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Certification battle in Ohio MERS class action heats up

Certification battle in Ohio MERS class action heats up


Lexology-

On April 23, 2012, the plaintiff in State of Ohio ex rel. David P. Joyce, Prosecuting Attorney of Geauga County Ohio v. MERSCORP, Inc., et al., N.D. Ohio Case No. 1:11-cv-02474, filed its motion seeking an order certifying the action as a class action, appointing Geauga County as class representative, and appointing plaintiff’s counsel, the New York law firm of Bernstein Liebhard LLP, as class counsel. The plaintiff argues that the case, which the plaintiff is attempting to bring on behalf of all 88 Ohio counties for relief relating to the allegedly unlawful failure of MERS and its member institutions to record millions of mortgages and mortgage assignments throughout Ohio, meets all requirements of Rule 23(a) and that certification is proper under any one of the 3 subsections of Rule 23(b). The plaintiff hopes to persuade the court that the MERS/member institution policy concerning recordation of mortgages and assignments is a “common scheme or course of conduct” that has given rise to claims “ideally suited for class certification.”

[LEXOLOGY]

[ipaper docId=94254592 access_key=key-2nn3qssi6kdpdxy704up height=600 width=600 /]

 

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COMPLAINT | State of Ohio, Geauga County v. MERSCORP, MERS et al., No. 11-M-001087

COMPLAINT | State of Ohio, Geauga County v. MERSCORP, MERS et al., No. 11-M-001087


IN THE COURT OF COMMON PLEAS
GEAUGA COUNTY, OHIO

STATE OF OHIO, ex.rel.
DAVID P. JOYCE
PROSECUTING ATTORNEY OF GEAUGA
COUNTY, OHIO
Courthouse Annex, 231 Main St. Suite 3A
Chardon, Ohio 44024

On behalf of Geauga County and all others similarly
situated,

Plaintiff,

v.

MERSCORP, INC.
1818 Library Street, Suite 300
Reston, Virginia 20190

and

MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC.
1818 Library Street, Suite 300
Reston, Virginia 20190

[…]

[ipaper docId=69166120 access_key=key-9gi3i39l3vj116tff1y height=600 width=600 /]

 

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Fannie, Freddie, MERS, LPS & the Bankers Dozen Meet

Fannie, Freddie, MERS, LPS & the Bankers Dozen Meet


Gretchen Morgenson tears this one up… gotta love this piece of the story

“Only Lender Processing Services had more — 91 — than Fannie and Freddie. (Perhaps they robo-signed their registrations.)”

NYT-

THE mortgage business is moribund. New loans are down. New foreclosures are up.

But why let a little sorry news get in the way of a good party? Last week, almost 3,000 people descended on the Hyatt Regency in Chicago for the 98th annual convention of the Mortgage Bankers Association.

The price of admission: about $1,000 a head. But for that grand, you got to hear the band Chicago play hits from the ’70s. And David Axelrod and Jeb Bush give speeches. And experts discuss things like demographics, the politics of housing and the future of the mortgage industry, according to a flier for the event.

[NEW YORK TIMES]

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MBA takes MISMO back from MERS

MBA takes MISMO back from MERS


I would urge the AG’s investigating MERS to turn to MISMO next because it’s beginning to appear they are taking crucial parts away from MERS. Something is definitely up?

 

 

But why? On July 30, 2010 MBA went before the SEC begging them to adopt MERS:

The major participants in the residential mortgage industry utilize the MIN. Fannie Mae, Freddie Mac and Ginnie Mae all utilize the MIN. MISMO encourages the SEC to adopt the MERS Mortgage Identification Number (MIN) as the primary loan identifier for real estate finance ABS.

Scott Cooley an independent mortgage technology consultant, analyst and author once said “Calling on MERS”:

“Today, most of the aforementioned parties are shipping the documents at great cost through carriers such as Federal Express. With VLF, all such shipping and the manual handling of the traditional loan folder is eliminated. In fact, all the paper in the process is gone. Yes, this is a form of imaging that some mortgage companies are using today. However, it goes much further, in that it would be used by all parties involved with each loan. In addition, it would also store the electronic data file of the loan and do so in a Mortgage Industry Standards Maintenance Organization Inc . (MISMO) format.”

VIA HW-

The Mortgage Bankers Association is going to take back management of its MISMO platform from MERS, according to a HousingWire source familiar with the plans.

The crossover will be complete Dec. 1 and a press release providing more details is said to be in the works.

[HOUSING WIRE]

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At FHA, Odd Accounting Burnished Stevens’ Image

At FHA, Odd Accounting Burnished Stevens’ Image


An “unprecedented crackdown.” That’s how Commissioner David Stevens described a get-tough program that took place under him at the Federal Housing Administration from mid-2009 until April of this year. As part of the push, the FHA’s Mortgage Review Board issued more administrative actions against lenders in Stevens’ first year than it had in the prior eight years combined.

[AMERICAN BANKER]

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MBA head David Stevens “Cozy” with Banks While at the FHA

MBA head David Stevens “Cozy” with Banks While at the FHA


The American Banker

David Stevens arrived as a commissioner at the Federal Housing Administration in 2009 vowing to restore financial discipline to a government housing body facing the stresses of a post-crash world. A former mortgage banker himself, Stevens, now 54, bolstered the agency’s finances and pursued alleged wrongdoing at nonbank lenders including Berkshire Hathaway and Goldman Sachs & Co. affiliates.

One group the FHA did not feud with during Stevens’ tenure: top industry players, such as Bank of America Corp. and Wells Fargo & Co. A collection of emails between Stevens and the Mortgage Bankers Association may help explain why.

[THE AMERICAN BANKER]

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READ LETTER | MBA Asks HUD to Permit E-Signatures on FHA Loans

READ LETTER | MBA Asks HUD to Permit E-Signatures on FHA Loans


We all know where very similar words got MERS…

“E-signatures will reduce the volume of lost paperwork, reduce signature fraud, reduce the time required to close a loan, and may lead to lower borrower costs.”

