX XXXX active listing comparables within the same XXXX report are priced at {$620000.00} and {$650000.00} both older than the subject yet the XXXX concludes the newer XXXX subject property is worth {$620000.00}. This internal contradiction exists within the same document. \nXXXX The subject received a lower price per square foot than comparables built XXXX and 13 years earlier inconsistent with standard market behavior where newer construction commands a premium. \nXXXX The XXXX 's own neighborhood data records XXXX comparable properties available in the subject 's price range. Despite this, XXXX new construction comparables were used. \nXXXX The preparer recorded that no prior XXXX data existed for the subject within the last 12 months meaning no independent market anchor existed and comparable selection was the entire basis of the valuation. \nXXXX XXXX comparable lot ranges from XXXX percent to XXXX percent larger than the subject 's lot of XXXX square feet, with XXXX downward adjustments applied to any comparable. \nXXXX The XXXX states condition was assessed by exterior inspection. The same document 's XXXX XXXX states the XXXX XXXX was XXXX. These statements directly contradict each other within the same document. \nA formal complaint was submitted to the servicer. In a written response dated XX/XX/XXXX, Case Number XXXX, the servicer 's XXXX XXXX XXXX XXXX confirmed in writing that XXXX XXXX XXXXdentified a concern with the XXXX vendor and contacted the vendor directly. The response further stated in the servicer 's own words that the adjustment calculations and the out-of-market comparable used in the BPO were not addressed by XXXX XXXX before the XXXX XXXX closed. The servicer accepted the vendor 's self-confirmation that the report was correct as sufficient quality control and stated no error occurred. \nFollowing the submission of complaints the servicer ordered a new independent property valuation. That valuation returned a value of {$640000.00} identical to the servicer 's owXXXX XXXX XXXX XXXX XXXX XXXX XXXXXX/XX/XXXX. XXXX entirely independent valuations conducted XXXX years apart both confirm the property was worth {$640000.00}. The XXXX at {$620000.00} is confirmed to be {$24000.00} below the correct value a material error that was used to deny PMI cancellation for 22 months after the XXXX was completed, and for approximately 35 months from the date of the original cancellation request in XX/XX/XXXX. \nPMI was cancelled effective XX/XX/XXXX. PMI was charged at {$87.00} per month from XX/XX/XXXX through XX/XX/XXXX approximately 35 months totaling {$3000.00} in premiums collected during the period the property value supported cancellation as confirmed by the servicer 's own XXXX. Under XXXX XXXX. XXXX ( f ), the servicer is legally required to return all unearned PMI premiums not later than 45 days after cancellation by XX/XX/XXXX. The servicer has refused to issue any refund. Under XXXX XXXX. XXXX, the servicer is additionally liable for actual damages sustained from the date the violation commenced, statutory damages not to exceed {$2000.00}, and reasonable attorney fees as determined by the court.","date_sent_to_company":"2026-05-04T22:15:48.000Z","issue":"Trouble during payment process","sub_product":"Conventional home mortgage","zip_code":"28027","tags":null,"has_narrative":true,"complaint_id":"21869055","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"WELLS FARGO & COMPANY","date_received":"2026-05-04T21:31:47.000Z","state":"NC","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Private mortgage insurance (PMI)"},"highlight":{"complaint_what_happened":["Rather than proceeding with cancellation, the servicer ordered a XXXX XXXX XXXX through XXXX XXXX XXXX XXXX XXXX, assigned to a licensed <em>real</em> <em>estate</em> broker, dated XX/XX/XXXX, File Number XXXX. The XXXX returned a value of {$620000.00}. This figure is {$24000.00} below the servicer 's own Fannie Mae XXXX result produced XXXX month earlier on the same property. It is also {$16000.00} below the {$630000.00} threshold required for PMI cancellation at XXXX percent XXXX."]},"sort":[12.367711,"21869055"]},{"_index":"complaint-public-v1","_id":"13817475","_score":12.357889,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"# LexisNexis Consumer Disclosure Request Letter * * XXXX XXXX * * XXXX XXXX XXXX XXXX, LA XXXX XXXX XXXX * * Date : * * XX/XX/XXXX * * LexisNexis Consumer Center * * XXXX XXXX XXXX XXXX, GA XXXX * * RE : REQUEST FOR COMPREHENSIVE CONSUMER DISCLOSURE REPORT * * * * Consumer Name : * * XXXX XXXX XXXX XXXX Date of Birth : * * XX/XX/XXXX * * Social Security Number : * * XXXXXXXX XXXX XXXX  * * Dear LexisNexis Consumer Center : * * Pursuant to my rights under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681g, I am formally requesting a complete and comprehensive disclosure of all consumer information contained in your files pertaining to me. This request encompasses all databases, files, and records maintained by LexisNexis Risk Solutions, including but not limited to : # # REQUESTED DISCLOSURE CATEGORIES : * * 1. COMPREHENSIVE CONSUMER REPORTS * * - Complete consumer report files- All versions and iterations of reports generated - Historical reporting data and archived information - Third-party furnished information and sources * * 2. IDENTITY VERIFICATION DATA * * - Personal identifying information databases- Address history and verification records- Phone number associations and verification data - Email address linkages and verification records * * 3. PUBLIC RECORDS INFORMATION * * - Court records and litigation history - Property ownership and real estate records- Professional licensing information - Bankruptcy and financial judgment records- Criminal background check data - XXXX offender XXXX information * * 4. COMMERCIAL DATABASE RECORDS * * - Marketing lists and consumer segmentation data - Lifestyle and demographic profiling information - Purchasing behavior and preference data- Social media and online presence data * * 5. RISK ASSESSMENT PRODUCTS * * - Identity authentication scores and algorithms - Fraud detection and prevention data - Risk scoring models and calculations - Predictive analytics and behavioral assessments * * 6. THIRD-PARTY DATA SOURCES * * - Information obtained from data brokers - Social networking site information - Publicly available information compilations- Government database extractions # # LEGAL BASIS AND CONSUMER RIGHTS : This request is made pursuant to : - Fair Credit Reporting Act ( FCRA ) 609, 15 U.S.C. 1681g - FCRA 610, 15 U.S.C. 1681h ( reinvestigation rights ) - FCRA 611, 15 U.S.C. 1681i ( dispute procedures ) # # REQUIRED DISCLOSURES : Please provide the following as required by federal law : 1. * * Complete File Disclosure : * * All information in your files on the consumer at the time of the request 2. * * Source Identification : * * The sources of all information contained in your files 3. * * Recipients List : * * All persons who have received consumer reports within the prescribed time periods 4. * * Investigative Report Disclosure : * * If any investigative consumer reports exist, provide complete disclosure as required under FCRA 609 ( a ) ( 1 ) # # IDENTITY VERIFICATION : To verify my identity for this request, I am providing : - Full legal name : XXXX XXXX - Current address : XXXX XXXX XXXX, XXXX, LA XXXX - Date of birth : XX/XX/XXXXXXXX  - Partial Social Security Number : XXXX - Contact phone number : XXXX - Email address : XXXX * * Note : * * I am prepared to provide additional identity verification documentation if required by your standard procedures. \n\n# # REQUEST FOR NO-COST DISCLOSURE : This is my first request for disclosure within the 12-month period. Pursuant to FCRA 609 ( a ) ( 1 ) ( A ), I am entitled to receive this information at no charge.\n\n# # DELIVERY INSTRUCTIONS : Please send the complete disclosure package to my address listed above. I prefer to receive the information via secure mail to ensure privacy and confidentiality. If electronic delivery is available and secure, please contact me at the email address provided. \n\n# # COMPLIANCE TIMEFRAME : Please be advised that under FCRA 609 ( a ) ( 1 ), you have a reasonable period of time, not to exceed 30 days, to comply with this request. I expect to receive the complete disclosure within this timeframe.\n\n# # RECORD RETENTION NOTICE : Please maintain records of this disclosure request and your response for compliance purposes as required under federal regulations.\n\nI appreciate your prompt attention to this matter and look forward to receiving the comprehensive disclosure within the required timeframe. Should you have any questions regarding this request or require additional identity verification, please contact me at the phone number or email address provided above.\n\nThank you for your cooperation in ensuring compliance with federal consumer protection laws. \n\n* * Sincerely, * * * * XXXX XXXX * * * * Consumer * *","date_sent_to_company":"2025-05-31T00:20:13.000Z","issue":"Unable to get your credit report or credit score","sub_product":"Credit reporting","zip_code":"713XX","tags":null,"has_narrative":true,"complaint_id":"13817475","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"LEXISNEXIS","date_received":"2025-05-30T23:56:49.000Z","state":"LA","company_public_response":null,"sub_issue":"Problem getting your free annual credit report"},"highlight":{"complaint_what_happened":["PUBLIC RECORDS INFORMATION * * - Court records and litigation history - Property ownership and <em>real</em> <em>estate</em> records- Professional licensing information - Bankruptcy and financial judgment records- Criminal background check data - XXXX offender XXXX information * * 4. COMMERCIAL DATABASE RECORDS * * - Marketing lists and consumer segmentation data - Lifestyle and demographic profiling information - Purchasing behavior and preference data- Social media and online presence data * * 5."]