{"took":215,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":4,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"12342459","_score":25.184074,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"This is a follow-up complaint against Experian, outlining additional violations and misconduct beyond what was previously reported. Experian has escalated its illegal activities by engaging in fraudulent credit reporting, obstruction of justice, racketeering ( RICO violations ), and securities fraud.\n\nAfter my initial arbitration filing and CFPB complaint, Experian has continued to manipulate my credit report in an attempt to conceal prior fraudulent actions. The company has committed new violations that include : Re-Aging of Debt to Extend Negative Reporting Beyond Legal Limits Experian has continued to update old accounts falsely, making them appear newer than they are. \n\nThis is a direct violation of 15 U.S.C. 1681c ( a ) under the Fair Credit Reporting Act ( FCRA ).\n\nFraudulent Deletion & Silent Modification of Accounts Experian has secretly removed certain negative items after my arbitration filing to cover up its previous misconduct. \n\nHowever, they have left other false negative items intact, selectively modifying data to deceive regulators and avoid accountability. \n\nThis is obstruction of justice and an attempt to manipulate evidence post-arbitration filing. \n\n\nRacketeering ( RICO ) Violations Coordinated Fraudulent Credit Reporting Experian, in collusion with XXXX and XXXX, has operated as a criminal enterprise by systematically reporting false, outdated, or re-aged debts to benefit lenders and collection agencies. \n\nExperian has financially gained from this fraudulent behavior by partnering with financial institutions that profit from higher interest rates and loan denials based on inflated risk. \n\nThese actions constitute a violation of the Racketeer Influenced and Corrupt Organizations Act ( RICO ), 18 U.S.C. 1962. \n\n\nSecurities Fraud Insider Trading & Financial Manipulation Experian executives sold off company stock immediately after my arbitration case was filed in XX/XX/XXXX, which exposed their fraudulent reporting practices. \n\nThis indicates insider trading, as the executives had knowledge of an impending financial risk due to regulatory scrutiny. \n\nThese stock sales are a violation of SEC rules on insider trading and securities fraud. \n\n\nFailure to Investigate & Retaliatory Practices Against Consumers Experian has repeatedly failed to provide verification for debts reported on my credit file, violating 15 U.S.C. 1681i ( a ) of the FCRA.\n\nInstead of correcting errors, Experian has engaged in deceptive tactics to block consumers from accessing their credit reports and filing disputes. \n\nThis is a clear violation of consumer rights and regulatory compliance obligations. \n\n\nHarm & Damages Experians systematic fraud, obstruction of justice, and financial misconduct have caused me severe financial harm, emotional distress, and damage to my creditworthiness, including : Denial of Mortgage, Loan, and Credit Opportunities due to fraudulent Experian reporting.\n\nIncreased Interest Rates & Higher Insurance Premiums caused by Experians false data.\n\nRestricted Access to Credit File & Dispute ProcessExperian has prevented me from properly monitoring or correcting my credit information.\n\nLong-Term Financial ConsequencesLenders, employers, and insurers rely on Experians fraudulent reporting to make decisions","date_sent_to_company":"2025-03-07T05:44:16.000Z","issue":"Incorrect information on your report","sub_product":"Credit reporting","zip_code":"55113","tags":null,"has_narrative":true,"complaint_id":"12342459","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Experian Information Solutions Inc.","date_received":"2025-03-07T05:28:22.000Z","state":"MN","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Account information incorrect"},"highlight":{"complaint_what_happened":["Securities <em>Fraud</em> <em>Insider</em> <em>Trading</em> & Financial <em>Manipulation</em> Experian executives sold off company stock immediately after my arbitration case was filed in XX/XX/XXXX, which exposed their fraudulent reporting practices. \n\nThis indicates <em>insider</em> <em>trading</em>, as the executives had knowledge of an impending financial risk due to regulatory scrutiny. \n\nThese stock sales are a violation of SEC <em>rules</em> on <em>insider</em> <em>trading</em> and securities <em>fraud</em>."]},"sort":[25.184074,"12342459"]},{"_index":"complaint-public-v1","_id":"9981445","_score":19.00127,"_source":{"product":"Credit card","complaint_what_happened":"I applied my credit to an application using my social security card for a charge card with American Express. \n\nAccording to Title 15 U.S.C 1602 ( I ) the term credit card means any card, plate, coupon book, or other credit device existing for the purpose of obtaining money, property, labor, or services on credit. Any card pertains to a social security card. Which classifies a credit card application denial or adverse action as an \" unauthorized use '' of a credit card due to them using the \" card '' to obtain money, property, labor, or services, but not allowing me to do the same.