MERS cannot even keep track of who owns what loan and with all the alleged fraudulent signatures originating from it’s certifying officers signing virtually any number of documents to land records… special caution to permit e-signatures that can easily be cut and pasted.

What if this ever gets “hacked”… nothing is bullet proof.

Read the letter below…

[ipaper docId=57025234 access_key=key-145ld1yf6pkpn8zowucm height=600 width=600 /]

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As We Were Saying, eMortgage Coming To Your Town?

As We Were Saying, eMortgage Coming To Your Town?


Come hungry…close a loan electronically within 15 minutes and with doughnuts. Not like it took any longer the paper route!

Providing all the ‘errors’ and ‘mistakes’ currently happening in foreclosure land, just hope your eNote/eMortgage doesn’t get deleted by accident.

via Housing Wire:

Harry Gardner, president of SigniaDocs, said the perfect infrastructure is one that manages all mortgage documents electronically, but the number of loans in the Mortgage Electronic Registration Systems’ eRegistry is about 200,000, or “a small fraction of mortgages written in the last 10 years.”

“And by eMortgage, we mean truly paperless not some hybrid of some paper and some electronic documentation,” Gardener said. “Ten years ago, we were saying mainstream eMortgage documentation was three to five years away, and I’m happy to say that mainstream eMortgage documentation is now three to five years away.”

continue reading….  Housing Wire

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eMortgages, eNotes …Get Ready For The No-DOC Zone

eMortgages, eNotes …Get Ready For The No-DOC Zone


For you to understand the plan the financial institutions have you need to grasp the following. Will MERS patterns continue? Imagine the price you will pay when these files are hacked or manipulated.

Everyone knows by now that MERS was ‘invented’ to keep costs low for the banks, reduce the risk of record-keeping errors and make it easier to keep track of loans for the banks not the borrowers. By these actions, not only has MERS eliminated crucial chain in title documents, has proven in many court cases to assign absolutely nothing because it had no power to negotiate the note but also eliminated an enormous amount of county revenues.

Last week SFF wrote about the latest invention planned to coexist with MERS called SmartSAFE, which will be used for creating, signing, storing, accessing and managing the lifecycle of electronic mortgage documents. According to Wave’s eSignSystems Executive VP Kelly Purcell, “Mortgages are sold several times throughout the life of a loan, and electronic mortgages address the problem of the ‘lost note,’ while improving efficiency in the process.”

This goes a step forward of what MERS can do today.

Will this process eliminate recording paper mortgages/deeds from county records? Eliminate fees that counties in trouble desperately need? THIS IS VERY DANGEROUS.

Still with me? Finally, according to CUinsight, a sample eNote in the form of a MRG Category 1 classified SMARTDoc, was successfully delivered to Xerox’s BlitzDocs eVault, a virtual repository that connects directly to the MERS® eRegistry and eDelivery systems, where it was electronically signed and registered.

Adding the finishing touches to permit MERS access to future eNotes? I say this is the master plan.

Looking forward to what MA John O’Brien, the Essex County register of deeds, NC Register of deeds Jeff Thigpen and NY Suffolk County, former county clerk Ed Romaine’s approach is after they read what they plan on doing to land records. If they thought it was limited to the elimination of recording fees for assignments of mortgage, they are mistaken.

Questions remain as to why replace something that has been working for so long? Why continue with MERS, a system which has failed in many ways? MERS is under investigation for fraud is it not? Why in a time where mortgage fraud is wide spread, will anyone even trust using electronic devices to manage possibly future trillions of dollars worth?

Say farewell to a tradition that has been here for well over 300 years. Eliminating ‘paper’ will put promissory notes and  mortgage related documents in great jeopardy. No computer system in the world is secure [PERIOD].

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LQQK ‘MOM’, No paper, Lost Paper, Detroyed and Misfiled Paper…The Next Wave

LQQK ‘MOM’, No paper, Lost Paper, Detroyed and Misfiled Paper…The Next Wave


Before you go down to the “New Device” take a look back when THE FLORIDA BANKER’S ASSOCIATION ADMITTED THAT NOTES ARE DESTROYED:

This is a direct quote from the Florida Banker’s Association Comments to the Supreme Court of Florida files September 30, 2009:

“It is a reality of commerce that virtually all paper documents related to a note and mortgage are converted to electronic files almost immediately after the loan is closed. Individual loans, as electronic data, are compiled into portfolios which are transferred to the secondary market, frequently as mortgage-backed securities.

The reason “many firms file lost note counts as a standard alternative pleading in the complaint” is because the physical document was deliberately eliminated to avoid confusion immediately upon its conversion to an electronic file. See State Street Bank and Trust Company v. Lord, 851 So. 2d 790 (Fla. 4th DCA 2003). Electronic storage is almost universally acknowledged as safer, more efficient and less expensive than maintaining the originals in hard copy, which bears the concomitant costs of physical indexing, archiving and maintaining security. It is a standard in the industry and becoming the benchmark of modern efficiency across the spectrum of commerce—including the court system.”

Now if there is no issues surrounding what everyone is shouting from their roof tops, then why integrate a new software that was suppose to have been implemented already to “Improves Efficiency & Transparency of Electronic Mortgage Transactions” within MERS itself?

THEY KNOW THEY HAVE A PROBLEM!

Now from SYS-CON on SmartSAFE

“During the foreclosure crisis of the last few years we saw many instances where the original and subsequent paperwork was lost, destroyed or misfiled when loans were bought and sold,” commented Kelly Purcell, Executive Vice President for Wave’s eSignSystems division. “Mortgages are sold several times throughout the life of a loan, and electronic mortgages address the problem of the ‘lost note,’ while improving efficiency in the process.”

This will debut during next week’s MBA National Technology in Mortgage Banking Conference and Expo 2011 (at the Westin Diplomat Resort & Spa in Ft. Lauderdale, Fla.).