},"sort":[12.357889,"13817475"]},{"_index":"complaint-public-v1","_id":"3760674","_score":8.351501,"_source":{"product":"Mortgage","complaint_what_happened":"Complaint 3 The petitioner request the CFPB Management Supervision for this complaint in connection with the two previous complaints, case id ( s ) XXXX & XXXX XXXX. \n\nThe petitioner argues, the respondent has not honored the question relating to the part of the debt in arears of {$1500.00}. The respondent can not explain in clear and plain language where four months of arrears are situated in the 48-month tenure of this loan servicer. At best, the petitioner argues, he was 1 to 2 months behind, but before the 2nd month came up a payment was made. The XX/XX/XXXX, payment was made, but the servicer halted the XX/XX/XXXX, payment till the TPP schedule the XX/XX/XXXX, plan. Time is critical when XXXX has imposed time-limit on a forbearance agreement, where the respondent seems to be buying the time. \n\nThis petitioner comes before the CFPB in complaint 3, that respondent Shellpoint Servicing, Escalation Dept, denies the petitioner the soundness granted by the policymakers of RESPA, REGULATION X, AND 12 CFR 1024, ETC. The petitioner believes, he has the right to pursue this claim under the CFPB, and should be allowed all privileges due according to the public regulations. The petitioner believes, he was abused by unfair business practices, when the loan servicers completed the loan modification process including the TPP. The petitioner believes, the loan servicer was obligated to disclose any information pertinent to this loan modification, in-progress, including an upcoming transfer. This petitioner believes he was held in the dark, by the way of deceit when all of a sudden, the loan transferred injuring the petitioner in the amount {$2000.00}, which is now the subject of XXXX XXXX XXXX, the new loan servicer. This injury subjects the petitioner to unwanted forbearance which warps the petitioners budget wrongly. Forbearance is a deduction in status and not same as a loan modification agreement, which was established by the successful completion of the TPP in XX/XX/XXXX. The institution of papers signing is the responsibility of the loan servicer not the successor. Like all documents which are ordinarily forwarded to the subject address and fees charged, this one too, should had undergone the same procedure. So, there is really no underlining excuse such as given to XXXX, that the petitioner failed to sign the assumption agreement. This is unacceptable. \n\nThis petitioner believes as a result of the aforementioned act committed by the respondent, the respondent violated negligence by not giving the proper duty of care to this transfer. Nor does the respondent acknowledge, this gallant duty of care, in the two previous complaints. \n\nCourts are just beginning to consider the general rights of homeowners to be evaluated for a loan modification. Indeed, the CFPBs regulations requiring loss mitigation procedures and enforceable by private right of action only took effect in XX/XX/XXXX. XXXX. Mortgage Servicing Rules Under the Real Estate Settlement Procedures Act ( Regulation X ), XXXX Fed. XXXX. XXXX, XXXX ( XXXX XXXX, XXXX )  ( codified at XXXX C.F.R. pt. XXXX ). XXXX, There has scarcely been time to reach court decisions on those rules. Extending the evaluation right to successor homeowners is a topic even fewer courts have addressed. XXXX of the first cases to consider the rights of successor homeowners to evaluation for a loan modification was XXXX v. XXXX XXXX XXXX XXXX, XXXX. XXXX. No. XXXX, XXXX WL XXXX, at XXXX ( E.D. XXXX. XXXX XXXX, XXXX ). XXXX XXXX inherited a home as the successor trustee to her mothers trust after her mother, the original borrower, passed away XXXX. Id. XXXX notified XXXX of the borrowers death and communicated with XXXX for many months in an attempt to obtain a loan modification. XXXX. Id. at XXXX. XXXX sent multiple letters to XXXX XXXX, XXXX deceased mother, as XXXX XXXX XXXX XXXX XXXX soliciting a loan modification application. XXXX. Id. at XXXX. Then XXXX sent a loan modification offer letter to XXXX XXXX XXXX XXXX. XXXX. Id. XXXX signed and returned the modification trial plan offer and made all three payments, only to be told by XXXX that she was denied for the modification because she was not the borrower. XXXX. Id. The court allowed XXXX to proceed with claims for negligence and unfair practices and found she had pled facts supporting a breach of the duty of care in the loan modification process. XXXX. Id. at XXXX, XXXX. The XXXX court offers an indirect approach to the problem of successor homeowners based on the intuitive unfairness of servicer conduct in these situations, XXXX. See id. at XXXX but the court did not conduct an analysis of the underlying legal rights of the parties. XXXX. XXXX id. at XXXX. The Texas federal district court in XXXX XXXX XXXX XXXX, XXXX. XXXX. XXXX XXXX XXXX. XXXX XXXX ( S.D. XXXX. XXXX ) offers the clearest and most coherent analysis of the relationship between a loan modification and an assumption. In that case, the court found that once the successorthe daughter of the original borrowerassumed, she stepped into the shoes of the mortgagor, with all the rights and responsibilities of the original borrower. XXXX. Id. at XXXX. These rights included the right to cure a default, right to receive a notice of any breach, and full authority to negotiate a loan modification agreement, even though the mortgage was in default at the time. XXXX. Id. at XXXX. Analytically, this approach makes sense. Upon assumption, the successor homeowner becomes the borrower with all the attendant rights and obligations. XXXX. XXXX id Mortgage modifications are routinely negotiated for borrowers who are in default, and the successor status of the borrower is not, in itself, a bar to a work out arrangement. At least XXXX bankruptcy court has agreed and permitted the successor homeowner to participate in a court sponsored loss mitigation program. XXXX. In XXXX XXXX, XXXX B.R. XXXX, XXXX XXXX XXXX. S.D.N.Y. XXXX ). In a cursory settlement conference decision, however, a New York state judge dismissed the argument that the XXXX XXXX exclusions give successor homeowners the right to be considered for a loan modification. XXXX. XXXX Bank XXXX XXXX, XXXX XXXX XXXX, XXXX XXXX Sup. Ct. XXXX ). The homeowner apparently had not assumed the loan in that case, and the judge relied on the lack of privity between the parties in holding that the borrower had no right to be evaluated for a loan modification. XXXX. But see In re XXXX, XXXX B.R. at XXXX ( rejecting the privity argument in the bankruptcy context and finding that a successor homeowner, protected from the exercise of the due-on-sale clause under the XXXX XXXX XXXX, was entitled to participate in a court-sponsored loss mitigation program ). The decision leaves open the possibility that if the homeowner had assumed the loan, like the homeowner in XXXX, the court might have reached a different result. XXXX. XXXX XXXX, XXXX XXXX at XXXX. As it stands, the courts decision flies in the face of guidance issued by XXXX XXXX, XXXX XXXX, and the Treasury Department requiring that successor homeowners be evaluated for a loan modification as if they were the original borrower and that an assumption be processed. XXXX. Muse-Evans, XXXX note XXXX, at XXXX ( successor homeowner must be evaluated for loan modification as if borrower and packet should be forwarded to XXXX XXXX for modification review and related assumption ) ; XXXX XXXX XXXX, XXXX note XXXX ( requiring simultaneous modification and assumption ) ; XXXX XXXX, XXXX note XXXX, at XXXX. For the programs they oversee, XXXX XXXX, XXXX XXXX, and the Treasury Department require servicers to evaluate successor homeowners for a loan modification and, if approved, to simultaneously process the modification and then and an assumption. XXXX. Muse-Evans, XXXX note XXXX, at XXXX ; XXXX XXXX XXXX, XXXX note XXXX ; XXXX XXXX, XXXX note XXXX, at XXXX. This requirement is imposed so that successor homeowners can know in advance of assumption whether or not the servicer will approve the homeowner for a loan modification and what the terms of that modification will be. XXXX. XXXX XXXX v. Bank XXXX XXXX XXXX, XXXX XXXX. Rptr. XXXX XXXX, XXXX ( Ct. App. XXXX ). For most homeowners, it makes no sense to assume a mortgage loan that is in default with unaffordable payments unless an affordable loan modification is assured. XXXX. See XXXX XXXX, Mortgage Modification Defaults Occur for XXXX in XXXX Borrowers, Study Says, XXXX XXXX XXXX XX/XX/XXXX, XXXX PM ), http : XXXX XXXX. When servicers require assumption before evaluation and block assumption on the basis of default status, successor homeowners are trapped. XXXX. See XXXX XXXX, Guidelines Help Heirs Assume and Modify Loans, XXXX XXXX XXXX XXXX XXXX, XXXX XXXX, XXXX : XXXX loans.html? _ XXXX. Recognizing this XXXX, XXXX  XXXX, XXXX XXXX, and the Treasury Department in its XXXX XXXX have all instituted procedures where a successor homeowner is evaluated for a loan modification before being required to assume the mortgage. XXXX. XXXX XXXX XXXX XXXX3, XXXX note 49 ; XXXX XXXX, XXXX note 99, at 129 ; XXXX-XXXX, supra note 49, at 1. Unfortunately, many servicers have not caught up with these policies and have continued to spread misinformation about the rights of successors to apply for a loan modification before assuming the loan. XXXX. XXXX XXXX, XXXX note XXXX Successors continue to report being told that the servicer can not talk with them about the loan or evaluate them for a modification because they are not the borrower, so many successor homeowners have found relief from bankruptcy courts. XXXX. See infra XXXX VI XXXX for bankruptcy de-accelerates the debt, which allows the successor to cure the default. XXXX. XXXX, XXXX, XXXX XXXX XXXX, XXXX. XXXX, XXXX WL XXXX, at XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) ; In re XXXX, XXXX B.R. XXXX, XXXX ( XXXX. D.S.C. XXXX ). The use of bankruptcy to protect the rights of successor homeowners is the subject of the following Part. \n\nSo, again the question stands to whether this case, that is, loan # XXXX involving XXXX XXXX. XXXX, mortgagor, and successor XXXX XXXX XXXX, heir v. Shellpoint Mortgage Servicer. Here the petitioner persists the loan modification of XX/XX/XXXX, progressed through the Trial Period Plan, but then was interfered with misinformation, delays and indecisiveness. It does not excuse the negligence to go forward with a transfer abruptly without making the successor aware of the seriousness involved, and vulnerabilities at stake concerning the shortness of time before the transfer is to take effect. There is no excuse for not discussing thoroughly in the months of XXXX and XX/XX/XXXX, the approaching of a transfer. As it is alleged, the transfer was done in secret, and was deceitful. There are how days in XXXX., that silence exist when we should be talking. Nowhere in the files or tapes, can Shellpoint or its representatives verify that this disclosure was properly administered. This homeowner had every right to have this information and understanding to the future of this loan, and should not be legally denied. That the courts do not permit the play with words in an effort shuffle into a winning position. Shellpoint  knowingly, that this misinformation would fail the budget of this petitioner, use the silence ( deceptive omission ) to through the loan into default. \n\nThe petitioner alleges and re-iterates further, there is a great case aforementioned