\n\nAccording to 12 CFR 360.6 ( 2 ) the credit application is a \" FINANCIAL ASSET '' that I have \" interest '' in, which they state in their letter that they received \" interest '' from me.\n\n\" Financial Asset '' means cash or a contract or instrument that conveys to one entity a contractual right to receive cash or another financial instrument from another entity.\n\nI have a contractual right to receive a financial instrument from American Express, like a credit device ( charge card ) existing for the purposes of obtaining money, property, labor, or services on credit.\n\nMy credit application is also considered SELF-LIQUIDATING PAPER according to 17 CFR 260.11 b-6. The term self-liquidating paper, as used in section 311 ( b ) ( 6 ) of the Trust Indenture Act, means any draft, bill of exchange, acceptance or obligation which is made, drawn, negotiated or incurred by the obligor for the purpose of financing the purchase, processing, manufacture, shipment, storage or sale of goods, wares or merchandise and which is secured by documents evidencing title to, possession of or a lien upon the goods, wares or merchandise or the receivables or proceeds arising from the sale of the goods, wares or merchandise previously constituting the security : Provided, The security is received by the trustee simultaneously with the creation of the creditor relationship with the obligor arising from the making, drawing, negotiating or incurring of the draft, bill of exchange, acceptance or obligation. It is my belief that the receivables or proceeds from the sale of my application ( goods ) constitutes a security, which may also be the reason my reference number, \" XXXX '', is in the form of a monetary value. WHY IS THERE A \" USD '' AT THE END OF THIS NUMBER IF THERE IS NO VALUE TO THE INSTRUMENT WHICH CREATED IT? \nSerious Question. \n\nThe ADVERSE ACTION is in violation of the following : 15 U.S.C 78j... Rules promulgated under subsection ( b ) that prohibit fraud, manipulation, or insider trading ( but not rules imposing or specifying reporting or recordkeeping requirements, procedures, or standards as prophylactic measures against fraud, manipulation, or insider trading ), and judicial precedents decided under subsection ( b ) and rules promulgated thereunder that prohibit fraud, manipulation, or insider trading, shall apply to security-based swap agreements to the same extent as they apply to securities. Judicial precedents decided under section 77q ( a ) of this title and sections 78i, 78o, 78p, 78t, and 78u1 of this title, and judicial precedents decided under applicable rules promulgated under such sections, shall apply to security-based swap agreements to the same extent as they apply to securities.\n\n15 U.S.C. 78ff a ) Willful violations ; false and misleading statements Any person who willfully violates any provision of this chapter ( other than section 78dd1 of this title ), or any rule or regulation thereunder the violation of which is made unlawful or the observance of which is required under the terms of this chapter, or any person who willfully and knowingly makes, or causes to be made, any statement in any application, report, or document required to be filed under this chapter or any rule or regulation thereunder or any undertaking contained in a registration statement as provided in subsection ( d ) of section 78o of this title, or by any self-regulatory organization in connection with an application for membership or participation therein or to become associated with a member thereof which statement was false or misleading with respect to any material fact, shall upon conviction be fined not more than {>= $1,000,000}, or imprisoned not more than 20 years, or both, except that when such person is a person other than a natural person, a fine not exceeding {>= $1,000,000} may be imposed ; but no person shall be subject to imprisonment under this section for the violation of any rule or regulation if he proves that he had no knowledge of such rule or regulation.\n\n15 U.S.C 1602 ( I ) 15 U.S.C 1691 ( a ) ( 3 ) It shall be unlawful for any creditor to discriminate against any applicant, with respect to any aspect of a credit transaction because the applicant has in good faith exercised any right under this chapter.\n\n18 U.S.C. 241 If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same ; They shall be fined under this title or imprisoned not more than ten years, or both ; and if death results from the acts committed in violation of this section or if such acts include XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  they shall be fined under this title or imprisoned for any term of years or for life, or both, or may be sentenced to death.\n\n18 U.S.C. 242.\n\nWhoever, under color of any law, statute, ordinance, regulation, or custom, willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, on account of such person being an alien, or by reason of his color, or race, than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned not more than one year, or both ; and if bodily injury results from the acts committed in violation of this section or if such acts include the use, attempted use, or threatened use of a dangerous weapon, explosives, or fire, shall be fined under this title or imprisoned not more than ten years, or both ; and if death results from the acts committed in violation of this section or if such acts include XXXX  or an XXXX XXXX XXXX XXXX XXXX XXXX or an XXXX XXXX XXXX XXXX XXXX XXXX or an XXXX XXXX XXXX, shall be fined under this title, or imprisoned for any term of years or for life, or both, or may be sentenced to death.