Will this be the new system that will eventually take over MERS as MOM?

This one is both “Smart & Safe” <wink>


 

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BLOOMBERG | Outgoing FHA Commissioner Will Head Mortgage Bankers Group

BLOOMBERG | Outgoing FHA Commissioner Will Head Mortgage Bankers Group


Federal Housing Administration Commissioner David H. Stevens will become head of the Mortgage Bankers Association after he leaves his government post this month, the trade group said.

Stevens last week announced his intention to resign from the housing agency. He will join the Washington-based bankers group in May.

Michael D. Berman, chairman of the bankers group, called Stevens “uniquely qualified” for the job.

“He has had a tremendous impact at FHA,” Berman said in a statement today.

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More on Strategic Defaults and a Happy Ending… Hopefully.

More on Strategic Defaults and a Happy Ending… Hopefully.


We’re all in this together.

Interesting article came out yesterday from PB Post’s Christine Stapleton where some homeowners, who can afford the mortgage, still default as a strategy.

from PB Post:

They crunched the numbers: $525,000 outstanding on their first mortgage and a $245,000 second mortgage on a home now worth about $319,000. His business was way down, her company was laying off workers and other investments had tanked. It made no sense to hang on to their underwater home. So they stopped paying their mortgage and waited for the foreclosure notice. It came in October.

Reading this article made me think about Fannie Mae announcing that she was going to start to penalize people who walk away from underwater mortgages.

Fannie said:

Fannie also will lengthen to seven years, from five, the amount of time borrowers who go through a foreclosure must wait before getting a new loan.

Did you read that? Now here’s the best strategic default yet but may leave us with their debt.

There is a very good chance that both Fannie and Freddie won’t be around in the next 5-7 years because the White House is planning to end Fannie, Freddie by winding it down and eventually eliminating them.

No matter how it’s sliced and diced…You, We, Us are all in this T O G E T H E R.

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NYTimes | Banks Want Pieces of Fannie-Freddie Pie

NYTimes | Banks Want Pieces of Fannie-Freddie Pie


By LOUISE STORY
Published: January 20, 2011

As the Obama administration prepares a report on the future of Fannie Mae and Freddie Mac, some of the nation’s largest banks are offering a few suggestions.

Wells Fargo and some other large banks would like private companies, perhaps even themselves, to become the new housing finance giants helping to bundle individual mortgages into securities — that would be stamped with a government guarantee.

The banks have presented their ideas publicly through trade groups. Housing industry consultants and people familiar with recent meetings at the Treasury Department say these banks view the government’s overhaul of the mortgage market as a potential profit opportunity. Treasury officials have met with executives from several institutions, including Wells Fargo, Morgan Stanley, Goldman Sachs and Credit Suisse, according to a public listing of the meetings.

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FED looking to screw homeowner protection against foreclosures and predatory loans

FED looking to screw homeowner protection against foreclosures and predatory loans


Fed wants to strip a key protection for homeowners

Posted on Wednesday, December 1, 2010

By Tony Pugh | McClatchy Newspapers

WASHINGTON — As Americans continue to lose their homes in record numbers, the Federal Reserve is considering making it much harder for homeowners to stop foreclosures and escape predatory home loans with onerous terms.

The Fed’s proposal to amend a 42-year-old provision of the federal Truth in Lending Act has angered labor, civil rights and consumer advocacy groups along with a slew of foreclosure defense attorneys.

They’re not only asking the Fed to withdraw the proposal, they also want any future changes to the law to be handled by the new Consumer Financial Protection Bureau, which begins its work next year.

In a letter to the Fed’s Board of Governors, dozens of groups that oppose the measure, including the National Consumer Law Center, the NAACP and the Service Employees International Union, say the proposal is bad medicine at the wrong time.

“At the depths of the worst foreclosure crisis since the Great Depression, we are surprised that the Fed has proposed rules that would eviscerate the primary protection homeowners currently have to escape abusive loans and avoid foreclosure: the extended right of rescission.”

Because the public comment period on the Fed’s proposal is still open until Dec. 23, a spokesman declined comment on the matter.

But in a September passage in the Federal Register, the Fed said the proposal was designed to “ensure a clearer and more equitable process for resolving rescission claims raised in court proceedings” and reflects what most courts already require.


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FULL TRANSCRIPT: Home Mortgage Disclosure Act Public Hearings, September 24, 2010

FULL TRANSCRIPT: Home Mortgage Disclosure Act Public Hearings, September 24, 2010


Excerpt:

How to report? One of the things we strongly recommend is that you look at the MISMO standards, the Mortgage Industry Standards Maintenance Organization, for definitions, for format, and I think this might address issues, for example, with HUD reported credit score. That if you like at the MISMO, we don’t simply look at one field for credit score. There’s a field for a number. There’s also then a field of whether it’s a vantage score, whether it comes from FICO, what vendor reported the score. So that there are a number of variables then that are really behind it, and if you simply then pick up all of these variables associated with the credit score the way we do, you can then use the information internal to then generate whatever percentile or whatever calculation you would like to do, but that that would not be put back on the lender to reenter data, to rekey it, but instead use what’s already out there in the industry. Also it would provide for easier changes later on, if any additions are needed.

What about a universal mortgage identifier? That has been brought up. We would strongly recommend that you look at the mortgage identification number that’s been put out by the Mortgage Electronic Registration System, MERS. It allows us to track mortgages throughout the system from application all the way to sale of servicing, sales of the secondary market and I think for these purposes it would allow us to really sort of track some of the under coverage that we do see in the HMDA data. We did some analysis and found that by throwing out all the correspondent loans, we are eliminating a number of loans that had no counterpart in the retail broker data.

What to make public? Well, we really think that’s your decision. In a sense that there are a number of data elements here that we would very much not want to make public as companies because of the limitations we face, but that certainly that’s an issue that the bureau and the Fed will have to face going forward is the tradeoff between risks of identity theft associated with some of these elements and that, but that’s really your decision to make rather than the industry, and to some degree, we would benefit, I think, in terms of what would explain what’s going on in the industry with a greater data release.