above for negligence and unfair business practice. In fact, the petitioner believes the XXXX XXXX XXXX XXXX Institution Act prohibits the problems Shellpoint has given this heir in loan # XXXX. \n\nThe petitioner believes there is an element of deceit and trickery within this complaint when Shellpoint withholds the information regarding the transfer. The petitioner believes he can be heard in a court of law when this proposed deceit and cause the harm in the form of the forbearance which XXXX presents to the debt of arrears ( {$2000.00} XXXX upcoming in the next month. The deceit when defined : lying in the real world covers more than lying studied in the laboratory : lying is often done for personal or ideological gain ; it can harm the victim, and it is often carried out over a considerable span of time. More broadly, deception includes more than lying. In fact, deception can be carried out without explicit lying. \n\nDeception can be defined broadly as the manipulation of appearances such that they convey a false reality. However, when one tries to list a variety of deceptions and their contexts, it becomes difficult to find a common set of features that characterizes all of them. At best, the various at best, the various types of deception bear what XXXX XXXX XXXX ) calls a family resemblance to one another. Deception includes both dissimulation ( hiding or withholding information ) and simulation ( putting out wrong or misleading information ). Both deception and lying can be accomplished by omission as well as by commission. Interestingly, folk theories of deception are more likely to attach moral significance to deceptions accomplished by commission than to those accomplished by omission.","date_sent_to_company":"2020-07-23T08:07:54.000Z","issue":"Struggling to pay mortgage","sub_product":"Conventional home mortgage","zip_code":"278XX","tags":"Older American, Servicemember","has_narrative":true,"complaint_id":"3760674","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Shellpoint Partners, LLC","date_received":"2020-07-23T07:52:57.000Z","state":"NC","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":null},"highlight":{"complaint_what_happened":["Mortgage Servicing Rules Under the <em>Real</em> <em>Estate</em> Settlement Procedures Act ( Regulation X ), XXXX Fed. XXXX. XXXX, XXXX ( XXXX XXXX, XXXX )  ( codified at XXXX C.F.R. pt. XXXX ). XXXX, There has scarcely been time to reach court decisions on those rules. Extending the evaluation right to successor homeowners is a topic even fewer courts have addressed. XXXX of the first cases to consider the rights of successor homeowners to evaluation for a loan modification was XXXX v."]},"sort":[8.351501,"3760674"]},{"_index":"complaint-public-v1","_id":"2945343","_score":5.1440544,"_source":{"product":"Checking or savings account","complaint_what_happened":". \n\n\n\n\n\nURGENT FROM : XXXX. XXXX XXXX XXXX, XXXX XXXX, President Commissaries XXXX ; and XXXX XXXX, Majority Owner, 100 % Proxy Holder and CIO ATT : 1.XXXX XXXX XXXX and XXXX XXXX XXXX XXXX XXXX - XXXX XXXX Head of Americas Email : XXXX Phone : XXXX XXXX XXXX XXXX XXXX XXXX XXXX / XXXX ; XXXXXXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX and XXXX ; 2.XXXX XXXX XXXX - VIA Email : XXXX ; XXXX Office Mail Code XXXX XXXX XXXX  XXXX XXXX, XXXX  XXXX CC : I. Federal Deposit Insurance Corporation, Division of Depositor and Consumer Protection XXXX / XXXX XXXX XXXX XXXX, XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX / FDIC Reference among others : Number : XXXX VIA / E-mail : XXXX, XXXX ; II. Federal Reserve Board of Governors XXXX XXXX XXXX XXXX, XXXX  XXXX VIA / E-mail : XXXX ; Reference among others : Number XXXX XXXX. Consumer Financial Protection Bureau XXXX XXXX, Senior Vice President - Head of Customer Experience Consumer Financial Protection Bureau-XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX VIA / E-mail : XXXX ; IV. Office of the Comptroller of the Currency XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXXXXXX VIA / E-mail : XXXX ; Reference among others : Number :XXXX XXXX United States Securities and Exchange Commission ( SEC ), XXXX XXXX SEC Headquarters Office, to the hands of XXXX XXXX XXXX XXXX Special Counsel Office of Investor Education and Advocacy U.S. Securities and Exchange Commission VIA / E-mail : XXXX, XXXX, XXXX ; VI. \n\nFEDERAL TRADE COMMISSION Headquarters Federal Trade Commission XXXX XXXX XXXX, XXXX XXXX XXXX XXXXXXXX Telephone : ( XXXX ) XXXX VIA Email : XXXX XXXX. XXXX Direction XXXX XXXX XXXX XXXX XXXX / XXXX XXXX XXXX XXXX ; XXXX. XXXX, XXXX ; Ladies and Gentlemen from XXXX XXXX and XXXX XXXX, Ladies and Gentlemen from CHASE, We, XXXX XXXX and XXXX XXXX, refer to our previous correspondence ( See attached corespondence with XXXX XXXX XXXX, XXXX XXXX  XXXX, XXXX, XXXX XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX XXXX ). We are acting in our capacity as President Commissaries, and 100 % Proxy-Hoder and CIO ( Chief Investment Officer ) from XXXX XXXXXXXX XXXX XXXX. \n\nTherefore among others, it has to be noted, that CHASE and its subsidiaries in the role of remittancebank illegally did transfer from our deposit-accounts in XXXX XXXX ( XXXX ) XXXX via XXXX XXXX XXXX to XXXX XXXX XXXX   an amount of USD XXXX XXXX ( please compare again belove attached clearing document ( mr XXXX XXXX XXXX PAGE ), which was sent to CHASE by FDIC and by CFPB, but which questionnaire remained unanswered ). Disposition ( s ) about our assets took place without XXXX XXXX XXXX   INVESTASIs knowledge and consent. This money was stolen from our account in XXXX XXXX ( XXXX ) XXXX and further on was illegally used by JP Morgan XXXX  ( whereby deposits are insured with FDIC and registered with SEC US ). \n\nIn connex with proceeds realized via stock-market by XXXX XXXX in cooperation with XXXX XXXX  XXXX ( USD XXXX XXXX-Please see attachment belove again XXXX dbag XXXX ) from traded deposits of XXXX XXXXXXXX XXXX XXXX, CHASE has received prospects and authentificated transaction by XXXX XXXX ( XXXX XXXX XXXX ) including all the details and registered with SEC US in a volume of XXXX XXXX USD. \n\nIn XX/XX/XXXX bank -statments from XXXX XXXX ( in total were collected more then USD XXXX XXXX from assets of XXXX XXXX XXXX ) were falsified and registered under the name of XXXX XXXX who again was not informed about. \n\nFrom XXXX XXXX per XXXX to XXXX XXXX XXXX XXXX then was confirmed, that suche transfers was provided for a certain beneficiary company for TRADING ( compare : XXXX XXXX XXXX -statements and Agreements which was sent among others to the US competent authorities FDIC , SEC US , CFPB and FED US and to competent international prosecutors in XXXX XXXX XXXX and XXXX in regard with investigations and prosecutions against involved XXXX XXXX  XXXX , XXXX XXXX , XXXX XXXX XXXX in International Criminal Organized Bank Cartel and abuse the assets of our company XXXX XXXX XXXX ( Please see above attachment XXXX XXXX XXXX  XXXX XXXX XXXX )! \nAs it can be seen from previous correspondence, XXXX XXXX did not want to cooperate with us. In the meantime it came up, that there are massive irregularities related to the business relationship between XXXX XXXXXXXX XXXX XXXX and XXXX XXXX XXXX, XXXX XXXX  XXXX, XXXX, XXXX, XXXX XXXX, XXXX XXXX and other international banks, this over many years. Our assets are based on the deposits held at XXXX XXXX XXXX and XXXX, XXXX and its subsidiary ( among others see attachments our mentioned assets registered with SEC US and insured with FDIC ), which were denominated in XXXX and have been used, among others, as collateral for credit lines opened at XXXX XXXX XXXX ( Please see attachment MKB 1 ( 1 ) .pdf ( 397 KB ). \n\nOnce these credit lines have been opened, XXXX XXXX  XXXX has given various assessments to other international banks where these investments exist until today. Interest and income were also assessed on a resurgent basis. But after original investments via XXXX XXXX XXXX have come to an end, we are prevented from accessing our assets. \n\n\nWe are now editing individual banks in which such investments are deposited in the name of PT. XXXX XXXX XXXX / XXXX XXXX. We provide you with appropriate information related to investments of PT. XXXX XXXX XXXX at XXXX XXXX, in which connex an essential role plays SEC, as among others - XXXX American Depositary Shares are filed with the U.S. Securities and Exchange Commission on XX/XX/XXXX ( Registration Nr. XXXX and that the role of CUSTODY has XXXX XXXX ).  Enclosed you find respective correspondences and prospectus. \n\n\nFurther there are XXXX XXXX Dynamic Proportion Portfolio Notes ( date of prospectus 6. XX/XX/XXXX ). An excerpt ( pages 80 86 ) from  respective prospectus you find enclosed, where you also will find the role of XXXX. XXXX XXXX XXXX. The name XXXX applies to the abbreviation of XXXX. XXXX XXXX XXXX at XXXX XXXX XXXX, but the real investor XXXX. XXXX XXXX XXXX here apparently has been tried to disguise and it has been tried to push forward a company with virtually identical /similar name as a PXXXX XXXX  called XXXX XXXXXXXX XXXX XXXX ( XXXX ) ltd.. But such a company was never officially registered under this name (! ). Such dubious circumstances are in an urgent need of clarification. \n\nIn our annexes you will also find part of the correspondence, prospectuses, etc. collected since XXXX. Direct corespondences with XXXX XXXX ( among others with XXXX XXXX XXXX ) remained inconclusive. In XXXX we also have contacted competent French supervisory authority XXXX among others via our legal department. First XXXX XXXX XXXX / XXXX seemed to be cooperative, but then XXXX XXXX / XXXX ( her superiors ) did not give us any valuable information and apparently had great interest in completing further contacts between XXXX. XXXX XXXX XXXX and XXXX. In the end, until now there was no result to get information from XXXX XXXX and from XXXX why we have not been able to realize even a single dollar of our XXXX XXXX assets (! ). \n\nPT. XXXX XXXX XXXX assets at XXXX XXXX consist of ( please see enclosed ) : a ) XXXX XXXX ADRs ; b ) XXXX XXXX Linked Dynamic Proportion Portfolio Notes ; c ) Possibly other assets, which have been concealed to us so far ; INFORMATION TABLE The provisions of this Information Table set out below ( save for Part 4 ( Fees ), Part 5 ( Performance Swap Information ) and Part 6 ( Administrative and Settlement Data ) ) will be endorsed upon, or attached to, each Global Note and Note Certificate. Part 1 Issue Amount and Redemption Date Class Initial Issue Amount Redemption Date Principal Protection Ratio Issue Date Class E-5GC Up to EUR XXXX XX/XX/XXXX 85 % XX/XX/XXXX The class of Notes specified above is a \" Class '' of Notes. 