\n\nNon-Discrimination in Credit Granting : As per the Equal Credit Opportunity Act, Title 15, Section 1691, your institution is legally bound not to deny credit based on race, color, religion, national origin, sex, marital status, age, or source of income. This Act underscores the principle of equal access to credit for all consumers, thereby cultivating a fair and non-discriminatory financial marketplace.\n\nI sent a letter to address/express the crucial consumer rights and safeguards that are relevant to credit transactions.\n\nThese are enshrined in Title 15 of the United States Code, the Truth in Lending Act ( TILA ), the Fair Credit Reporting Act ( FCRA ), Generally Accepted Accounting Principals ( GAAP ), the Servicemembers Civil Relief Act ( SCRA ), the Fair Debt Collection Practices Act ( FDCPA ), the Credit Card Act of 2009, Law Merchant, the Privacy Act of 1974, the Uniform Commerical Code ( UCC ), among other pivotal laws, regulations, and case law.\n\nLimitations on the Use of Credit Reports : As stipulated by the FCRA, Title 15, Sections 1681-1681x, only information from my credit application can be used to evaluate my creditworthiness. A violation occurs if my credit reports are used unjustly to deny credit, thereby ensuring a fair assessment of my ability to repay any credit extended.\n\n15 USC 1681a ( 2 ) Exclusions says that Except as provided in paragraph ( 3 ), the term consumer report does not include any authorization or approval of a specific extension of credit directly or indirectly by the issuer of a credit card or similar device ; although the reason for the denial states, and I quote, \" We were unable to get your consumer credit score from the agency ( ies ) listed at the end of this letter. '' Non-adherence to TILA or Title 15 provisions can result in substantial penalties as defined in Title 15, Section 1640- Civil Liability. These penalties may include compensation for actual damages suffered by the consumer due to the violation, statutory damages of up to { {$4000.00} } in individual actions or a sum equal to the lesser of { >= {>= $1,000,000} } or 1 % of the creditors net worth in class actions, and the recovery of the actions cost and attorneys fees.\n\nIn light of these protections, I respectfully request that American Express strictly adhere to these regulatory provisions, statutory requirements, and established case law proceedings during our financial engagements.\n\nThese legal guidelines are designed to uphold the integrity of the consumer credit market and shield consumers like me from potentially harmful financial practices.\n\nIn particular, the unjustifiable denial of credit infringes upon the Equal Credit Opportunity Act ( ECOA ), which outlaws credit discrimination.\n\nFurthermore, inappropriate use of personal information, such as Social Security Numbers, in credit decisions contravenes the Privacy Act of 1974 and the Fair Credit Reporting Act ( FCRA ).\n\nUnder the principles of Generally Accepted Accounting Principles ( GAAP ), the Law Merchant, and the Uniform Commercial Code ( UCC ), transparency and fairness are fundamental to all credit transactions.\n\nThank you for your attention to this significant matter. I anticipate engaging in fair, transparent, and lawful credit transactions. \n\nTHIS CONSTITUTES MY NOTICE OF ADVERSE CLAIM! \nTHIS CONSTITUTES MY NOTICE OF ADVERSE CLAIM!! \nTHIS CONSTITUTES MY NOTICE OF ADVERSE CLAIM!!! \n\nAS A REMINDER : DENIAL OF CREDIT IS INTERFERENCE WITH COMMERCE AND USING A CREDIT REPORT TO DENY ME CREDIT IS INTERFERENCE WITH COMMERCE!!","date_sent_to_company":"2024-08-31T00:28:26.000Z","issue":"Getting a credit card","sub_product":"General-purpose credit card or charge card","zip_code":"19013","tags":null,"has_narrative":true,"complaint_id":"9981445","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"AMERICAN EXPRESS COMPANY","date_received":"2024-08-30T23:25:04.000Z","state":"PA","company_public_response":null,"sub_issue":"Application denied"},"highlight":{"complaint_what_happened":["<em>Rules</em> promulgated under subsection ( b ) that prohibit <em>fraud</em>, <em>manipulation</em>, or <em>insider</em> <em>trading</em> ( but not <em>rules</em> imposing or specifying reporting or recordkeeping requirements, procedures, or standards as prophylactic measures against <em>fraud</em>, <em>manipulation</em>, or <em>insider</em> <em>trading</em> ), and judicial precedents decided under subsection ( b ) and <em>rules</em> promulgated thereunder that prohibit <em>fraud</em>, <em>manipulation</em>, or <em>insider</em> <em>trading</em>, shall apply to security-based swap agreements to the same extent as they apply to"]},"sort":[19.00127,"9981445"]},{"_index":"complaint-public-v1","_id":"17114085","_score":10.89143,"_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":["XXXX XXXX : Coordinated enrichment through data <em>manipulation</em> and <em>insider</em> sales sustains a XXXX XXXX ( c ) enterprise theory with predicate acts of wire <em>fraud</em>, mail <em>fraud</em>, and securities <em>fraud</em>. XXXX. Investor XXXX : Earnings distortion and <em>insider</em> 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 )."]