Finally on multifamily, we did an analysis and we think that HMDA already covers about 95 percent of the multifamily loans that are made. In contrast, though, it covers only about 60 percent or so of the dollar amount of the loans. So that if you look then at the average loan amount that’s in HMDA, it’s about $1.7 million for a multifamily loan. If you look at the average loan size of what’s missing, it’s about $19 million. So we don’t know how much effort really should be put into trying to capture this remaining 5 percent of really high dollar loans that are done for just an entirely different set of investors out there. So I think you really ought to look at what do you really want to do with the multifamily data? Do you really want to expand it or is there a questionable usefulness of what’s already there? Thank you.

[ipaper docId=42211905 access_key=key-2llkeixrro0fj9v82nv6 height=600 width=600 /]

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Mortgage Bankers Association Strategic Default

Mortgage Bankers Association Strategic Default


Hilarious!

What happens when the Mortgage Bankers Association walks away from their $79,000,000 dollar building!


The Daily Show With Jon Stewart Mon – Thurs 11p / 10c
Mortgage Bankers Association Strategic Default
www.thedailyshow.com
Daily Show Full Episodes Political Humor Rally to Restore Sanity
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MBA Testifies on Potential Revisions to The Home Mortgage Disclosure Act (HMDA)

MBA Testifies on Potential Revisions to The Home Mortgage Disclosure Act (HMDA)


WASHINGTON, D.C. (September 24, 2010) – Jay Brinkmann, Chief Economist and Senior Vice President of Research and Economics for the Mortgage Bankers Association (MBA), testified today before the Federal Reserve Board of Governors at a hearing entitled, “Potential Revisions to Regulation C – Implementing the Home Mortgage Disclosure Act (HMDA).”

Below is Mr. Brinkmann’s oral statement before the committee, as prepared for delivery.

“My name is Jay Brinkmann and I am the Chief Economist and head of research at the Mortgage Bankers Association (MBA). I very much appreciate the opportunity to participate in today’s hearing of the Federal Reserve Board on potential revisions to its Home Mortgage Disclosure Act (HMDA) requirements.

I would like to address essentially five questions or areas that need to be addressed. First, what data should be required? Second, how should the data be reported? Third, what should be used as the universal mortgage identifier? Fourth, what data should be made public? Finally, I will address some issues regarding multifamily data.

What data should be required?

Dodd-Frank already requires a significant expansion of the required data elements, although some are left to the discretion of the Bureau of Consumer Financial Protection (CFPB). In addition, we understand the Federal Reserve is looking at some potential additions beyond what is in Dodd-Frank. We have no objection to an expansion of the HMDA data elements as long as that expansion is consistent with the stated purposes of HMDA, the elements are consistent with what is already collected, and the changes would not pose unnecessary burdens on lenders. It should be understood, however, that no matter how many additional data elements are required they will not serve as a reliable proxy for the range of credit models or credit decisions given the sequential nature of the credit decision, variations in decision-making processes among lenders, as well as variations in shopping behavior and self-selection of credit terms by borrowers.

One issue the Fed must keep in mind in determining what data elements to collect is that HMDA requirements should not turn into a safe harbor of allowable credit variables to be considered when making a loan. Freezing credit models into an official sanctioned set of variables would have a deleterious impact on credit availability going forward, limiting the growth of lenders who believe they have a better idea of how to do things. For example, over the years some lenders have come to believe that credit scores are not as important as the number of times a potential borrower has been late with housing-related payments. Some lenders now will simply refuse to make a loan to a borrower who has walked away from a previous mortgage, or appears to be positioning himself or herself for such behavior. None of these considerations are captured in any of the proposed HMDA data elements, nor should they be.

How to report?

In determining definitions and file formats for potential data items, the Fed should use the standard and uniform definitions developed over the last ten years by the Mortgage Industry Standards and Maintenance Organization, Inc. (MISMO®). Reliance on MISMO definitions would greatly reduce the regulatory compliance burden by allowing lenders and vendors furnishing HMDA compliance services to pull from existing MISMO-compliant databases to report under HMDA. This would reduce the errors associated with entering data a second time for HMDA purposes and reduce the phase-in period for trying to interpret and then implementing new HMDA definitions. In addition, MISMO standards have already been adopted by Fannie Mae and Freddie Mac.

Reliance on the MISMO dictionary and standards would also help deal with the ambiguity surrounding some of the data elements specified in Dodd-Frank. For example, Dodd-Frank requires that credit scores be reported. MISMO recognizes that there is no such thing as a single credit score, so while it has a field for the score, it also has a field for the credit score vendor (such as Vantage Score or FICO), and the reporting agency. Rather than asking lenders to map multiple fields into a single number to be reported to the Fed, a number that likely would not appear in any credit file nor be used in the credit or loan pricing decision, the Fed could simply ask for the multiple fields dealing with credit scores and do its own mapping depending on whether it is doing a company-level or industry-level analysis.

I cannot stress enough the extent of the regulatory burden that HMDA and other reporting and compliance requirements place on the industry. The largest shares of investments in technology today are going to reporting and compliance needs, with no direct benefit to the companies or their customers. I would hope that the Fed would keep this burden and its costs in mind and minimize future changes in HMDA once these changes are made. Relying on MISMO would not only minimize costs but it would allow minor tweaking of data requirements in the future with less burden.

What to use as the universal mortgage identifier?

The industry already has a uniform mortgage identification number that is issued through the Mortgage Electronic Registration Systems, Inc. (MERS). This MERS number is used by a very high percentage of lenders and is integral to numerous origination and secondary market functions. It would cause considerable confusion and unnecessary implementation expense to impose a new mortgage identification protocol on the industry. Reliance on the MERS Mortgage Identification Number (MIN) allows loans to be tracked from origination through sale in the secondary market and subsequent servicing, and is valuable in identifying and preventing mortgage fraud.

