COMBO Title and Securitization Search, Report, Documents, Analysis & Commentary COMBO Title and Securitization Search, Report, Documents, Analysis & Commentary




If this is posted, it has be posted anonymously.

Many people seeking loan modifications have difficulty with their paperwork being lost. This rarely happens. The reason their documents go missing is because they are intentionally destroyed in order to prevent a loan modification in circumstances where Wells has a legal obligation to modify a loan. Wells Fargo had a legal obligation under its TARP agreement when it still had 25 billion in Federal money, and still has the obligation as part of its servicing agreements. If Wells has an obligation to modify, but doesn’t want to, they have to create a way of rejecting the modification application without there being a record of it. Losing the documents serves this purpose.

Documents are destroyed in “The Black Hole.” The people you talk to when you are seeking a loan modification have no knowledge of it. Many of them are temps, lacking experience in loan processing. It never registers with most of them that something strange is going on. The Black Hole is kept completely isolated from Wells Fargo servicing staff. Even if they realize it exists, they have no idea of its location.

Here’s how it works. Any document pertaining to a loan modification must pass through The Black Hole. A customer cannot simply submit a document directly to the people working on their modification application. Wells gives customers a fax number to submit their documents to. This fax number goes directly into the Black Hole. If physical documents are sent to a Wells Fargo fulfillment center (known as an FC), they are faxed to the Black Hole by servicing staff. If you send documents directly to a processor working on loan modification, they are forbidden to simply take the documents and work on your application. They must fax them to the black hole. Serving staff are only permitted to communicate with a borrower via telephone or mail using form letters- no email.

The people who work in servicing are completely cut off from The Black Hole. They have never talked to anyone who works there, they have never received any communication from it. Documents go into The Black Hole, sometimes they come out, sometimes they don’t. When documents disappear, it’s not random.
The following is my belief as to how the Black Hole works. I won’t give my reasons behind the belief, because it would be a long explanation. Documents sent to The Black Hole are converted to PDF documents. A software system scans the document, pulling the loan number. With the loan number, the system automatically pulls servicing data- such as payment history, investor info, loan to value at origination, and so on. Another existing software system (an LPS product) identifies the property location and data on the local real estate market. The Black Hole uses this information to make a decision about whether or not it is in the best interest of the lender/servicer to modify the loan.
If you are way upside-down in your house, the lender/servicer may not want to foreclose if they have a risk that they can’t saddle the investor with the loss- better modify that loan! What if they can foreclose, pay off the investor, and make money on the equity in the house?- your modification docs might get lost. Depending on who the investor is, they may want to drag things out to make higher servicing fees, or in the case of a government loan, make money by the fees charged for services by third party vendors, vendors in which the servicer has ownership interest. In the case of Wells, this would be RELS. There is nothing that warms the heart of a banker like risk-free fee income. The relationships with LPS and First American should also be given scrutiny.

I think it unlikely The Black Hole is actually in Wells Fargo. They have to keep it separate from their own staff, and separation provides a layer of insulation from discovery in lawsuits. It’s likely a service provided by LPS. It’s curious that other servicers who are LPS clients have a public record of the same kinds of loan modification document disappearance. My best guess for the name of the LPS product (software) that does this is LPS HAMP Solutions.