},"sort":[10.89143,"17114085"]},{"_index":"complaint-public-v1","_id":"3344343","_score":7.231249,"_source":{"product":"Debt collection","complaint_what_happened":"Dear CFPB :\n\nPlease find this Amended Complaint; Qualified Written Request; Validation of Debt; and Request for Adequate Assurance from Bank of America  (“BOA”) and XXXX XXXX, Inc. (XXXX XXXX”) aka XXXX  XXXX XXXX   (“XXXX”) for their mortgage fraud; fraud with XXXX XXXX securities; forgery; unlawful collection  and violations of all possible laws. \n\nWhile BOA’s sham conduit XXXX  XXXX XXXX, XXXX  (“XXXX”) who pretend to be “owner/investor” (now merely “servicer”) repeatedly stated that I have right to dispute my debt, at the same time they deprived me from  this right  and now illegally  try to accelerate my payments by threats  with a foreclosure – without proper validation or any Assurances, solely based on a poorly forged by XXXX XXXX Allonge to the Note (without any endorsements) where XXXX is not even mentioned. BOA relentless fraud, extortion  and scary tactic placed me under extreme emotional distress which caused severe damages to my health condition since I have to take strong pain killers and sleep medication because I lost my night sleep dealing with BOA and their co-conspirators criminal conduct and violations of all laws.  \n\nI received additional evidence from  XXXX which  clearly indicates that neither XXXX or XXXX are not the real party who actually own my debt but rather fake conduits for Bank of America who illegally cashing my mortgage payment checks without guaranteeing that upon completion of my loan I will successfully own my title. This evidence also shows that my “lender” is simply a front for BoA whose ultimate goal with my loan is to push me into foreclosure through murky collection practices and fees while the bank enriches itself through reselling my loan through securities known as CDO (derivatives). \n\nThis evidence further shows that my performing loan was internally defaulted by BOA to illegally remove it from XXXX  XXXX custody by abusing a XXXX XXXX rule that give issuers the option to buy back their loans if the loans are 90 days delinquent or more; and resell for profits . \n\nBoth XXXX  and XXXX  merely  impersonate as \"servicer\" and \"owners/investors\" to defraud me about the real identity of the party – BOA - who collects my mortgage payments as their handsome income  while they want me to think I repay the debt to legitimate investors; as well as about the real party who sends me threatening Notices – XXXX  XXXX. \n\nMy conclusion is based on  XXXX  respond  on XX/XX/XXXX where they sent me a copy of poorly forged Alonge to the Note which lacked any chain of Assignments in violation of all applicable laws; and threatened me with a Payoff demand – while I never refused to pay my mortgage to the  lawful owners of my debt as soon as the debt is validated. \n\nPlus, it appears that onXX/XX/XXXX XXXX   promptly changed its payment mailing address from XXXX XXXX XXXX  XXXX  TX to XXXX XXXX  XXXX, XXXX XXXX   CA, so I don’t even know where my mortgage payments should be mailed and who actually collected them in XXXX, TX where neither XXXX or XXXX  have no officers nearby. \n\nOn XX/XX/XXXX I emailed  a Complaint to Michigan Senator XXXX  asking for help and intervention. I included in this email Bank of America’s top executives. \n\nThe very same day,XX/XX/XXXX XXXX,  who during last three months  was not able to located any documents related to my loan,  suddenly \"found\" the whole closing package (!) which was emailed to them by someone else ( XXXX  XXXX) via large PDF file. \n\nYou can see from the attached documents, the top and the bottom of each page has a line \"Generated by XXXX XXXX\" (on top); and \"click here to unlock XXXX\" (on the bottom). This PDF file was sent by someone, aka XXXX  XXXX, owned by Mr. XXXX, XXXX, who also owns XXXX. While one part of Mr. XXXX business – XXXX XXXX fka XXXX XXXX XXXX /XXXX – operates a sophisticated forgery mill of  mortgage Notes to defraud borrowers and investors; another part – XXXX   XXXX  – issues property Title insurances for fatally damaged by  XXXX XXXX Titles\n\nXXXX  mailed this  package to me by overnight XXXX   about XXXX XXXX the same day, XX/XX/XXXX, apparently without even reviewing included  documents. Bear to repeat, I requested these documents since XXXX   XXXX  and XXXX  was not able to locate it until I included Senator XXXX  into this dispute.  