ADAM LEVITIN | Banks to AGs on Servicing Fraud: Drop Dead

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ADAM LEVITIN | Banks to AGs on Servicing Fraud: Drop Dead

ADAM LEVITIN | Banks to AGs on Servicing Fraud: Drop Dead

Here’s the banks’ counterproposal for a servicing fraud settlement. I can sum it up in two words: drop dead.  Or two letters:  F.U. This proposals is so pathetically thin that it’s not a good faith counterproposal. This document only deals with servicing standards–nothing in it whatsoever about penalties, modification quotas, etc. But even on servicing standards it is a bunch of empty promises to have internal controls and try harder.

The first point about this counterproposal is simply to note what’s absent from it:

(1) nothing about principal reductions

(2) nothing about second liens and conflicts of interest

(3) nothing about MERS (reserved for later)

(4) nothing about in-sourced vendor fees or force-placed insurance to affiliates. This makes the fees and force-place insurance sections pretty meaningless.

(5) nothing about pyramiding of fees.

© 2010-17 FORECLOSURE FRAUD | by DinSFLA. All rights reserved.



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CONTROL FRAUD | ‘If you don’t look; you don’t find, Wherever you look; you will find’ -William Black

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