For the Fed’s purposes, a further advantage of using the MERS MIN is that it would help prevent double counting or the failure to count loans altogether. For example, the current practice of eliminating loans purchased as closed loans from correspondent banks lowers the apparent coverage level of HMDA. In an effort to see what was missing from HMDA, the MBA several years ago did a matched-pair analysis of correspondent loans and found that a large percentage did not have a matching loan in the retail/broker data. Use of the MERS MIN would largely solve the problem of estimating coverage levels because it would permit an explicit matching between retail/broker originations and correspondent originations, it would provide a matching of loans originated in one calendar year and sold in another, and it allow loan data to be double checked against other data sources like Fannie Mae, Freddie Mac and Ginnie Mae.

What to make public?

Federal Reserve staff have developed considerable expertise in the analysis and interpretation of HMDA data. Their annual article in the Federal Reserve Bulletin is the source of information on HMDA for most analysts. In recent years, Fed staff have gone the extra mile to conduct analyses beyond the HMDA data to answer topical policy questions.

However, while it is proper and customary for a firm’s regulator to have access to confidential data, care needs to taken before those data are made public. While we see tremendous risk of widespread identity theft if all of the HMDA data elements were to be released in their collected form, particularly when those data are combined with other publicly available data, under Dodd-Frank, decisions on such release now lie with the Board and later the CFPB. The lending industry has poured tremendous resources into safeguarding the private information of our customers, and we have paid large fines for lapses. No doubt we would face the potential of additional fines and public recrimination were we to make the proposed HMDA data elements available to the public at large. That is why any liability associated with the collection and release of these data pursuant to Board rules should lie with the Fed. Moreover, the Board should provide guidance on how lenders should deal with requests that come directly to them for these data.

To a certain degree, we would support a greater release of credit data in some form. While it still would not solve all of the statistical problems associated with trying to mimic credit models with these data, it would go a long way to putting to rest once and for all charges of racism that have been hurled at the industry by various groups over the years that have no basis in fact. The econometric problems of omitted variables, multicolinearity and spurious correlation would still remain, but sufficient data would be available in the public domain to refute most of these charges.

What multifamily data should be reported?

MBA estimates that the 2008 HMDA data contained information on 95 percent of the multifamily loans made that year based on the number of loans, but covered only about 61 percent of their dollar amount. The average multifamily loan in HMDA was about $1.7 million while the average missing loan was about $18.9 million. We question the benefit of expanding the reporting requirements to include a relative small number of high-dollar multifamily projects.

Clearly, the data elements associated with single-family lending are not applicable to any but the smallest multifamily projects. Variables like race and credit score do not apply to limited partnerships, corporations or real estate investment trusts. We suggest that the Fed should examine the usefulness of the multifamily data it collects now with an eye to scaling back the requirement rather than going to large lengths to expand the reporting requirements to cover a small number of large dollar projects.

In conclusion, in making changes to the required data elements of HMDA, the Fed should look carefully at what is needed considering the new data requirements under Dodd-Frank and their costs, integrating the data requirements with what is already being collected, and using data definitions and identifiers that are already in common use. In addition, the Fed should be very concerned with the privacy related issues that would attend a wholesale public release of the new required data elements.”

###

The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 280,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nation’s residential and commercial real estate markets; to expand homeownership and extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of over 2,200 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, Wall Street conduits, life insurance companies and others in the mortgage lending field. For additional information, visit MBA’s Web site: www.mortgagebankers.org.

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CLASS ACTION AMENDED against MERSCORP to include Shareholders, DJSP

CLASS ACTION AMENDED against MERSCORP to include Shareholders, DJSP


Kenneth Eric Trent, P.A. of Broward County has amended the Class Action complaint Figueroa v. MERSCORP, Inc. et al filed on July 26, 2010 in the Southern District of Florida.

Included in the amended complaint is MERS shareholders HSBC, JPMorgan Chase & Co., Wells Fargo & Company, AIG, Fannie Mae, Freddie Mac, WAMU, Countrywide, GMAC, Guaranty Bank, Merrill Lynch, Mortgage Bankers Association (MBA), Norwest, Bank of America, Everhome, American Land Title, First American Title, Corinthian Mtg, MGIC Investor Svc, Nationwide Advantage, Stewart Title,  CRE Finance Council f/k/a Commercial Mortgage Securities Association, Suntrust Mortgage,  CCO Mortgage Corporation, PMI Mortgage Insurance Company, Wells Fargo and also DJS Processing which is owned by David J. Stern.

MERSCORP shareholders…HERE

[ipaper docId=36456183 access_key=key-26csq0mmgo6l8zsnw0is height=600 width=600 /]

Related article:

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CLASS ACTION FILED| Figueroa v. Law Offices Of David J. Stern, P.A. and MERSCORP, Inc.

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



Posted in bank of america, chain in title, citimortgage, class action, concealment, CONTROL FRAUD, corruption, countrywide, djsp enterprises, fannie mae, foreclosure, foreclosure fraud, foreclosure mills, foreclosures, forgery, Freddie Mac, HSBC, investigation, jpmorgan chase, Law Offices Of David J. Stern P.A., lawsuit, mail fraud, mbs, Merrill Lynch, MERS, MERSCORP, mortgage, Mortgage Bankers Association, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., Mortgage Foreclosure Fraud, non disclosure, notary fraud, note, racketeering, Real Estate, RICO, rmbs, securitization, stock, title company, trade secrets, trustee, Trusts, truth in lending act, wamu, washington mutual, wells fargoComments (13)

Tracking Loans Through a Firm That Holds Millions: MERS

Tracking Loans Through a Firm That Holds Millions: MERS


Kevin P. Casey for The New York Times: Darlene and Robert Blendheim of Seattle are struggling to keep their home after their subprime lender went out of business.