1. Distribution fees and other costs of issuance in relation to each Class of Notes are met by the Swap Counterparty on behalf of the Issuer in consideration for a debit to the applicable Notional Cash Account as described in the section of this Prospectus entitled \" The Performance Swaps ''. The Swap Counterparty will make payment of such distribution fees to the Sole Distributor. \n\n\n2. The Issue Date and Redemption Date may be subject to adjustment. Any such adjustment will be the subject of an announcement on the website of the XXXX Stock Exchange ( XXXX ) and on the website of the XXXX Stock Exchange ( XXXX ). \n\nPart 2 Coupons Notes Coupon Payment Dates Day Count Fraction Guaranteed Coupon Rate Class E-5GC Each date falling on the expiry of each six month period from the Issue Date, up to and including the Redemption Date XXXX 0.25 % Part 3 General Business Day Centres : XXXX, XXXX XXXX, XXXX   XXXX, XXXX, XXXX Issue Price : 100 per cent. Series Number : XXXX \" XXXX XXXX '' ( See Page 17 ) Part 4 Fees Notes Senior Management Fee Rate Junior Management Fee Proportion Gap Risk Payment Rate Target Rate Class E-5GC 0.80 % 20 % 0.80 % 3 month EURIBOR plus 230bps Part 5 Performance Swap Information Notes Currency Limit Liquidity Event Threshold Class E-5GC 2.00 % 2.00 % Eligible Currency : USD, EUR, GBP, JPY Part 6 Administrative and Settlement Data Notes Specified Denomination Tradeable Amount ISIN Common Code VP code Class E5GC EUR XXXX EUR XXXX and integral multiples of EUR XXXX thereafter XXXX, XXXX, XXXX See paragraph 3.1 of the section of this Prospectus headed \" Summary of the Portofolio. \nIt can be assumed that XXXX XXXX XXXX, which still withholds crucial information and codes, has intervened with XXXX XXXX, possibly also with XXXX, so that the business relationship between XXXX XXXX XXXX and XXXX. XXXX XXXX XXXX could not be discovered by way of XXXX XXXX. \n\nThere is urgent suspect, that XXXX XXXX and XXXX XXXX was and is acting with an aim of misusing assets from XXXX. XXXX XXXX XXXX and improperly enriching itself and / or third parties ( clients and/or business-partners ). According to our investigations XXXX XXXX is responsible for illegal and criminal steps by falsification of prospects related to our investments. The facts of investment ( s ) of PT. XXXX XXXX XXXX in XXXX XXXX are out of question and are evident from prospectuses registered with SEC US ( see  XXXX ( 43 KB ), filed with US SEC on XXXX XXXX, Registration XXXX ). \n\nIn both prospects from the beginning are containing general text and date of ISSUE 6. XX/XX/XXXX ( in total 117 pages ), compare prospectuses ( XXXX Prospectus.pdf ( 963 KB ) and XXXX XXXX Credit-Linked Dynamic Proportion % XXXX ( 1 ) .pdf ( 756 KB ). \n\nQUOTE PROSPECTUS XXXX XXXX ( the \" Issuer '' ) ( incorporated in XXXX ) issue of \" XXXX XXXX '' Dynamic Proportion Portfolio Notes ( the \" Notes '' ) This Prospectus constitutes a prospectus for the purposes of Article 5.3 of Directive XXXX ( the \" Prospectus Directive '' ) as implemented in XXXX by the Prospectus ( Directive XXXX ) Regulations XXXX and has been prepared, amongst other things, for the purpose of giving information with regard to the Issuer and the Notes. \n\nApplication will be made to the XXXX Financial Services Regulatory Authority ( the \" XXXX '' ), as competent authority under the Prospectus Directive, for this Prospectus to be approved. Such approval will relate only to Notes which are to be admitted to trading on the regulated market of the XXXX Stock Exchange or  other regulated markets for the purposes of Directive XXXX or which are to be offered to the public in any Member State of the XXXX XXXX XXXX. \n\nApplication will be made to the XXXX Stock Exchange for Notes issued to be admitted to the Official List and trading on its regulated market. Application will additionally be made to XXXX XXXX for some or all of the Classes of Notes to be admitted to trading on its regulated market ( on the basis of the approval of the XXXX referred to above ). \n\nNo assurances can be given that such listing and admission to trading will be approved. Any investment in Notes does not have the status of a deposit and will not have the benefit of the deposit protection scheme operated by the XXXX. The Issuer will not be regulated by the IFSRA by virtue of the issue of Notes. \n\nThe Notes will be offered for sale to the public in XXXX, XXXX, the Kingdom of XXXX and the Kingdom of XXXX during a subscription period from ( and including ) XXXX XX/XX/XXXX to ( and including ) XXXX XX/XX/XXXX, provided that the relevant regulatory approvals have been granted. Such subscription period is subject to adjustment by or on behalf of the Issuer ( and for the avoidance of doubt, no supplement to this XXXX will be published in relation thereto ). \n\nThe total number of Notes and the Classes of Notes to be issued will be determined based on market demand for the Notes during the subscription period together with market conditions at the end of the subscription period and will be made available on the website of the XXXX Stock Exchange ( XXXX ) on or around the last day of the subscription period ( and for the avoidance of doubt, no supplement to this Prospectus will be published in relation thereto and such information will be in the form of an announcement in accordance with Article 8 of the Prospectus Directive and the XXXX will be notified of such information and dealing in the Notes may begin before such information is made available ). \n\nThe XXXX has been requested to provide the competent authorities in XXXX, XXXX, the Kingdom of XXXX and the Kingdom of XXXX for the purposes of the Prospectus Directive with a certificate of approval attesting that the Prospectus has been drawn up in accordance with the Prospectus Directive. Further requests may be made in the future to the competent authorities in other jurisdictions. \n\nTHE NOTES HAVE NOT BEEN, AND WILL NOT BE, REGISTERED UNDER THE SECURITIES ACT AND, MAY NOT BE OFFERED, SOLD OR DELIVERED WITHIN THE UNITED STATES OR TO, OR FOR THE ACCOUNT OR BENEFIT OF, U.S. PERSONS ( AS DEFINED IN REGULATION S UNDER THE SECURITIES ACT ). THE ISSUER HAS NOT BEEN NOR WILL BE REGISTERED UNDER THE INVESTMENT COMPANY ACT. \n\nArranger : XXXX XXXX XXXX XXXX XXXX XXXX XXXX, Sole Distributor XXXX XXXX The date of this Prospectus is XXXX XX/XX/XXXX UNQUOTE BUT : Note Difference in the text starts in prospectus A ( XXXX Prospectus.pdf ( XXXX KB ) on PAGE 1 below where are the following DATA DETAILS evident : / XXXX XXXX XXXX XXXX and further , among others on PAGES XXXX XXXX : QUOTE THE PORTFOLIO MANAGER XXXX XXXX XXXX, XXXX, a XXXX corporation ( XXXX ), is a holding company which, through its subsidiaries, is engaged in a broad range of insurance and related activities in the United States and abroad. \n\nXXXX  primary activities include both general and life insurance operations. Other significant activities include retirement services, financial services and asset management. XXXX XXXX XXXX ( XXXX ) comprises a group of international companies which provide investment advice and market asset management products and services to clients around the world. \n\nThe XXXX XXXX will be XXXX XXXXXXXX XXXX XXXX ( XXXX ) XXXX XXXX the Portfolio XXXX ), a private limited company incorporated under the laws of XXXX and XXXX, and authorized and regulated by the XXXX XXXX XXXX XXXX XXXX with permission to manage investments. XXXX. XXXX XXXX XXXX, a XXXX XXXX corporation and an investment advisor registered with the United States Securities and Exchange Commission, will provide subadvisor services to the Portfolio Manager. \n\nEach of the Portfolio Manager and XXXX. XXXX XXXX XXXX. are wholly-owned subsidiaries of XXXX. As of XX/XX/XXXX, XXXX managed approximately U.S. dollars XXXX XXXX of assets, of which approximately XXXX dollars XXXX XXXX related to XXXX affiliated assets ( including those managed by joint ventures and certain other JSXinvestment advisor subsidiaries, but not including assets sub-advised to third party managers ) and approximately U.S. dollars XXXX XXXX related to client assets.JSX manages more than U.S. dollars XXXX XXXX in fixed income investments. JSXs managed fixed income investments include investment grade bonds, high yield bonds, private investments, leveraged loans, municipal bonds and mortgage loans. XXXX presently has more than 2,000 employees worldwide. \n\nPersonel Information regarding the background and experience of key personnel who are expected to be involved, directly or indirectly, in the selection and management of the XXXX XXXX XXXX is set out below. Such persons may not necessarily continue to be employed by XXXX for the entire term of the Portfolio Management Agreement and/or may not perform or continue to perform services in relation to the Global Reference Portfolio or the Portfolio Management Agreement. \n\nXXXX XXXX, Vice President, Senior Portfolio Manager, XXXX XXXX and XXXX XXXX XXXX joined XXXX in XXXX and is a Senior Portfolio Manager responsible for managing credit derivatives, synthetic CDOs, and preferred stock portfolios. Since joining, XXXX XXXX has been involved in building XXXX 's credit derivatives portfolio. Prior to AIGGIG, XXXX XXXX worked with XXXX as a Corporate Bond Strategist. His responsibilities there included developing quantitative and relative value tools, portfolio strategy, credit derivatives, and risk management. Prior to XXXX, he was at XXXX XXXX in their XXXX XXXX XXXX XXXX. Prior to that, he worked as a XXXX XXXX XXXX at XXXX XXXX XXXX XXXX. XXXX XXXX received an XXXX in XXXX from XXXX University of XXXX XXXX and a XXXX  in XXXX from XXXX XXXX XXXX XXXX in XXXX. \n\nXXXX XXXX, Vice President, Senior Credit Analyst, High Grade Fixed Income XXXX XXXX joined XXXX in XXXX. He is primarily involved in high grade credit research and oversees the global consumer cyclical research team. In addition, he has regional sector responsibility for XXXX XXXX, building materials, and general industrials. Prior to this role, XXXX XXXX was a portfolio manager responsible for managing a range of XXXX and XXXX balance sheet and total return portfolios. Prior to joining XXXX, he worked as a portfolio manager in the XXXX XXXX XXXX subsidiary of XXXX XXXX XXXX XXXX. XXXX XXXX is a qualified Accountant and is an Associate Member of the XXXX XXXX XXXX XXXX XXXX ( XXXX ). He received a XXXX  ( Honours ) in XXXX XXXX XXXX from XXXX XXXX XXXX and is an Associate Member of the XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX ). \n\nXXXX XXXX, Senior Managing Director, Head of Global Fixed Income XXXX XXXX joined XXXX with the acquisition of XXXX XXXX XXXX XXXX ( XXXX ) in XXXX and is responsible for XXXX 's Global Fixed Income operations. As Chief Investment Officer of XXXX since XXXX, XXXX XXXX