Why would Wells do this? Doesn’t this sound far-fetched? You have to understand how they think. First, a core element of Wells Fargo corporate culture is what they call “the Wells Fargo swagger.” This a polite way of saying that at Wells Fargo corporate, arrogance is a virtue. Legally, this is outside the application of any existing regulatory box. While all of the intent for violations of law are there, there is no precedent for the law having been applied in this way.  For example, Wells Fargo knows the O.C.C. could potentially apply Reg B to loan mod applications, but they have never done so. Plus, Reg B fines levied per occurrence. Even if the O.C.C. said that every instance of document destruction is the equivalent of a loan denial, what record is there that it occurred? Wells Fargo staff meets with the O.C.C. bi-weekly. They have an established system for their interaction. All of this falls outside of their established way of interacting. The internal Wells Fargo compliance system is built to serve this existing interaction.
This is why a big corporation like Wells can run circles around regulators, making money all the way. Regulators are under funded and understaffed. Wells makes it easy to do their job with compliance systems that tell the regulators what they want to hear, while they are way out in front of the Federal Government making money on the frontier.
Wells Fargo’s public statements regarding loan modification, as well as on many other subjects, are not credible. Remember the scandal in 2009 about charitable contributions? Earlier this year, Mark Heid stood up in front of Congress and, in sworn testimony, stated Wells Fargo had 17,000 people working to keep people in their homes. This was false. Using an internal system, I counted them. The total number was a lot less, and this included all of the people in loss mitigation, even all the people whose job it is to foreclose on houses- not keep them in their homes. Just prior to Mark Heid’s first appearance before congress in 2010, Wells Fargo converted existing loan fulfillment sites to loan modification- an effort to fluff the numbers – and started converting those fulfillment sites back to loan origination right after his second testimony. Even in the interim between the two congressional appearances, there were fulfillment sites internally listed as loan modifications sites that were at least partially committed to origination. In Wells Fargo’s Branch retail fulfillment system, there was (as of June 2010), approximately 6,500 people working in loan origination fulfillment- and creating a new loan is a lot more work than modifying an existing loan. I find Mark Heid’s testimony be very difficult to believe.  How do we know Wells Fargo is telling the truth when they claim to have modified over half a million mortgages? How can this be independently verified? The compliance agent for the Federal Loan Modification program is Freddie Mac, a company with whom Wells Fargo has old, very close, and very large (hundreds of billions of dollars) relationships. How do we know they are telling the truth about anything?


37 Responses

  1. No surprise by anonymous. I’ve had three loan mod attempts by WF. The first one they told me it will take 70-120 days to give me an answer yes or no. Two weeks later I received a foreclosure notice. I called my congressman and that ended that. My second loan mod attempt was rejected because on the phone they stated my home had plenty of equity, more than what I owed (not a subprime, not upside down) and that they would rather take the home than help me and my severely ill wife keep our home of 15 years. On the rejection letter- application they used my monthly gross (instead of net) against my monthly obligations. My congressman had an influence in that we received a third loan mod attempt but this one is called an “Internal modification”. Very swiftly my wife received her social security benefits and medicare in which we submitted into the 3rd application. We where approved with very little change from the original loan, same interest, -$100 per month. I will turn this offer down because we are now out of the woods, however, I will never ever do business with this bank again and or any other large wall street bank, we were treated extremely bad and it was uncalled for, we had perfect credit for decades, a severe illness was involved and we were only two payments behind. I’ve now opened new accounts with my credit union and may look at a Canadian Bank also. Within couple of months both SunTrust and WellsFargo can take a giant leap off a short pier.

  2. […] This post was mentioned on Twitter by Wanta Freedumb. Wanta Freedumb said: WELLS WHISTLEBLOWER REVEALS BLACK HOLE FOR DOCUMENTS AND PROCEDURES: http://t.co/4xO11F9 […]

  3. anyone know if AHMSI has relationship with LPS??

  4. I am posting this observation by this Wells Fargo employee to my website:


  5. Rabi, You are so right. HSBC is one of the nastiest and one of the crookedest.

    A friend of mine had a loan with them which she tried to bring current by sending in a certified check for $10,000 with a Forbearance Agmt issued by an attorney. She sent it by UPS special delivery with receipt required, and they “lost” the agreement, cashed her $10,000 check and sent her house to foreclosure. They foreclosed, and she lost the $10,000 and her home.

    The courts here in SC let this happen, and then she sued in Federal Court in Florida, because HSBC is in Florida. She also reported to the FBI–nothing, Still pending, still fraud, embezzlement, theft, forgery, etc. Disgusting! http://www.challengingforeclosure.com Sirak@challengingforeclosure.com

  6. Gardener
    email me at carra2009@gmail.com

    I am in northern calif.

    I may have a couple of calif attorneys you can check out.

  7. Abby in Ca., Are you in or near Sac Town? How may I contact you. I need serious hep finding an attorney and I thinik I have talked with you about 1 yr ago.

  8. Anyone had any dealings with Property Asset Management or law firm Baer Timberlake?

    Their mortgage assignment filed said to send documents to Wells Fargo. I’m trying to map all the dots. Thanks if you can provide some insight.

  9. Ok, that’s it, after reading what Abbey in Calif wrote, I’m putting a 20 foot wall around my house, these yahoos will never get in, beware of big big dog. Also beware of electric barb wire. Haha.

