Thanks to Abigail for the post title.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,
555 4th Street, NW
Washington, DC 20530

49 States et al

Plaintiffs.

v.

BANK OF AMERICA CORPORATION,
Corporate Center 100
100 North Tyron Street
Charlotte, North Carolina 28255

BANK OF AMERICA, N.A.,
100 North Tyron Street
Charlotte, North Carolina 28255

BAC HOME LOANS SERVICING, LP f/k/a
COUNTRYWIDE HOME LOANS
SERVICING, LP,
4500 Park Grenada
Calabasas, California 91302-1613

COUNTRYWIDE HOME LOANS, INC.,
4500 Park Grenada )
Calabasas, California 91302

COUNTRYWIDE FINANCIAL CORPORATION,
4500 Park Grenada
Calabasas, California 91302

COUNTRYWIDE MORTGAGE
VENTURES, LLC,
4500 Park Grenada
Calabasas, California 91302-1613

COUNTRYWIDE BANK, FSB,
100 North Tryon Street
Charlotte, NC 282002

CITIGROUP INC.,
399 Park Ave.
New York, New York 10022-4614

CITIBANK, N.A.,
399 Park Ave.
New York, New York 10022-4617

CITIMORTGAGE, INC.,
1000 Technology Drive
O’Fallon, Missouri 63368

J.P. MORGAN CHASE & COMPANY,
270 Park Avenue
New York, New York 10017

JPMORGAN CHASE BANK, N.A.
1111 Polaris Parkway
Columbus, OH 43240

RESIDENTIAL CAPITAL, LLC,
1100 Virginia Drive
Fort Washington, Pennsylvania 19034

ALLY FINANCIAL, INC.,
200 Renaissance Center
P.O. Box 200
Detroit, Michigan 48265

GMAC MORTGAGE, LLC,
1100 Virginia Drive
Fort Washington, Pennsylvania 19034

GMAC RESIDENTIAL FUNDING CO. LLC
8400 Normandale Lake Boulevard
Minneapolis, Minnesota 55437

WELLS FARGO & COMPANY,
420 Montgomery Street Front
San Francisco, CA 94104-1205

WELLS FARGO BANK, N.A.,
One Home Campus
Des Moines, IA 50328

Defendants.
________________________________________________)

EXCERPT:

57. In the course of their conduct, management and oversight of loan
modifications in the plaintiff States, the Banks have engaged in a pattern of unfair
and deceptive practices.

58. The Banks’ failure to discharge their required loan modification
obligations, and related unfair and deceptive practices, include, but are not limited
to, the following:

a. failing to perform proper loan modification underwriting;

b. failing to gather or losing loan modification application
documentation and other paper work;

c. failing to provide adequate staffing to implement programs;

d. failing to adequately train staff responsible for loan
modifications;

e. failing to establish adequate processes for loan
modifications;

f. allowing borrowers to stay in trial modifications for
excessive time periods;

g. wrongfully denying modification applications;

h. failing to respond to borrower inquiries;

i. providing false or misleading information to consumers
while referring loans to foreclosure during the loan modification
application process;

j. providing false or misleading information to consumers
while initiating foreclosures where the borrower was in good faith actively
pursuing a loss mitigation alternative offered by the Bank;

k. providing false or misleading information to consumers
while scheduling and conducting foreclosure sales during the loan
application process and during trial loan modification periods;

l. misrepresenting to borrowers that loss mitigation programs
would provide relief from the initiation of foreclosure or further
foreclosure efforts;

m. failing to provide accurate and timely information to
borrowers who are in need of, and eligible for, loss mitigation services,
including loan modifications;

n. falsely advising borrowers that they must be at least 60
days delinquent in loan payments to qualify for a loan modification;

o. miscalculating borrowers’ eligibility for loan modification
programs and improperly denying loan modification relief to eligible
borrowers;

p. misleading borrowers by representing that loan
modification applications will be handled promptly when Banks regularly
fail to act on loan modifications in a timely manner;

q. failing to properly process borrowers’ applications for loan
modifications, including failing to account for documents submitted by
borrowers and failing to respond to borrowers’ reasonable requests for
information and assistance;

r. failing to assign adequate staff resources with sufficient
training to handle the demand from distressed borrowers; and

s. misleading borrowers by providing false or deceptive
reasons for denial of loan modifications.

3. Wrongful Conduct Related to Foreclosures

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