By MIKE McINTIRE NYTimes
Published: April 23, 2009

Judge Walt Logan had seen enough. As a county judge in Florida, he had 28 cases pending in which an entity called MERS wanted to foreclose on homeowners even though it had never lent them any money.

Into the Mortgage NetherworldGraphicInto the Mortgage Netherworld

MERS, a tiny data-management company, claimed the right to foreclose, but would not explain how it came to possess the mortgage notes originally issued by banks. Judge Logan summoned a MERS lawyer to the Pinellas County courthouse and insisted that that fundamental question be answered before he permitted the drastic step of seizing someone’s home.

Daniel Rosenbaum for The New York Times R. K. Arnold, MERS president, said the company helped reduce mortgage fraud and imposed order on the industry.

“You don’t think that’s reasonable?” the judge asked.

“I don’t,” the lawyer replied. “And in fact, not only do I think it’s not reasonable, often that’s going to be impossible.”

Judge Logan had entered the murky realm of MERS. Although the average person has never heard of it, MERS — short for Mortgage Electronic Registration Systems — holds 60 million mortgages on American homes, through a legal maneuver that has saved banks more than $1 billion over the last decade but made life maddeningly difficult for some troubled homeowners.

Created by lenders seeking to save millions of dollars on paperwork and public recording fees every time a loan changes hands, MERS is a confidential computer registry for trading mortgage loans. From an office in the Washington suburbs, it played an integral, if unsung, role in the proliferation of mortgage-backed securities that fueled the housing boom. But with the collapse of the housing market, the name of MERS has been popping up on foreclosure notices and on court dockets across the country, raising many questions about the way this controversial but legal process obscures the tortuous paths of mortgage ownership.

If MERS began as a convenience, it has, in effect, become a corporate cloak: no matter how many times a mortgage is bundled, sliced up or resold, the public record often begins and ends with MERS. In the last few years, banks have initiated tens of thousands of foreclosures in the name of MERS — about 13,000 in the New York region alone since 2005 — confounding homeowners seeking relief directly from lenders and judges trying to help borrowers untangle loan ownership. What is more, the way MERS obscures loan ownership makes it difficult for communities to identify predatory lenders whose practices led to the high foreclosure rates that have blighted some neighborhoods.

In Brooklyn, an elderly homeowner pursuing fraud claims had to go to court to learn the identity of the bank holding his mortgage note, which was concealed in the MERS system. In distressed neighborhoods of Atlanta, where MERS appeared as the most frequent filer of foreclosures, advocates wanting to engage lenders “face a challenge even finding someone with whom to begin the conversation,” according to a report by NeighborWorks America, a community development group.

To a number of critics, MERS has served to cushion banks from the fallout of their reckless lending practices.

“I’m convinced that part of the scheme here is to exhaust the resources of consumers and their advocates,” said Marie McDonnell, a mortgage analyst in Orleans, Mass., who is a consultant for lawyers suing lenders. “This system removes transparency over what’s happening to these mortgage obligations and sows confusion, which can only benefit the banks.”

A recent visitor to the MERS offices in Reston, Va., found the receptionist answering a telephone call from a befuddled borrower: “I’m sorry, ma’am, we can’t help you with your loan.” MERS officials say they frequently get such calls, and they offer a phone line and Web page where homeowners can look up the actual servicer of their mortgage.

In an interview, the president of MERS, R. K. Arnold, said that his company had benefited not only banks, but also millions of borrowers who could not have obtained loans without the money-saving efficiencies it brought to the mortgage trade. He said that far from posing a hurdle for homeowners, MERS had helped reduce mortgage fraud and imposed order on a sprawling industry where, in the past, lenders might have gone out of business and left no contact information for borrowers seeking assistance.

“We’re not this big bad animal,” Mr. Arnold said. “This crisis that we’ve had in the mortgage business would have been a lot worse without MERS.”

About 3,000 financial services firms pay annual fees for access to MERS, which has 44 employees and is owned by two dozen of the nation’s largest lenders, including Citigroup, JPMorgan Chase and Wells Fargo. It was the brainchild of the Mortgage Bankers Association, along with Fannie MaeFreddie Mac and Ginnie Mae, the mortgage finance giants, who produced a white paper in 1993 on the need to modernize the trading of mortgages.

At the time, the secondary market was gaining momentum, and Wall Street banks and institutional investors were making millions of dollars from the creative bundling and reselling of loans. But unlike common stocks, whose ownership has traditionally been hidden, mortgage-backed securities are based on loans whose details were long available in public land records kept by county clerks, who collect fees for each filing. The “tyranny of these forms,” the white paper said, was costing the industry $164 million a year.

“Before MERS,” said John A. Courson, president of the Mortgage Bankers Association, “the problem was that every time those documents or a file changed hands, you had to file a paper assignment, and that becomes terribly debilitating.”

Although several courts have raised questions over the years about the secrecy afforded mortgage owners by MERS, the legality has ultimately been upheld. The issue has surfaced again because so many homeowners facing foreclosure are dealing with MERS.

Advocates for borrowers complain that the system’s secrecy makes it impossible to seek help from the unidentified investors who own their loans. Avi Shenkar, whose company, the GMA Modification Corporation in North Miami Beach, Fla., helps homeowners renegotiate mortgages, said loan servicers frequently argued that “investor guidelines” prevented them from modifying loan terms.

“But when you ask what those guidelines are, or who the investor is so you can talk to them directly, you can’t find out,” he said.

MERS has considered making information about secondary ownership of mortgages available to borrowers, Mr. Arnold said, but he expressed doubts that it would be useful. Banks appoint a servicer to manage individual mortgages so “investors are not in the business of dealing with borrowers,” he said. “It seems like anything that bypasses the servicer is counterproductive,” he added.

When foreclosures do occur, MERS becomes responsible for initiating them as the mortgage holder of record. But because MERS occupies that role in name only, the bank actually servicing the loan deputizes its employees to act for MERS and has its lawyers file foreclosures in the name of MERS.