Otherwise they would notice that the Note is not endorsed at all; and the Allonge is very poorly forged by someone who has NO authority to sign Notes or transfer them. \n\nXXXX   merely  separated XXXXt file in two parts and put one part on front of their package - such as a  copy of my Note without ANY endorsements and a copy of a very poorly forged Allonge  prepared by XXXX  XXXX XXXX XXXX  who on XX/XX/XXXX (!) the same day as my loan was signed, passed it to XXXX XXXX XXXX   while XXXX claimed that they received it on XX/XX/XXXX. It was unclear if Mr. XXXX  worked for XXXX or XXXX   at the time when he signed Allonge  to this Note which Mr. XXXX  had no authority to sign under ANY circumstances. \n\nThis is a glaring violation of all endorsement rules, plus Collateral Shipper XXXX  (who worked for whom?) had NO authority to sign anything to XXXX, he merely must obtain an authorized signature. XXXX XXXX or any Trust was not mentioned at all, as well as Mortgagee XXXX or “owner/investor” XXXX  (who is a FAKE Servicer) . \n\nI suspect that this Allonge was  prepared on a  rush basis on the same day, XX/XX/XXXX by  – Mr. XXXX - who had no idea about anything regarding my loan -  when XXXX   received it (XX/XX/XXXX); XXXX as a mortgage, ect. Someone (aka XXXX  XXXX) merely had someone (posing  as XXXX XXXX)  to sign an obviously fraudulent document. \n\nMr. XXXX signature is not a wet ink signature and appears to be an electronically forged signature which can be placed by anybody – thus, a modernized variation of robo-signing. \n\nIn the middle of the document pile XXXX  put billing documents received probably from XXXX. The don't have PDF file on the bottom and top (see XXXX  Sequence of documents)\n\n At the end XXXXc  attached  all documents related to origination, including Appraisal, photos, ect. Total over 100 pages (speaking about \"broad and burdensome\" request to give me a name of the Trust and proof of the valid Transfer with  value paid). Obviously, XXXX  wanted to make an impression that all these documents were originally in their files and kept in  consecutive chronological order while they were obviously not. \n\n Again, the front  and back parts of these documents were the same voluminous PDF file received by XXXX  via email from XXXX  XXXX  for the first time on XX/XX/XXXX while documents in the middle came from some other sources. \n\nNone of these documents mentioned  XXXX as an \"owner/investor\" (now XXXX claims to be merely \"servicers\" while Servicers are NOT owners of the loans, thus XXXX made false statements to mislead me about their “ownership” ).\n\nHere is  no proof of any valid transfer or any value paid by XXXX to XXXX or by XXXX to XXXX from whom XXXX received my loan from XXXX via  Allonge transfer on XX/XX/XXXX while XXXX insisted that they obtained my loan from XXXX onXX/XX/XXXX.  According to endorcement rules,  must use the NOTE space first before they attach any allonges. \n\nAccording to the Rules: The note must be endorsed to each subsequent owner of the mortgage unless one or more of the owners endorsed the note in blank. The last endorsement on the note should be that of the mortgage seller. The mortgage seller must endorse the note in blank and without recourse. \n\nThe only endorsement on the Allonge is “Pay to XXXX   XXXX  XXXX, Inc without recourse” was made on XX/XX/XXXX while XXXX claimed they are next servicers who receive my loan onXX/XX/XXXX for servicing purposes and owner/investor is XXXX  XXXX. No other endorsements are  present – neither to XXXX  XXXX   although they must be listed on the Note; nor to XXXX. \n\nThe Rules also specify using an Allonge for the Endorsement.   The endorsement must appear on the note. An allonge  may be used for the endorsement as long as the following requirements are met: The form and content of the allonge used must comply with all applicable state, local, or federal law governing the use of allonges and result in an enforceable and proper endorsement to the note.  The allonge must be permanently affixed to the related note and must clearly identify the note by referencing at least the name of the borrower(s), the date of the note, the amount of the note, and the address of the security property.  The note must clearly reference the attached allonge. XXXX XXXX status as a “holder in due course” must not be impaired. \n\nOnce again, here is NOTHING on the Note referencing to XXXX  XXXX; or XXXX or Allonge itself which was prepared by collateral shipper Mr. XXXX  who does not have authority to assign any Notes. \n\nIn other words, my Note and Allonge are a glaring example of modern documents forgery committed by the same companies who flooded US Courts with forged robo-signed foreclosures. These companies changed their names to XXXX, XXXX, and XXXX XXXX but their criminal practices are the same. \n\nBear to repeat, after I asked why both servicers  - XXXX   and XXXX receive my payments in the same post Office in XXXX TX, XXXX  promptly changed payment mailing address from XXXX XXXX  in XXXX TX to XXXX XXXX  XXXX XXXX  XXXX  CA .\n\n So, where I should pay my mortgage? Why XXXX   demanded my XXXX, XXXX and XXXX payments to be mailed to XXXX TX if they don’t even have offices in TX? Whom I paid my debt when I mailed my payments to XXXX  TX?  \n\nWhen I spoke with XXXX on XX/XX/XXXX around XXXX how they  deposited   my payments (this conversation was  witnessed by XXXX banker XXXX   XXXX  who processed my check  to XXXX), XXXX   representative Mr. XXXX said that XXXX deposited it in THEIR account with Bank of America. \n\nAccording to the refund check XXXX  mailed me on XX/XX/XXXX from their Oklahoma XXXX XXXX XX/XX/XXXX XX/XX/XXXX, OK XX/XX/XXXX, this BOA location is in Georgia and routing number is XX/XX/XXXX. It does not make any sense for XX/XX/XXXXwhose place of business is in Oklahoma, to collect my payments in XX/XX/XXXX TX and issue me refunds from BOA account located in XX/XX/XXXX GA while process my payments with a different BOA location. If XX/XX/XXXX used BOA location in GA, it would be reasonable to deposit my payments on the same account. \n\nBased on XXXX XXXX  MBS Guide, my payments should be handled by a Trustee (apparently XXXX XXXX  XXXX XXXX) and distributed to XXXX XXXX investors. None of it present.\n\nBut my payments were processed by BOA in TX (where neither XXXX or XXXX  do not have any offices nearby) and Bank of Final Deposit had routing number XXXX, which belonged to XXXX XXXX XXXX   which merged with BOA\n\nThe name of the Trust is not mentioned but the XXXX XXXX pool is supposedly XXXX. XXXX XXXX pools have different abbreviations; and I was not able to locate any XXXX Trusts.\n\nNow XXXX  said that they prepared a PayOff Demand letter, apparently trying to demand me to pay them FULL amount of my loan, in violation of all applicable laws, while I never refused to pay my debt and lawfully requested Validation of Debt and Adequate Assurance during which time I have right to suspend my performance.\n\nXXXX on XX/XX/XXXX for the first time provided me a copy of my Note – without ANY assignments; and poorly forged Allonge to the Note while the Note has no references to any Allonges or XXXX what-so-ever; and now XXXXXXXX wants me to pay them the ENTIRE amount of my loan, which is a text book fraud; wrongful collection; violation of FDCPA and racket under RICO Act.\n\nSo, the delay with payment was caused not by my refusal to pay ( I am willing and able my debt to legitimate investors) but by XXXX  violation of all applicable laws.\n\nI really don't know that to do about since these criminals have no limits in their violations of the law and I am consented they can illegally foreclose even though I have all evidence of their fraud and they cannot accelerate payments during validation period. \n\nI contacted XXXX XXXX (who emailed XXXX  PDF file on XX/XX/XXXX)  Here is that they said: “Ms. XXXX, Thank you for your correspondence.  This matter does not involve XXXX   XXXX business activities and any questions that you may have should be directed to the current servicer of your loan. Sincerely”\n\nThis is a blatant lie. First, XXXX XXXX ordered a copy of the FEMA map acting on behalf of XXXX as their client. \n\nSecond, anyone who knows about securitization of residential debt knows that the only way the banks could succeed is if they had a central repository and central command center from which all documents were fabricated and all instructions were issued. \nFor nearly all loans the central command was XXXX, aided by XXXX. \n\nWhile XXXX is technically defunct and XXXX XXXX went to jail taking one for the team, the functions of XXXX  remained the same.\n\nXXXX  changed its name to XXXX  XXXX  who in fact is owned and operated by XXXX   and Me. XXXX XXXX, and in a PR coup transformed itself into the publisher of what is largely viewed as comprehensive data on mortgage lending and foreclosures. Hence it went from the purveyor of false, fraudulent, forged documentation to the purveyor of data perceived as reliable and thence became a trusted source whose data is considered worthy of legal presumptions.\n\nSystems at XXXX/XXXX XXXX  include data processing on virtually all residential loans subject to claims of securitization many of which are represented by data on the XX/XX/XXXX  Platform which is a workaround to hide separate split transfers of the debt, the note and the mortgage or deed of trust. The systems on XXXX/XXXX   XXXX are designed for the express purpose of presenting consistent data in foreclosure claims. As such it also enables the rotation of apparent servicers, none of whom perform bookkeeping functions even if some of them interact with borrowers as if they were actually the servicers.\n\nThe rotation of servicers comes with the false representation and illusion of boarding in which the process is falsely represented as meaning that the new servicer inspected, audited, reviewed and input the data into their own system. None of that occurred. Instead the new servicer merely gained access to the same XXXX   system as the last servicer with a new login and password.\n\nAll evidence shows that the functions for fabricated, forging and robosigning documents continue to be performed under the direction of XXXX/XXXX XXXX (in fact, by XXXX under leadership of XXXX XXXX XXXX) ) which receives all instructions from various investment banks who have each started their own securitization scheme masking apparent trades in the secondary market for loans and trades in the shadow banking market where “private contracts” are regularly traded without any securities regulation.\n\n Far from dropping their connection with XXXX/XXXX the major banks have completely embraced this central repository of all loan data, all of which is subject to manual and algorithmic manipulation to suit the needs of the banks; thus they produce a report that creates the illusion of credibility, reliability and even independence even though none of those things are true.  