was responsible for overseeing all aspects of AGIMs business. Prior to AGIM in XXXX, XXXX XXXX served as Vice Chairman, General Counsel, and Chief Investment Officer of XXXX XXXX XXXX, a U.S. dollars XXXX XXXX annuity company, based in XXXX, XXXX. XXXX XXXX began his career at XXXX XXXX XXXX in XXXX. After two years with the firm, XXXX XXXX moved to XXXX XXXX XXXX, XXXX. where he was a partner in the corporate finance and securities section of the firm. XXXX XXXX received an XXXX ( cum laude ) in  XXXX from XXXX University and a XXXX  from XXXX University XXXX XXXX. He is also a member of XXXX XXXX XXXX. \n\nXXXX XXXX, Vice President & Senior Investment Manager,  Emerging Markets Fixed Income XXXX XXXX joined XXXX in XXXX as a Senior Investment Manager contributing to the Emerging Market Bond Team. He focuses on portfolio management of local currency debt as well as sovereign debt. XXXX XXXX was previously the London-based emerging market currency strategist for an affiliate, XXXX XXXX XXXX. \n\nXXXX XXXX began his investment career when he joined the XXXX member companies in XXXX, following roles at the XXXX for XXXX, the XXXX XXXX, and the Permanent Representation of XXXX to the XXXX XXXX. He received a degree in XXXX from the University XXXX XXXX and a XXXX in XXXX of the XXXX XXXX from the University of XXXX. \n\nXXXX XXXX, Managing Director, Co-Head of High Yield ( Please see public Article ... .. ) XXXX XXXX XXXX XXXX as Head of High Yield Research in 2001 with the acquisition of XXXX XXXX XXXX XXXX became a high yield Portfolio Manager for XXXX in XX/XX/XXXX and Co-Head of High Yield in XXXX. At AGIM, XXXX XXXX served as the media/communications group head. XXXX XXXX was with XXXX XXXX of California where he most recently served as Vice President covering the media and communications sectors. Prior to that, XXXX XXXX served as Vice President in the media and communications groups of XXXX XXXX and XXXX XXXX. He also worked as an associate in corporate finance at XXXX XXXX XXXX XXXX. XXXX XXXX began his career in the audit division of XXXX XXXX XXXX XXXX  He received a XXXX, summa cum laude, in XXXX from XXXX, and an XXXX from the University of XXXX, XXXX. He is a member of XXXX XXXX XXXX. \n\nXXXX XXXX, Managing Director, Head of High Grade Corporate Bond Trading XXXX XXXX joined XXXX in XXXX and is a Managing Director and Head of High Grade Corporate Trading, overseeing trading for both the XXXX XXXX and XXXX trading desks. XXXX XXXX also is responsible for trading U.S. corporate bond and credit derivative markets for the airlines, autos, energy, and REITs sectors. Since joining XXXX, XXXX XXXX has been involved in integrating trading teams from both XXXX and XXXX XXXX, as well as the high grade team in XXXX. Prior to joining XXXX, XXXX XXXX was a Fixed Income Trader and Portfolio Manager for XXXX XXXX and a Management Associate with XXXX XXXX XXXX. XXXX XXXX received a XXXX in XXXX XXXX   XXXX from XXXX XXXX. \n\nXXXX XXXX, Managing Director, Head of XXXX XXXX Debt XXXX XXXX joined XXXX in XXXX and is Head of Emerging Markets Debt. He is responsible for the portfolio management of emerging sovereign strategies in hard and local currencies and credit default swaps for internal and non-affiliated clients. Prior to his current position and responsibilities at XXXX, his responsibilities included portfolio management of single currency U.S. Dollar, Sterling, and Irish Punt portfolios as well as global bond portfolios. XXXX XXXX is a member of the Fixed Income Asset Allocation Team and also represents emerging markets debt in the Global Asset Allocation Committee meetings. He received a XXXX ( Honours ) in XXXX XXXX XXXX from the University of XXXX. \n\nXXXX XXXX, Vice President, Trader, High Grade Fixed Income XXXX XXXX joined XXXX in XX/XX/XXXX and is currently based in XXXX XXXX, and is responsible for trading dollars in the following sectors : Aerospace/Defense, Healthcare, Homebuilders, Hotels, Gaming, Consumer Products, Retail and Supermarkets. XXXX XXXX was based in XXXX from XX/XX/XXXX to XXXX of XXXX, where he traded dollars, euros and sterling in the following sectors : Autos, XXXX Chemicals, Metals, Supermarkets, Retail, Sovereigns, Supranationals, U.S. treasuries and U.S. agencies. From XX/XX/XXXX to XX/XX/XXXX, XXXX XXXX was based in XXXX XXXX and traded Consumer Products, Defence, Banks, Brokers, Healthcare, Sovereigns, Supranational,  Agencies, other services and all floating rate paper. Upon joining XXXX, he worked in the Systems Department as a Front Office Systems Analyst where he implemented several different fixed income and equity analytical systems. Prior to joining XXXX, XXXX XXXX was a Senior Pricing Analyst at XXXX XXXX XXXX. He received a XXXX in XXXX XXXX and a Minor in Economics from the University of XXXX XXXX. He holds Series 7 and 63 licenses and the XXXX XXXX XXXX. \n\nXXXX XXXX, Fixed Income Trader, Investment Grade Fixed Income XXXX XXXX joined XXXX in XXXX and is a member for the XXXX High Grade team trading Financials, Utilities, Defence, Pharmaceuticals, and Consumer Products in both cash and CDS. Prior to joining XXXX, XXXX XXXX was an underwriting trainee at XXXX. He received a XXXX in XXXX from XXXX University. \n\nXXXX XXXX, Managing Director, Head of Fixed Income Trading Desk, XXXX XXXX XXXX joined XXXX in XXXX and is the Head of Fixed Income Trading in XXXX. His responsibilities include trading corporate bonds and credit default swaps within balance sheet and total return portfolios. XXXX XXXX also manages three other traders in the XXXX office and is the dedicated emerging market trader focusing on both hard currency and local government markets. \n\nPreviously, XXXX XXXX was at XXXX XXXX XXXX, most recently as a Fixed Income XXXX. Prior to XXXX, he was employed by XXXX XXXX XXXX XXXX and XXXX XXXX Overseas Division in different capacities in the money market area. XXXX XXXX received his Investment Management Certificate and completed the Security and Financial Derivatives Examination. XXXX XXXX, XXXX, Vice President, Investment XXXX, Fixed Income Investment Grade XXXX XXXX joined XXXX in XXXX as a Fixed Income Investment XXXX. Her primary responsibility includes managing single currency portfolios with a credit bias. She began her career as an Investment Manager for XXXX XXXX XXXX on the XXXX XXXX XXXX team specializing in XXXX credit portfolios. \n\nXXXX XXXX graduated from XXXX University with a XXXX  degree in XXXX. She has completed the XXXX XXXX XXXX and XXXX. XXXX XXXX is a member of the XXXX XXXX and the XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX  ). She is a CFA charterholder. \n\nXXXX XXXX, Chief Credit Officer, Global Fixed Income XXXX XXXX joined XXXX in XXXX and is the Chief Credit Officer for Global Fixed Income with responsibilities that span various asset classes and geographies. \n\nHe also chairs XXXX XXXX XXXX XXXX. Prior to his current duties, XXXX XXXX served as Managing Director of High Grade Fixed Income Research, where he oversaw a team of 16 investment professionals responsible for over U.S. dollars XXXX XXXX in assets. Prior to joining XXXX, XXXX XXXX worked for New York XXXX XXXX XXXX for 12 years, serving as an analyst covering various industry sectors, then as a manager in various credit functions. Previously, he worked in the Controller 's Department of XXXX XXXX XXXXXXXX for 6 years where he focused on investment accounting, mergers and acquisitions, competitive analysis and strategic planning. XXXX XXXX is a member of the XXXX XXXX Society of Security Analysts and has served on the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, where he remains a member. He holds an XXXX in XXXX from XXXX XXXX University 's XXXX XXXX XXXX XXXX and a XXXX in XXXX  from XXXX University. \n\nXXXX XXXX, XXXX, Managing Director, Fixed Income Capital Markets of XXXX XXXX XXXX is responsible for XXXX Matched Investment Program, as well as coordinating XXXX other fixed income capital markets initiatives. \n\nXXXX XXXX is also responsible for overseeing XXXX Structured Credit business including investments in third-party-managed CDO transactions and issuance of XXXX XXXX transactions. XXXX XXXX held a similar position at XXXX where she also directed the firms investments in asset-backed and commercial mortgage-backed securities. XXXX XXXX joined XXXX with the acquisition of XXXX in XXXX, and XXXX XXXX in XXXX as a member of the real estate group. Her prior experience was in real estate banking. XXXX XXXX earned a BA degree in sociology and an XXXX degree in XXXX  from the University of XXXX at XXXX. XXXX XXXX is a CFA charterholder. \n\nXXXX XXXX XXXX, CFA, Vice President, High Yield Trader, XXXX XXXX XXXX XXXX XXXX rejoined XXXX XXXX High Yield Team in XXXX. XXXX XXXX was a high yield portfolio manager with XXXX XXXX XXXX. Over the ten years that he has been associated with XXXX, XXXX XXXX had been involved in many different aspects of the companys financial business including systems, marketing services, securities accounting, portfolio forecasting and analysis and, beginning in XXXX, high yield trading. Prior to joining XXXX in XXXX, XXXX XXXX was a municipal bond trader with XXXX XXXX, XXXX and a financial analyst and trader for XXXX XXXX XXXX XXXX XXXX. He received a BS in Finance from the University of XXXX in XXXX and an XXXX in XXXX from XXXX University in XXXX. He is a XXXX charterholder. \n\nXXXX XXXX, Vice President, Senior Investment XXXX XXXX XXXX joined XXXX in XXXX and is a Vice President and Senior Investment Manager responsible for interest rate and currency and credit risk on both multi-currency and single currency bond portfolios. Since joining XXXX, he has been in charge of initiating both XXXX and XXXX XXXX products. \n\nXXXX XXXX industry experience began in XXXX at JP Morgan Investment Management where he was responsible for managing single and multi-currency bond portfolios on behalf of pension funds and private clients. During his 11 years at JP Morgan, XXXX XXXX undertook positions in capital markets research, fixed income trading and portfolio management focusing on risk management techniques, use of derivatives and macro economic analysis. XXXX XXXX holds a BSc degree ( honours ) in XXXX XXXX  XXXX from the University of XXXX. He holds the IMC and is registered as a holder of the CFTC Series 3 qualification. \n\nXXXX XXXX, XXXX, Vice President, Structured Credit XXXX XXXX joined XXXX in XXXX. XXXX XXXX invests in and manages a portfolio of third-partymanaged CDO transactions and assists in the issuance of XXXX XXXX transactions. Previously, XXXX XXXX was employed at XXXX, where she was responsible for recommending investments in the XXXX sector and was the analyst for the XXXX portfolio. In addition, XXXX XXXX was part of the management team for two TIAA-managed CDOs backed by structured finance securities. XXXX XXXX has a XXXX  in XXXX ( magna cum laude ) from XXXX University and an XXXX in XXXX from XXXX XXXX University, XXXX XXXX XXXX XXXX. XXXX XXXX is a XXXX charterholder. \n\nXXXX XXXX, Managing Director, High Grade Research XXXX XXXX XXXX joined XXXX in XXXX as a XXXX XXXX XXXX covering financial institutions. In XX/XX/XXXX, he became Director of High Grade Research, and is responsible for managing a group of XXXX XXXX XXXX","date_sent_to_company":"2018-06-25T19:02:37.000Z","issue":"Managing an account","sub_product":"Other banking product or service","zip_code":"XXXXX","tags":null,"has_narrative":true,"complaint_id":"2945343","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"JPMORGAN CHASE & CO.","date_received":"2018-06-25T18:22:41.000Z","state":null,"company_public_response":null,"sub_issue":"Deposits and withdrawals"},"highlight":{"complaint_what_happened":["XXXX XXXX joined XXXX with the acquisition of XXXX in XXXX, and XXXX XXXX in XXXX as a member of the <em>real</em> <em>estate</em> group. Her prior experience was in <em>real</em> <em>estate</em> banking. XXXX XXXX earned a BA degree in sociology and an XXXX degree in XXXX  from the University of XXXX at XXXX. XXXX XXXX is a CFA charterholder. \n\nXXXX XXXX XXXX, CFA, Vice President, High Yield Trader, XXXX XXXX XXXX XXXX XXXX rejoined XXXX XXXX High Yield Team in XXXX."]