    So I write a letter, where’s the note and who owns it, to the new servicer of my home loan, some 58 days ago, they responded we will respond in 60 days, 2 days to go to receive something in the mail. I’m just going to quiet title I guess.

    It’s amazing, we submitted papers some 6 months ago for loan mod thru Chase. Then they inform us, some 3 months into it, that the new servicer will be Lender Business Process Services. I check and it’s IBM. What in the world is IBM doing in loan mods? Goes to show you. Once the the letter from Chase came and informed us LBPS would be the new servicer at so and so date, well the date happened and LBPS sent us an invoice and letters once a week – they made it sound so formal. Then I wrote the letter asking who owned the note. Well two days to go. It’s funny, those letters, and they are formed letters that look like photocopies, all had the disclaimer lingo ” This is a collection letter ……….”. Red Flag.

    Ever notice invoices from these great big companies or whatever is never on nice stationary, they all are form letters, photocopy format – means it is sent out in bulk.

  10. Stanley, what happened was theft. There is no other way to name it. We’d been hoodwinked. In the 80’s bankers committed the biggest bank robbery in history with the savings and loan scandal. Now it’s the biggest attempt at a land grab, and a coordinated attempt to steal the wealth of a nation, this moment in history. It is financial terrorism, and intentionally not recognized nor defined, for what it is, by the very ones committing this abomination.

    I feel like the Ones in Horton Hears a Who.

    “We are here, we are here, we are here!”

    “We are here, we are here, we are here!”

    “We are here, we are here, we are here!”

    “We are here, we are here, we are here!”

    Lawyers and judges, ‘yes’ you have your own dictionary, and ‘no’ the average man or woman does not know your ‘words of art’. BUT we are alive and we have a conscious…we are the conscious of the Universe and of the Cosmos, and we share the same corner of the Milk Way with many stars and galaxies. We are the eyes for which the Universe and the Cosmos experiences itself. We share this planet, the air, the water, and the soil. Your “words of art” cannot neither describe who we are, nor ‘ignore who we are’.

    Forget an affinity within three degrees. I am the Creator within and I declare we have an affinity within one degree. The Creator within knows all. There ARE NO secrets. You cannot hide from your deeds. Your words and your oaths and your laws will not help you.

    The Creator in us have unconditional love. We trust. Where there is trust, there is Love. We are One. We must evolve. A house divided cannot stand. Yet those among us judge themselves by their deeds. There are laws of nature that cannot be ignored. A predator that consumes all his prey must starve and die when there is nothing left to consume. A planet without oxygen producing plants must not be able to sustain life that requires oxygen. A bank that has become fiscally irresponsible and created junk obligations that exceed assets of value must be dissolved and exist no more.

    Genesis 1 God created male and female, in his image, he made “them” (mankind).
    Genesis 2, God rested and LORD God created. He took made ‘the man’ he formed and put him in a garden east of Eden. When ‘the man’ and Woman gained the knowledge (as a God), they were ‘cursed’ by LORD God (their creator), and sent out of Eden.
    (Wow!, cursed while in paradise…Great!!!)
    Well they are mixed with God’s male/female.

    Jesus parable spoke of the mixing the two creations.
    Matthew 13 (KJV) 24 – 30..(farmer plants good seed, as he sleeps his enemy plants tares, as they sprout the servants see tares growing with the wheat, ask if they should pull the tares, are told by the LORD (the keeper of the house until the master returns), to let them grow together and the reapers will remove them.

    We are dealing with some among us from a different creator. The lawyers and judges who have uprooted ‘life’; have uprooted law and stolen property and property rights from the Ones protected by their constitution. If not spiritually, you will have to come to terms that your ‘words of art’ denies ‘life’ it’s inalienable rights., by it’s Creator. By oath you were tricked into a deceptive world against the spirit of the Creator. Your words, by their use, cannot ignore nor erase what ‘really’ exist. Redefining life into fiction by ‘words of art’ is no better than displacing ‘life’ for a fictitious creditor that created fictitious value and declares fictitious ownership.

    We own the estate created by the Creator.

    If the bankers created the Heavens and the earth, they’d have a legitimate claim. They created nothing but fictitious money and fictitious corporations and titles for legal fictions. They’ve produced no sweat equity to build nor maintain, nor upkeep, nor improve the homes they steal. Hours of life was spent, converting bank credits to money of substance.