The potential for confusion is multiplied when the high-tech MERS system collides with the paper-driven foreclosure process. Banks using MERS to consummate mortgage trades with “electronic handshakes” must later prove their legal standing to foreclose. But without the chain of title that MERS removed from the public record, banks sometimes recreate paper assignments long after the fact or try to replace mortgage notes lost in the securitization process.

This maneuvering has been attacked by judges, who say it reflects a cavalier attitude toward legal safeguards for property owners, and exploited by borrowers hoping to delay foreclosure. Judge Logan in Florida, among the first to raise questions about the role of MERS, stopped accepting MERS foreclosures in 2005 after his colloquy with the company lawyer. MERS appealed and won two years later, although it has asked banks not to foreclose in its name in Florida because of lingering concerns.

Last February, a State Supreme Court justice in Brooklyn, Arthur M. Schack, rejected a foreclosure based on a document in which a Bank of New York executive identified herself as a vice president of MERS. Calling her “a milliner’s delight by virtue of the number of hats she wears,” Judge Schack wondered if the banker was “engaged in a subterfuge.”

In Seattle, Ms. McDonnell has raised similar questions about bankers with dual identities and sloppily prepared documents, helping to delay foreclosure on the home of Darlene and Robert Blendheim, whose subprime lender went out of business and left a confusing paper trail.

“I had never heard of MERS until this happened,” Mrs. Blendheim said. “It became an issue with us, because the bank didn’t have the paperwork to prove they owned the mortgage and basically recreated what they needed.”

The avalanche of foreclosures — three million last year, up 81 percent from 2007 — has also caused unforeseen problems for the people who run MERS, who take obvious pride in their unheralded role as a fulcrum of the American mortgage industry.

In Delaware, MERS is facing a class-action lawsuit by homeowners who contend it should be held accountable for fraudulent fees charged by banks that foreclose in MERS’s name.

Sometimes, banks have held title to foreclosed homes in the name of MERS, rather than their own. When local officials call and complain about vacant properties falling into disrepair, MERS tries to track down the lender for them, and has also created a registry to locate property managers responsible for foreclosed homes.

“But at the end of the day,” said Mr. Arnold, president of MERS, “if that lawn is not getting mowed and we cannot find the party who’s responsible for that, I have to get out there and mow that lawn.”

Posted in CitiGroup, concealment, conspiracy, fannie mae, foreclosure, foreclosure fraud, foreclosure mills, forensic loan audit, forensic mortgage investigation audit, Freddie Mac, investigation, jpmorgan chase, judge arthur schack, MERS, mortgage bankers association, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., Mortgage Foreclosure Fraud, mortgage modification, note, R.K. Arnold, securitization, wells fargoComments (0)

After foreclosure: How long until you can buy again? CNNMoney

After foreclosure: How long until you can buy again? CNNMoney


Again, FAIR ISAAC CORPORATION aka FICO: Now Worthless……It’s another scam taken over by wallstreet/mba to make us *think* we are worth a number!

By Les Christie, staff writerMay 28, 2010: 7:58 AM ET

NEW YORK (CNNMoney.com) — Walking away from a mortgage you can still afford to pay has consequences; everyone knows that. Your credit score is shot and it can be impossible to get credit.

Some homeowners, no doubt, believe that the credit score hit is worth getting out from a deeply underwater mortgage. They may owe, say, $500,000 when their house value is only valued at $350,000. And, they figure, there’s no way it will ever be worth what they owe so it’s better to get out from underneath the burden.

After default, they reason, they can raise their FICO scores by paying all their bills on time and eventually finance another home purchase.

Don’t count on it.

While homeowners who default due to economic hardship, such as a job loss or divorce, normally must wait two to five years before buying a home again, walkaways may face double that time.

“It could be well over seven or eight years before [walkaways] are able to obtain a mortgage to buy a home again,” said Jay Brinkmann, chief economist for the Mortgage Bankers Association.

How foreclosure impacts your credit score
“Credit scores are only one component of a complete credit decision,” Brinkmann said. “[In these cases] credit scores are not a good indicator of their willingness to continue to pay their mortgage.”

But future underwriters will scrutinize their records very closely, and if they find no precipitating factors leading to the defaults — no job loss, no health issues –the repaired credit score won’t overshadow the black mark of a walkaway.

“If you made a strategic decision to default on paying your mortgage, it will work against you,” said Bill Merrell of the National Association of Review Appraisers and Mortgage Underwriters.

Merrell, who teaches underwriting, said banks are looking at several factors in determining whether to grant mortgages: the amount of money borrowers have in the bank; employment histories; payment history.

However, banks may be far more lenient if the default resulted from factors somewhat beyond the borrower’s control, such as from local economic problems. “They’ll give you more consideration if it’s job related,” he said. But, he added, banks look at strategic defaults “very negatively.”

That said, it’s not impossible to get a loan. Banks still want to make interest payments, so they might be willing to gamble with a walkaway.

“It might be a little more difficult for them to borrow, but [banks’] drive for market share — to profit from making loans — will trump that caution,” said Keith Gumbinger, of the mortgage information publisher HSH Associates. “I don’t think we’ll see a full denial.”

It’s hard to foresee the state of mortgage lending six or seven months from now, let alone seven or eight years into the future. So lenders may look at applications from one-time strategic defaulters and say, “Yes, they walked away but it’s a whole different market now,” according to Gumbinger.

Even so, lenders may require more from borrowers who walked away than those who didn’t.

“To the extent they could get a mortgage,” said Brinkmann, “they can count on needing a heavy down payment.”

The lenders may ask for 30% down or more. That would provide enough collateral cushion that the bank could get all or most of its money back in a foreclosure.

Strategic defaulters might also be charged higher interest rates, even above the levels other borrowers with similar credit scores would receive.