This is why the claims of a “Boarding process” are pure fiction, because the records are always kept in the same place and never move. \n\nThis is obvious in my situation with fake Servicers XXXX   and XXXX  who have no documents pertaining to my loan. \n\nXXXX was the place where most of not all document fabrications took place including signatures that were forged or robosigned. Fabrication means that they were creating documents that did not previously exist. Those documents did not exist for only one reason, to wit: there was no transaction to document so the document was never prepared until it was necessary to fake it for the purposes of foreclosures.\n\nXXXX XXXX  is now used as a trusted source of information about mortgages and foreclosures despite being the central entity (operating through third party contractors) from which false documents are created and used in foreclosures.\n\nIt was necessary to fake it because under the law, it isn’t enough to allege or assert that a borrower failed to pay. Failure to pay is only a breach as to the owner of the debt who is entitled to receive the payment because he/she/it paid money for the debt and the rights to enforce. But no such payment ever occurred. If there is no rebach there is no claim.\n\nSo in order to cover-up the illusions created by fabrications of documents, it was necessary to fake the sending, filing and serving of process of documents. The secrecy  was accomplished by sending the notices not from the central repository, XXXX XXXX, which would make it obvious that it was all coming from one place, but from different locations around the country — hundreds of them.\n\nSo in my  example, XXXX agrees to let XXXX XXXX   use its name for notices, and Bank of America agrees to have the notice sent from one of its thousands of locations. In reality the notice came from XXXX XXXX (aka XXXX).\n\nAgain, it is very evident in my loan where XXXX  XXXX   was secretly  involved from the beginning when XXXX   XXXX ordered a Flood Insurance Map from FEMA acting on behalf of their “client” XXXX, the purported “Lender”. \n\n The  massive PDF file to XXXX was emailed on XX/XX/XXXX  by XXXX  XXXX  who did not even bother to prepare somehow legitimately-looking assignment or  include XXXX into it. Thus, Mr. XXXX   XXXX, who forged an Allonge, shall be held for document forgery and fraud against Federal Government from who Mr. XXXX  STOLE my loan and the Note which he “assigned” to XXXX, not XXXX XXXX. \n\nXXXX  evasive and incomplete responses regarding essential documents related to my debt – a copy of my Note with full chain of transfer and a receipt of sale/purchase,  leaves only one possible conclusion, to wit: that the loan origination was only one part of a much larger undisclosed scheme, the existence of which was intentionally obscured and withheld from the borrower, whose name, signature reputation and home were not just material, but absolutely essential requirements for the success of the scheme, which includes huge  tax evasion and money laundering. \n\nThe intent was clearly not to receive repayment of a loan. In fact all evidence currently available suggests that any money that has been received as a result of the “loans” to consumers was actually revenue disguised as principal, interest, or the proceeds of property sales – voluntary or involuntary. \n\nThe current evidence strongly suggests that there was a complete conversion of the loan receivable from the category of “asset” to “income.” In order to maintain the illusion, which required concealment of the conversion of the apparent loan receivable from asset to income, it was necessary to bring foreclosure actions on those consumers who had stopped making payments. This was true even though the parties to whom they were making payments, were not collecting on behalf of any party who owned the debt by virtue of having paid money for ownership of the debt and the rights to enforce it.\n\nBut since the loan receivable had been converted from asset to income they had to create the appearance that the conversion had never occurred. And that is why we saw widespread fabrication, forgery and Robo signing of backdated documents that referred to nonexistent transactions. In reality it is simply not possible that anyone in the chain of title could have paid any money for ownership of the debt and the rights to enforce it; this was simply because none of those parties had ever funded the origination or acquisition of the debt. All attributes of the debt and all revenue streams or profits from treating indirectly on the debt were sold for profit in which the participants in that revenue stream received at least 11 times the amount of the purported “loan.” As part of the cover-up most of the revenue stream was reported as return of capital, implying that the conversion to income had never occurred. This enabled avoidance of substantial income taxes on regular trading income.\n\nThe taxes lost to State and Federal Government were far in excess of the cost of various packages that were used to stimulate the economy after the crash caused by the very same investment bankers who had cheated the government out of the receipt of tax revenues, cheated homeowners, and cheated investors.