},"sort":[5.1440544,"2945343"]},{"_index":"complaint-public-v1","_id":"17114085","_score":3.2440872,"_source":{"product":"Mortgage","complaint_what_happened":"Consumer Financial Protection Bureau XXXX XXXX and XXXX Framework Submission Subject : Coordinated Mortgage Servicing Fraud, Accounting Manipulation, and Enrichment Scheme Primary Entities : XXXX XXXX XXXX, NewRez LLC, Shellpoint Mortgage Servicing, XXXX XXXX XXXX XXXX XXXX XXXX XXXX Supporting Evidence : CFPB Complaint XXXX # ( list XXXX XXXX ) + audio transcripts + servicing ledgers + metadata images Introduction XXXX XXXX and Corrupt Organizations ( XXXX ) Framework This submission establishes the existence of a continuing criminal enterprise composed of XXXX XXXX XXXX, its wholly owned subsidiaries NewRez LLC and Shellpoint Mortgage Servicing, and its retained legal counsel XXXX, XXXX, XXXX XXXX XXXX XXXX XXXX XXXX, with the participation and enrichment of multiple investment banks and insiders. The enterprises conduct spans mortgage servicing, securities reporting, and legal certification functions, coordinated for the purpose of financial enrichment through deception, concealment, and coercion. Its operational nucleus lies in a single integrated servicing system that manipulates consumer payments, falsifies corporate disclosures, and insulates its actors throu Systemic Consumer Harm and Market-Wide Impact The pattern of conduct established in both pending and resolved actions against NewRez LLC XXXX Shellpoint Mortgage Servicing XXXX and parent XXXX XXXX XXXX demonstrates that the violations are not isolated clerical errors, but symptoms of a uniform servicing architecture that injures every consumer whose mortgage is routed through these entities. XXXX. Structural Misapplication of Payments Across multiple jurisdictionsincluding XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ), and the current CFPB complaint databaseborrowers report identical failures to credit payments as of the date received. Your own account shows more than {$100000.00} held in unapplied suspense, yet monthly statements assess delinquency and fees. This mirrors the XXXX v. NewRez allegations of inflated unapplied balances and phantom late fees. Under XXXX C.F.R. XXXX ( c ) ( XXXX ) ( XXXX XXXX ) and XXXX XXXX. XXXX ( k ) ( XXXX ) ( C ) ( RESPA ), this practice constitutes a prohibited servicing act. The systemic replication of that violation across portfolios means every consumers amortization schedule, credit history, and equity position is corrupted. XXXX. False XXXX and XXXX XXXX Servicers routinely threaten foreclosure even when internal ledgers acknowledge that funds are present but misallocated. In your evidence, Shellpoint agents confirmed receipt of payments on XX/XX/XXXX yet issued non-payment threats on later callsconduct meeting the XXXX XXXX, XXXX U.S.C. XXXX, definition of extortion under XXXX of right. The same fact pattern appears in XXXX v. NewRez LLC ( XXXX. XXXX. ) and XXXX v. Shellpoint Mortgage Servicing ( XXXX. Md. ), establishing a nationwide blueprint for coercive servicing. XXXX. Obstruction of Error Resolution and Federal Oversight The enterprises wrong company response to RESPA Notices of XXXX that complaints were mis-directed despite consolidated ownershipis a deliberate obstruction under XXXX U.S.C. XXXX and violates XXXX C.F.R. XXXX ( XXXX ). Every consumer invoking statutory review rights is met with the same misrepresentation, depriving the public of the protections XXXX codified through XXXX XXXX XXXX XXXX ). XXXX. Economic and Psychological Damage Consumers suffer cumulative harms that regulators have recognized as unfair, deceptive, or abusive acts or practices ( UDAAPs ) under XXXX U.S.C. XXXX : XXXX : late fees, negative amortization, inflated escrow shortages, and loss of refinance eligibility. Credit : false delinquency reporting to XXXX XXXX XXXX U.S.C XXXX XXXX ( a ). Emotional : stress, reputational harm, and loss of housing stabilitythe same categories compensated in CFPB XXXX XXXX XXXX Bank XXXX. ( XXXX XXXX XXXX ). Your recordwhere Shellpoint issued a foreclosure threat while holding documented fundsdemonstrates these harms at the micro level, while the national docket of similar suits proves macro-level replication. XXXX. Market Integrity and Investor Deception Because XXXX XXXX consolidates subsidiary servicing income and uses those revenues to justify public equity sales ( as in its {$750.00} XXXX ATM program ), every falsified consumer ledger inflates corporate earnings. This constitutes a false statement of material fact under XXXX U.S.C. XXXX ( b ) and XXXX C.F.R. XXXX, mirroring SEC precedents such as SEC v. XXXX XXXX XXXX. XXXX. XXXX ). When millions of consumer accounts are handled through the same unlawful accounting method, both retail borrowers and capital-market investors are defrauded simultaneouslythe dual-victim hallmark of a racketeering enterprise. Conclusion : Public Harm Beyond Individual Accounts The identical misconduct confirmed in your casefunds sequestered, statements falsified, wrong company denials, and intimidation via foreclosure noticesappears across dozens of federal dockets, CFPB complaint records, and settlement orders. This establishes : XXXX. Continuity : the enterprise has operated with the same unlawful methods for years ( XXXX ). XXXX. Relationship : the acts are interdependent across XXXX, NewRez, and Shellpoint structures. XXXX. XXXX XXXX : every consumer loan they service is exposed to the same risk of financial and legal injury. Accordingly, the matter transcends private dispute and constitutes a systemic threat to consumer financial protection and market integrity, warranting full enforcement under XXXX U.S.C. XXXX ( b ) and referral to the DOJ and SEC for coordinated XXXX and securities-fraud prosecution. Introduction & Background of Servicing Entities The mortgage-servicing group composed of XXXX XXXX XXXX XXXX XXXX parent ), NewRez LLC XXXX XXXX subsidiary ) and Shellpoint Mortgage Servicing ( operating arm ) has drawn increasing regulatory, consumer-class action, and investor scrutiny over multiple jurisdictions and legal theories. These exposures provide a credible backdrop for alleged enterprise misconduct under the XXXX XXXX and Corrupt Organizations Act ( XXXX ) and federal consumer protection statutes : In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing, No. XXXX ( D. Md. ), borrowers alleged that Shellpoint systematically failed to provide required notices under the Real Estate Settlement Procedures Act ( RESPA ) and imposed fees in violation of the Maryland Consumer Debt Collection Act and the Maryland XXXX XXXX XXXX. In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing and The Bank of New York XXXX XXXX XXXX XXXX XXXX ( D. XXXX. ), the complaint alleges a pattern of zombie second-mortgage practices : inflated balances, failure to send statements to XXXX bankruptcy borrowers, and foreclosure threats on dormant liens. In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing, XXXX ( S.D. XXXX. ), a class action alleges that Shellpoint ( via acquired entity SLS ) charged pay-to-pay telephone payment fees up to {$7.00} far above processor cost thereby over-charging borrowers in violation of the Texas Fair Debt Collection XXXX and like statutes in other states. Consumer-complaint data filed with the CFPB show multiple narratives against NewRez/Shellpoint for XXXX XXXX XXXX, including failure to timely credit or apply payments, inadequate responses to RESPA Notices of XXXX, and misleading statements of arrearage. Recent media reporting characterises XXXX XXXX XXXX a legal and foreclosure storm in XXXX as lawsuits mount and servicing portfolio issues proliferate. Independent class-action settlements exist : for example, Shellpoint agreed XXXX a {$500000.00} settlement in XXXX to resolve claims of misleading statements sent to borrowers in XXXX XXXX forbearance. Corporate disclosures and filings indicate Rithm Capital ( formerly New Residential ) consolidates the servicing revenues of NewRez and Shellpoint and sells equity via XXXX ( ATM ) offerings tied to those revenues. I. Overview The enterprise consists of XXXX XXXX XXXX and its wholly-owned subsidiaries NewRez LLC and Shellpoint Mortgage Servicing, aided by XXXX XXXX XXXX XXXX XXXX counsel and XXXX investment banks as distribution agents for XXXX {$750.00} XXXX ATM equity program. Evidence demonstrates an ongoing pattern of servicing manipulation, false disclosures, and investor enrichment through unapplied-fund misallocation, constituting predicate acts under XXXX U.S.C. XXXX, XXXX, XXXX, XXXX, XXXX, and XXXX ( d ). XXXX. Organizational Structure and Control Layer Function Primary Actors Parent Entity Controls mortgage revenues, SEC reporting, and stock issuances XXXX XXXX ( XXXX ), XXXX XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ) Servicing Subsidiary Implements accounting and fund allocation policies XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX Operating Arm Executes collection and ledger activity XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX Provides filing cover and opinion letters XXXX XXXX XXXX ( XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX XXXX XXXX ) Investor Syndicate Profits from inflated earnings XXXX, XXXX XXXX, XXXX, XXXX, XXXX XXXX, XXXX, XXXX XXXX XXXX. Statutory Violations and XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX C.F.R. XXXX ( c ) ( XXXX ) ; XXXX U.S.C. XXXX ( a ) ( XXXX ) ( A ) XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) Payments diverted into unapplied accounts ; late fees assessed contrary to XXXX XXXX XXXX Failure XXXX C.F.R. XXXX XXXX XXXX Bank XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX. XXXX XXXX ) Ignored or false responses ( wrong company ) to RESPA notices. XXXX XXXX XXXX XXXX. XXXX ( a ), XXXX ( a ) ( XXXX ) ( B ) CFPB XXXX XXXX XXXX Bank XXXX. ( XXXX XXXX XXXX ) False statements of delinquency and corporate responsibility. Mail / XXXX XXXX XXXX U.S.C. XXXX, XXXX XXXX v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ) XXXX of fraudulent statements and records through interstate channels. Bank XXXX XXXX XXXX. XXXX United States v. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Diversion of mortgage payments to internal pools to inflate revenue. False SEC Disclosures XXXX U.S.C. XXXX ; XXXX U.S.C. XXXX SEC XXXX XXXX, XXXX XXXX XXXX ( C.D. XXXX. ) Certifying filings omitting subsidiary liabilities and CFPB exposure. Extortion ( XXXX XXXX ) XXXX U.S.C. XXXX United States v. Enmons, XXXX XXXX XXXX ( XXXX ) Foreclosure threats despite acknowledged funds ; coercive collection. Obstruction of XXXX XXXX U.S.C. XXXX XXXX v. XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Concealment of violations after CFPB / TNDFI notice. XXXX XXXX XXXX U.S.C. XXXX ( d ) H.J. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ; United States XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( D.D.C. XXXX ) Coordinated enterprise across subsidiaries and agents for ongoing fraudulent gain. IV. XXXX XXXX and XXXX Closed-ended continuity : XXXX repetitive predicate acts ( payment misallocation, false notices, threats ). Open-ended continuity : Enterprise structure persists, creating ongoing risk to consumers and markets. Each act satisfies the pattern of racketeering activity under XXXX, XXXX. v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ). Insider Trading and Certifier Liability Matrix Integrated Legal Interpretation Tier XXXX XXXX XXXX XXXX ( Parent Entity ) XXXX XXXX XXXX XXXX XXXX Form XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} {$1.00} XXXX value. XXXX : XXXX XXXX XXXX XXXX ( XXXX ) : Converted Class B Profit Units to cash during active concealment of NewRez/Shellpoint liabilities ; violates Rule XXXX, SOX XXXX, and XXXX where certifiers profit from materially misstated consolidated results. XXXX XXXX XXXX Chief Financial XXXX Form XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares + XXXX Class B Profit Unit tranches @ {$11.00} {$1.00} XXXX. Enrichment ( XXXX ) : Granted equity based on overstated servicing-segment earnings ; as CFO and SOX certifier, bears primary liability under SEC v. XXXX, XXXX XXXX XXXX. XXXX XXXX ( S.D.N.Y. XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00}. Enrichment ( XXXX ) : Oversaw subsidiary legal reporting ; participated in filing false SEC certifications while supervising ongoing RESPA and XXXX XXXX violations direct predicate acts under XXXX U.S.C. XXXX ( XXXX ) ( XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Benefited from director-stock issuance while subsidiary revenues were inflated through improper capitalization of unapplied mortgage payments. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Timing aligns with inflated XXXX XXXX earnings attributed to the Servicing segment, satisfying the XXXX v. XXXX XXXX inference of scienter for XXXX actions. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Profited from compensation plan executed during known violations of XXXX C.F.R. XXXX ( c ) ( XXXX ) ( payment-crediting ). XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Stock granted within XXXX days of CFPB escalation regarding NewRez payment allocationwillful ignorance sufficient for reckless misrepresentation liability. XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( AIF XXXX XXXX XXXX ). XXXX ( XXXX ) : Equity award contemporaneous with Shellpoints classification of unapplied-funds income as revenueconstitutes unjust enrichment under XXXX ( XXXX ) of Restitution XXXX. Tier XXXX NewRez LLC ( Servicing Subsidiary ) Corporate Officers : XXXX XXXX ( XXXX ), XXXX XXXX ( Head of Originations ), XXXX XXXX ( Head of Servicing ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( Chief XXXX & XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ). Liability Vector : Each participated in or benefited from deferred-compensation plans indexed to XXXX stock appreciation, which was artificially supported by revenue from unlawfully retained borrower payments. Violations include XXXX C.F.R. XXXX ( b ) ( XXXX ) ( failure to correct payment-posting errors ) and XXXX U.S.C. XXXX ( k ) ( servicer duties ). Precedents : XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) ; XXXX XXXX XXXX Mortgage XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) both holding servicers liable for misallocation and misrepresentation of payments. Tier XXXX Shellpoint Mortgage Servicing ( NewRez Operating Arm ) Key Executives : XXXX XXXX ( XXXX ), XXXX XXXX ( Co-CEO ), XXXX XXXX ( VP Recovery ), XXXX XXXX ( VP Servicing Strategy & Process Improvement ), XXXX XXXX ( XXXX Bankruptcy ), XXXX XXXX ( XXXX XXXX ), XXXX XXXX ( XXXX Loss Mitigation ), XXXX XXXX ( XXXX XXXX Analytics ). XXXX XXXX : Performance bonuses tied to cash-flow throughput metrics incorporating unapplied-funds balancesdirectly contravening XXXX C.F.R. XXXX ( c ) ( XXXX ) ( payment-application rule ) and XXXX C.F.R. XXXX ( XXXX ) ( error-resolution ). Such actions further qualify as predicate acts of mail and wire fraud under XXXX U.S.C. XXXX and XXXX, sustaining XXXX jurisdiction ( Sedima v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ). XXXX XXXX XXXX XXXX. Consolidation under XXXX ASC XXXX : XXXX XXXX certifies the financials of NewRez and Shellpoint, creating joint and several responsibility for any misstatement. XXXX. False Wrong Company Responses : constitute willful misrepresentation under XXXX XXXX. XXXX and deceptive-practices violations of XXXX U.S.C. XXXX ( CFPB XXXX authority ). XXXX. Investor Reliance : Each insider sale occurred after the deceptive wrong company filings were issued to regulatorsevidence of knowledge and motive consistent with SEC XXXX Texas XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). XXXX. Pattern of XXXX : At least XXXX predicate acts ( mail fraud, wire fraud, securities fraud ) within 10 years satisfy XXXX U.S.C. XXXX ( XXXX ). Regulatory and Civil Exposure CFPB Complaints ( XXXX Filed XXXX ) : Demonstrate systemic failure to apply payments, issue XXXX acknowledgments, or correct errors within statutory deadlines. Tennessee XXXX Inquiry : Triggers multi-jurisdictional enforcement ; pattern meets criteria for referral under XXXX U.S.C. XXXX ( c ) ( XXXX ) and XXXX ( XXXX ). DOJ Exposure : Possible criminal referral for mail/wire fraud and obstruction of agency proceedings under XXXX U.S.C. XXXX. Damages and Relief Economic Loss : $ XXXX in unapplied funds and ledger distortion. Punitive and Statutory Damages : {>= $1,000,000} under RESPA XXXX ( f ) and XXXX XXXX ( c ). Emotional and Credit Damage : Resulting from false delinquency and threat letters while account was current. V. Regulatory Misrepresentation Wrong Company Defense XXXX and NewRez routinely responded to CFPB and XXXX complaints claiming wrong company. SEC filings prove 100 % ownership and consolidation of Shellpoint revenues. Statutory Exposure : XXXX U.S.C. XXXX ( k ) ( XXXX ) ( C ) ( RESPA misrepresentation ) XXXX C.F.R. XXXX ( XXXX ) ( XXXX ) ( i ) ( failure to provide substantive response ) XXXX U.S.C. XXXX ( b ) ; XXXX C.F.R. XXXX ( false material statement to investors ) XXXX U.S.C. XXXX ( false statement to federal agency ) XXXX U.S.C. XXXX ( SOX criminal certification liability ) Interpretation : The defense constitutes a knowing attempt to evade federal jurisdiction and maintain enrichment through false corporate distinctionqualifying as a XXXX predicate under XXXX ( XXXX ) ( B ). VI. Insider Trading & Certifier Liability Matrix Distribution and XXXX XXXX Investor XXXX XXXX XXXX Investor and XXXX XXXX XXXX XXXX and XXXX XXXX XXXX XXXX XXXX XXXX {$750.00} XXXX At-the-Market ( ATM ) Equity Offering, as disclosed in its Form XXXX ( XXXX XXXX XXXX ), enumerated XXXX co-managing sales agents and underwriters. Each agent acted under contractual authority to sell shares from time to time on XXXX behalf into the open market. These entities, and the individual officers identified below, were directly notified of the ongoing allegations of securities falsification and servicing-based enrichment. Their continued participation following notice creates exposure under XXXX U.S.C. XXXX ( d ) ( XXXX conspiracy ), XXXX U.S.C. XXXX ( a ) ( control-person liability ), and XXXX ( XXXX ) of XXXX XXXX ( b ) ( knowing participation in tortious conduct ). Institution / XXXX Affiliation Function in Enterprise Legal Exposure XXXX XXXX XXXX XXXX XXXX. Co-Manager / Sales Agent Received and executed XXXX ATM equity sales under XX/XX/XXXX Form XXXX ; notified of servicing-fraud exposure. XXXX U.S.C. XXXX ( wire fraud ), XXXX ( d ) ( XXXX conspiracy ) XXXX XXXX XXXX XXXX XXXX. Co-Manager/ XXXX XXXX Participated in continuing ATM program following CFPB escalation; acted despite knowledge of violations. XXXX U.S.C. XXXX ( money laundering ), XXXX ( d ) XXXX XXXX XXXX XXXX Distribution Agent Executed trades benefiting from inflated Rithm earnings derived from NewRez/Shellpoint revenues. XXXX U.S.C. XXXX ( b ) ; XXXX C.F.R. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Coordinated sales while institution simultaneously held investment interests in XXXX XXXX trusts. XXXX U.S.C. XXXX ( d ) ; XXXX U.S.C. XXXX XXXX XXXX XXXX XXXX XXXX XXXX Distribution Agent Processed transactional filings under identical metadata ; complicit in resale of tainted securities. XXXX U.S.C. XXXX ( securities fraud ) XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Co-Manager Received investor notice documenting enforcement risk; failed to halt program. XXXX U.S.C. XXXX ( d ) ; XXXX U.S.C. XXXX J.T. XXXX XXXX XXXX XXXX XXXX Co-Manager Continued capital-raising activities after notice ; integrated illicit revenue streams. XXXX U.S.C. XXXX, XXXX ( d ) XXXX XXXX XXXX XXXX XXXX XXXX Co-Manager Accepted direct written notification of scheme ; distributed proceeds via ATM sales. XXXX U.S.C. XXXX ( a ) ( XXXX ) ( B ) ( i ) ; XXXX ( d ) Underwriter / Enrichment Layer Under the XX/XX/XXXX {$750.00} XXXX ATM XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) XXXX XXXX ( XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX. XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX ) Interpretation Each of these XXXX named officers served under institutions explicitly listed in Rithm Capitals XX/XX/XXXX Form XXXX ( Exhibit XXXX ) as sales agents for the {$750.00} XXXX ATM equity program. Because they were directly copied on communications documenting the servicing and accounting fraud, their subsequent participation satisfies the knowing agreement standard under XXXX U.S.C. XXXX ( d ) ( United States v. XXXX, XXXX XXXX XXXX ( XXXX ) ; XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ). Shellpoint Mortgage Servicing XXXX Layer Operational Arm of Enterprise Finding Shellpoint Mortgage Servicing ( SMS ), a division operating under the NewRez LLC license, functions as the servicing apparatus for XXXX XXXX XXXX Its executives and department heads directly executed the borrower-facing misconduct that generated unlawful cash-flow inflations later consolidated into Rithms reported earnings. Shellpoints personnel acted as the functional endpoint of the enterprise, producing the predicate acts of mail, wire, and accounting fraud that sustained the parent corporations securities gains. Evidence Internal call transcripts ( XXXX XXXX ) and CFPB complaint filings document continuous misapplication of payments, concealment of unapplied funds exceeding {$100000.00}, and issuance of deceptive delinquency communications while accounts were current. These actions were performed under the authority of Shellpoints servicing leadership and recorded within NewRez-branded portals. Title Name Primary Role Liability Nexus / Predicate Act XXXX XXXX XXXX Dual-hatted XXXX across NewRez and Shellpoint. Authorized application of borrower payments into suspense to inflate servicing liquidity ; predicate act under XXXX U.S.C. XXXX ( wire fraud ). XXXX XXXX XXXX XXXX sign-off on payment-application policy. Endorsed wrong company response protocol to CFPB inquiries ; violation of XXXX U.S.C. XXXX ( false statements ). XXXX XXXX XXXX XXXX, XXXX Oversaw collections and foreclosure pipeline. XXXX issuance of automated foreclosure threats while unapplied funds existedconstituting attempted extortion and unfair practice under XXXX U.S.C. XXXX ( a ). XXXX XXXX XXXX, Servicing Strategy & Process Improvement Engineered data-processing schema linking NewRez and Shellpoint systems. Enabled cross-system data manipulation that disguised unapplied-funds totals ; breach of XXXX C.F.R. XXXX ( c ) ( XXXX ) ( crediting of payments ). XXXX XXXX XXXX, Bankruptcy Managed borrower accounts under bankruptcy protection. Failed to apply post-petition payments timely, violating XXXX U.S.C. XXXX ( i ) and RESPA XXXX ( k ). XXXX XXXX XXXX, XXXX XXXX escrow and hazard-insurance remittances. Misallocated escrow surpluses into suspense accounts, creating false delinquency records. XXXX XXXX XXXX, XXXX XXXX XXXX loan-modification pipeline. Concealed payment re-application tasks confirmed complete in call logs ; violation of XXXX C.F.R. XXXX ( loss-mitigation process ). XXXX XXXX XXXX, XXXX XXXX XXXX for performance and audit metrics. Produced internal metrics rewarding retention of unapplied balances ; foundational to Rithms inflated cash-flow throughput. XXXX XXXX leadership orchestrated a servicing model that contravened federal consumer-finance statutes while enriching parent executives through distorted earnings. The call-record evidence establishes knowledge and pattern : each agent acknowledged unapplied funds, confirmed payments, and yet continued delinquency reporting. Key precedents amplify liability : XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) : servicer liability for misapplied payments under RESPA XXXX ( f ). Marais v. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) : failure to investigate borrower disputes constitutes independent damages. XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) : repetitive misapplication satisfies pattern for treble damages. These rulings establish that each missed correction and false delinquency notice is a discrete statutory violation and XXXX predicate. When multiplied across tens of thousands of loans serviced under the same scheme, XXXX acts become the operational backbone of a XXXX ( c ) racketeering enterprise. XXXX XXXX XXXX. Criminal Exposure : Continuous misrepresentations to borrowers and regulators satisfy mail- and wire-fraud predicates ( XXXX U.S.C. XXXX, XXXX ) and false-statement liability ( XXXX ). XXXX. Civil Damages : Each RESPA error-resolution failure carries per-violation statutory damages up to {$2000.00} per borrower, multiplied across portfoliosplus treble recovery under XXXX XXXX ( c ). XXXX. Regulatory Sanctions : CFPB and Tennessee XXXX possess concurrent jurisdiction ; patterns mirror prior enforcement in In re XXXX XXXX, File No. XXXX. XXXX. XXXX XXXX : Shellpoints manipulation of ledgers directly increased XXXX XXXX reported earnings, establishing parent-subsidiary unity under XXXX XXXX XXXX and negating any separate-entity defense. XXXX. Damages Quantification : Current documented loss {$100000.00} in unapplied funds plus consequential and punitive damages of {$5.00} millionconstitutes both individual injury and representative harm warranting class treatment. Expanded Enterprise Roster NewRez LLC Leadership Layer Finding NewRez LLC operates as a wholly owned subsidiary of XXXX XXXX XXXX, functioning as the parents licensed mortgage originator and primary residential loan servicer. Despite public separation rhetoric, XXXX officers report upward to the XXXX XXXX XXXX committee, participate in the same deferred-compensation pool, and certify ledger data ultimately consolidated in XXXX XXXX and XXXX filings. Evidence Metadata from the SEC XXXX prospectus and NewRez organizational materials confirms direct hierarchical and financial integration between XXXX and its subsidiaries ( XXXX XXXX, XXXX ). Internal filings and CFPB complaint responses further reveal that all operational communications from Shellpoint Mortgage Servicing route through XXXX systems. Title Name Primary Role Liability Nexus / XXXX XXXX XXXX XXXX XXXX XXXX approval authority for all Servicing and Originations revenue reports. Authorized subsidiary attestations underpinning overstated cash-flow ratios used in XXXX equity-based XXXX formulastriggering exposure under XXXX U.S.C. XXXX ( b ) and XXXX C.F.R. XXXX. XXXX XXXX XXXX of XXXX XXXX broker and lender channels. Tied to improper cross-posting of fees into Servicing income lines, contravening XXXX C.F.R. XXXX ( d ). XXXX XXXX XXXX of XXXX / XXXX of Shellpoint XXXX role across entities. Maintained systems that converted unapplied borrower payments into cash-flow throughput performance metrics ; predicate acts under XXXX XXXX. XXXX ( wire fraud ). XXXX XXXX XXXX XXXX XXXX XXXX of servicing policy and data management. Failure to maintain XXXX error-resolution workflow in violation of XXXX C.F.R. XXXX ( XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX reporting to XXXX XXXX enterprise analytics. Participation in consolidated reporting that ignored regulatory exposure, violating XXXX XXXX XXXX XXXX XXXX known trends and uncertainties ). XXXX XXXX XXXX XXXX & XXXX XXXX Provided internal certification to XXXX XXXX. Contributed to wrong company CFPB responses while acknowledging consolidated ownershipconstituting XXXX U.S.C. XXXX ( false statements ). XXXX XXXX XXXX XXXX XXXX XXXX subsidiary ledgers for consolidation. XXXX manipulated unapplied-funds balances ; liable under SOX XXXX XXXX and SEC v. XXXX XXXX XXXX XXXX. XXXX XXXX XXXX XXXX XXXX Managed cross-platform data link between NewRez and Shellpoint portals. Authorized data structures that misrepresented payment status, violating XXXX U.S.C. XXXX ( k ). XXXX XXXX XXXX XXXX XXXX Responsible for growth and partnership revenue. Benefited through incentive structures indexed to inflated cash-realization metrics. XXXX XXXX XXXX XXXX XXXX XXXX borrower-communication campaigns. Approved misleading account current messaging while internal ledgers showed unapplied balancesUDAAP breach under XXXX U.S.C. XXXX. XXXX XXXX XXXX XXXX XXXX XXXX bonus pool and performance metrics. Distributed incentive pay derived from illegal income recognition, satisfying the financial gain element under XXXX U.S.C. XXXX ( XXXX ) ( B ) ( XXXX ). Interpretation Each XXXX occupied a node in the servicing data chain that transformed borrower payments into revenue and bonus metrics. The identical timing between their internal certifications and Rithms XXXX XXXX insider-trading window supports the inference of coordinated knowledge and profit motive ( XXXX XXXX XXXX XXXX & Rights, XXXX XXXX XXXX XXXX XXXX ) ). Under XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ), servicers are directly liable for failure to investigate and correct payment errors regardless of parent directives. Because XXXX consolidates NewRez results, every misapplied dollar inflates parent earningsbinding both tiers under XXXX ASC XXXX and SOX certification liability. XXXX XXXX XXXX. Regulatory Exposure : Repeated breaches of RESPA XXXX ( k ) and TILA XXXX expose both NewRez and XXXX to CFPB XXXX and DOJ referral. XXXX. Civil Exposure : Pattern of misapplied payments and false delinquency threatens class-action replication ( Rawlings v. XXXX Mortgage XXXX XXXX XXXX ). XXXX. XXXX XXXX : Coordinated enrichment through data manipulation and insider sales sustains a XXXX XXXX ( c ) enterprise theory with predicate acts of wire fraud, mail fraud, and securities fraud. XXXX. Investor XXXX : Earnings distortion and insider disposition reduce investor confidence, aligning with the reckless disregard standard in XXXX re XXXX XXXX XXXX, XXXX. XXXX. XXXX XXXX and XXXX XXXX {$100000.00} in payments documented as unapplied in violation of XXXX C.F.R. XXXX ( c ) ( XXXX ). Psychological and financial harm from false delinquency and foreclosure threats. Material credit damage and increased interest costs. Aggregate enterprise enrichment through inflated servicing income and XXXX","date_sent_to_company":"2025-11-08T20:10:51.000Z","issue":"Trouble during payment process","sub_product":"VA mortgage","zip_code":"37066","tags":"Servicemember","has_narrative":true,"complaint_id":"17114085","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Shellpoint Partners, LLC","date_received":"2025-11-08T20:01:57.000Z","state":"TN","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Payment process"},"highlight":{"complaint_what_happened":["Md. ), borrowers alleged that Shellpoint systematically failed to provide required notices under the <em>Real</em> <em>Estate</em> Settlement Procedures Act ( RESPA ) and imposed fees in violation of the Maryland Consumer Debt Collection Act and the Maryland XXXX XXXX XXXX. 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