Posted in fico, foreclosure fraud, mortgage bankers associationComments (0)

Poor Risk Management, Unrealistic Optimism Collapsed Housing: MBA

Poor Risk Management, Unrealistic Optimism Collapsed Housing: MBA


The originators/warehouse lenders knew *exactly* what they were doing.  That’s why they were immediately assigned!

And look at the bonuses the instigators received as *rewards* for their actions.

And then they lied about AAA ratings to sucker in US and foreign investors, including municipalities and state governments that are now in critical economic positions, as well.

BY: CARRIE BAY DsNEWS.com

It’s hard to pinpoint just what brought the nation’s thriving residential real estate market to its knees. Everyone’s got an opinion, but trying to nail down the exact trigger in order to prevent a sequel is a difficult task. The Mortgage Bankers Association (MBA) is attempting to do just that.

According to a study released Wednesday by the trade group, poor risk management habits, including insufficient data and incomplete performance metrics, coupled with a short-term focus and unrealistic optimism among senior business managers were all factors that contributed to the collapse of the U.S. housing and mortgage markets.

The study entitled, Anatomy of Risk Management Practices in the Mortgage Industry was conducted by Professor Cliff Rossi of the University of Maryland and sponsored by MBA’s Research Institute for Housing America (RIHA). It analyzes the risk management processes employed by mortgage lenders leading up to the housing crisis and discusses lessons learned for future risk managers.

Professor Rossi, who has more than 20 years’ experience within the mortgage industry and at regulatory agencies, says that as home prices increased, lenders were pressured to offer innovative products that could help borrowers afford a home. He found that the increase and expansion of risk layering that resulted, along with changes in borrower behaviors, left risk managers unable to offer reliable risk estimates.

“According to some empirical analysis, when market conditions changed, mortgage performance models proved unstable, with loans originated in 2006 defaulting at four times the rate of what a model prior to 2004 would have predicted,” Rossi explained. “Moving forward, it will be essential for the industry to develop early warning measures of the level of risk in new originations and less reliance on imprecise historical performance of new loan products.”

Rossi says that in addition to limited information available for proper risk assessment, corporate culture and cognitive biases also strongly influenced decision-making during the boom. He argues that one of the biggest black eyes to come out of the prosperous years leading up to the bust was the decline in senior management’s loss aversion, thanks to a lengthy period of strong home prices and low defaults, which in turn led to relaxed underwriting and again, higher levels of risk layering.

“The combination of informational limitations on risk managers and a governance structure and culture that may have tipped decisions in favor of business-driven strategies is central to explaining the increase in risk-taking that took place throughout the industry,” Rossi said. “As the industry is now compensating for the resulting losses through tighter underwriting standards and a lower appetite for risk, it will be vital for executive management to instill a culture where all employees are on guard for risks that exceed the risk appetite of the company.”

Key findings from the study include:

  • Subprime loan underwriting criteria along several risk attributes expanded between 1999 and 2006. In particular, combined loan-to-value ratios (LTVs) increased over time as the percentage of loans with silent second liens attached to the property also increased. At the same time, the percentage of loans with full documentation declined.
  • The relative lack of geographic and product diversification by a number of the largest mortgage lenders was rationalized by investment opportunity costs and relative value.
  • A false sense of security with new products originated prior to 2007 occurred as a result of better than average economic conditions coupled with a lack of information regarding subtle but real changes in borrower and counterparty behavior.
  • Cognitive bias toward risk management may have combined with management views on loss-taking to view risk managers as overly conservative and inefficient, which would explain senior management’s actions that ultimately placed their firms at risk.

Michael Fratantoni, MBA’s VP of research and economics, commented, “Today’s mortgage industry is operating under vastly different guidelines than just a few years ago and the survivors in the industry today are clearly the companies that did things right. There is room for debate on how best to proceed, but certainly building a stronger risk management framework around the mortgage industry will be critical.”

Posted in concealment, foreclosure fraud, mortgage bankers associationComments (0)

Calling on MERS “In fact, all the paper in the process is gone”.: Scott Cooley

Calling on MERS “In fact, all the paper in the process is gone”.: Scott Cooley


Calling on MERS

VIENNA, VIRGINIA–BASED MERS IS A great example of how technological solutions can work for the betterment of our industry. MERS’story is more typical, though, in terms of how long it took the company’s solution to become mainstream.

I’ve found that typically new technologies or new technology firms take five to seven years to become successful in this industry. Of course, it is difficult for startup companies to last that long, which is one of the main reasons there is such a high failure rate among these firms. From the start, MERS had widespread support from the Mortgage Bankers Association(MBA) and all the major mortgage companies. Originally, MERS wasn’t well-funded ($5.2 million), but in 1998 it was recapitalized with significant contributions from MBA, FannieMae and Freddie Mac—mostly interms of a line of credit. Still, it took five to seven years until MERS wash and handling millions of loans. Today, it has handled more than 30 million loans and just launched it’s next endeavor, called the MERS® eRegistry. It’s a great success story overall.

MERS’ eRegistry for eNotes was started in March 2003 (see www.mersinc.org for details). Its purpose is to provide a“pointer” to the location of the eNote, and it holds the legal identity of the controller. Any lender can then find the vault where the eNote is stored, as well as who controls it.

MERS provides the very valuable solution of tracking the eNote’s location without trying to compete with the private industry for all of the other actions that occur around an eNote, such as storage in a vault. By MERS’ own admission, this solution will take years before it becomes mainstream.

[…]

Today, most of the aforementioned parties are shipping the documents at great cost through carriers such as Federal Express. With VLF, all such shipping and the manual handling of the traditional loan folder is eliminated. In fact, all the paper in the process is gone. Yes, this is a form of imaging that some mortgage companies are using today. However, it goes much further, in that it would be used by all parties involved with each loan. In addition, it would also store the electronic data file of the loan and do so in a Mortgage Industry Standards Maintenance Organization Inc . (MISMO) format.

CONTINUE READING [SCOTT COOLEY]

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



Posted in foreclosure fraud, MERS, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., noteComments (1)

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