\n \nIn the recent Complaint filed by the Department of Justice against XXXX  , the insiders who were trading digitized certificates and contracts deriving value from an index that referred to a group of loans that were not owned by any of the participants, referred to the “pooling” and the derivatives as a bag of XXXX whose value was something less then XXXX. And that is what is being enforced in foreclosure courts across the country. And somehow most homeowners continue to experience feelings of shame and regret for not giving even more revenue to players who will already profited in XXXX proportions to any money that was loaned. Those homeowners think that they are either paying a debt if they are making monthly payments, or they are giving up their house to pay a debt. If that was true, that none of the fabrication of documents, forgery or Robo signing would have been necessary. \n\nThus, a full validation of my debt to XXXX aka BOA;  and Adequate Assurance that I deal with a legitimate company, not with a bundle of the same criminals  who once crashed US economy is absolutely mandatory.  I respectfully request you to intervene and ORDER BOA, XXXX, and their co-conspirators to compensate me for ALL damages, in the amount no less that (1) 15% royalties from trades on my name, signature and reputation; (2) treble damages for fraud and forgery;( 3) treble damages for racket; (4) damages for extreme emotional distress while dealing with BOA RICO enterprise who as of today is engaged in a wide-spree crimes. \n\nBOA found it lucrative to gamble with lives and homes  of veterans like myself, with gross disregard to all damages their criminal conduct can cause. The laughable settlements paid by BOA with other people money only made fraud more attractive since BOA acts with total impunity and not afraid to defraud borrowers as much as they want. \n \nRegards. XXXX XXXX","date_sent_to_company":"2019-08-21T13:07:36.000Z","issue":"Attempts to collect debt not owed","sub_product":"Mortgage debt","zip_code":"490XX","tags":"Servicemember","has_narrative":true,"complaint_id":"3344343","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"BANK OF AMERICA, NATIONAL ASSOCIATION","date_received":"2019-08-18T12:47:05.000Z","state":"MI","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Debt was result of identity theft"},"highlight":{"complaint_what_happened":["(XXXX XXXX”) aka XXXX  XXXX XXXX   (“XXXX”) for their mortgage <em>fraud</em>; <em>fraud</em> with XXXX XXXX securities; forgery; unlawful collection  and violations of all possible laws."]},"sort":[7.231249,"3344343"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":4,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":4}]}},"product":{"doc_count":4,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit card","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"General-purpose credit card or charge card","doc_count":1}]}},{"key":"Credit reporting or other personal consumer reports","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit reporting","doc_count":1}]}},{"key":"Debt collection","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Mortgage debt","doc_count":1}]}},{"key":"Mortgage","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"VA mortgage","doc_count":1}]}}]}},"issue":{"doc_count":4,"issue":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Attempts to collect debt not owed","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Debt was result of identity theft","doc_count":1}]}},{"key":"Getting a credit card","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Application denied","doc_count":1}]}},{"key":"Incorrect information on your report","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Account information incorrect","doc_count":1}]}},{"key":"Trouble during payment process","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Payment process","doc_count":1}]}}]}},"timely":{"doc_count":4,"timely":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Yes","doc_count":4}]}},"company_response":{"doc_count":4,"company_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Closed with explanation","doc_count":4}]}},"submitted_via":{"doc_count":4,"submitted_via":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Web","doc_count":4}]}},"company":{"doc_count":4,"company":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"AMERICAN EXPRESS COMPANY","doc_count":1},{"key":"BANK OF AMERICA, NATIONAL ASSOCIATION","doc_count":1},{"key":"Experian Information Solutions Inc.","doc_count":1},{"key":"Shellpoint Partners, LLC","doc_count":1}]}},"state":{"doc_count":4,"state":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"MI","doc_count":1},{"key":"MN","doc_count":1},{"key":"PA","doc_count":1},{"key":"TN","doc_count":1}]}},"company_public_response":{"doc_count":4,"company_public_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","doc_count":3}]}},"tags":{"doc_count":4,"tags":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Servicemember","doc_count":2}]}}},"_meta":{"license":"CC0","last_updated":"2026-07-15T12:00:00-05:00","last_indexed":"2026-07-15T12:00:00-05:00","total_record_count":16469162,"is_data_stale":false,"has_data_issue":false,"break_points":{}}}