    If life and existence were valued like the ‘bald eagle’ this could never have happened.

    I love you, but share a bit of embarrassment that I am part of the Creation that has a conscious, and can do this to the spirit of the Creator as ‘life’ on this planet. I am embarrassed that you were ‘tempted’ by a select few into displacing many for a fictitious illusion of wealth, membership, and ownership.

    Light and Love,
    trespass unwanted, adult, alive, allodial, corporeal, live born, born alive, free, life, whole blood

  11. It’s funny we have’nt heard of the abuses perpetrated by HSBC. They seem to be keeping a low profile although they are one of the nastiest…… Any one out there please post.

  12. JR and Pam,

    If you have Wells Fargo and/or Regional Trustee Services Corp as your trustee, can you write to me?
    They are based out of Seattle. Our docs are fraudulent here in CA.

    Good posts everyone!

  13. Wells Fargo foreclosed on us about a year ago. We tried to get a modification from Wells back in Dec. of 08 in Jan 09. I don’t know if the Black Hole existed then, but we got the same story. Yes they had the docs and now they don’t. In complete frustration when I was talking to this rude thing she said to me “Well ma’am if you just paid your mortgage you would not be in this mess. You should have been more responsible.” I replied that we had sent doc with sensitive info at least 4 times. You said you had them and then we get a call a day later saying we need to send again. I called Wells irresponsible for loosing our info 4 times and that I knew they had no intention of modifying our loan.

    Our property was never underwater. Had a lot of equity in it even though property values were dropping. House did not sell at auction, but the house was sold REO 4 months later at an unbelievable high price. Large commissions for all involved. My former neighbors were stunned when they found out what my property sold for.

    In going through my foreclosure paperwork and the paperwork Wells had their attorney send to the BK court, I have found what I as well as others believe to be questionable paperwork. OK I will say it FRAUD. Our BK attorney was a joke. I believe there is a break in chain of title and I also believe that Wells had no legal standing to forelclosed on my house. I find things almost everyday in the paperwork that does not make sense. I found this site way to late.

    Pamela Edwards and JR I also live in WA. How do I get in touch with you? Is NW Trustee Services involved in your cases?

    I never believed what the head idiots of the banks said at the hearings. They made to out like this was some big joke

  14. Pj, and Stanley Putra,

    It is coming — just not fast enough for our liking..

  15. SO WHAT?? The judges and attorney generalwon’t rock the boat with Big Banks. They use fraud Mers assignments affidavits. No body cares. They took everythig anyway.

  16. While it is all well and good for an “insider” to spill the beans, is this really any surprise? Quantitative information needs to be supplied here, from the “whistelblower” .

    Consider all the people that were given false “HOPE” under HAMP, they stayed put and shut up… they were, or so they thought were the lucky ones that were tapped by the magic wand extending from DC & WS. This really in the end was a mass fishing expedition to get all the fraud off the books, sorry to say on both ends of the hook and reel!

    However 3 years and counting, makes it sure look like they ALL got more then they bargained for.

  17. Abby in CA

    What is Pres. Obama doing — who is really advising him?? So afraid of the banks power — Pres. Obama will cave to demands to show support of banks??? Mr. President — you disappoint.

  18. JR please contact us as we may have info that may help you out. We too are in Washington in tacoma and are going through very similar circumstances

  19. JR,

    Do not know details of your case — but will guarantee — not as they were stated in court. Consider whatever else you can to keep alive — much still being investigated. Keep it alive.

  20. article about Obama’s next chief of staff holding 7.6 million worth of Chase stock by
    Shahien Nasirpourt today 1/11/2011

    see below

  21. President Barack Obama’s next chief of staff holds more than $7.6 million worth of stock in JPMorgan Chase, according to a regulatory filing.

    William M. Daley, vice chairman at JPMorgan Chase, holds 175,678 shares in the $2.1 trillion behemoth, the nation’s second-largest bank by assets. Daley headed the firm’s Corporate Responsibility division, which included oversight of the firm’s lobbyists and relations with government officials.

    Daley exercised his holdings on Thursday, the same day Obama announced he was bringing in the former banker to run the White House. Daley acquired 201,913 shares to bring his total to 316,327, but sold 140,649 of those shares to cover tax liabilities, according to the filing with the Securities and Exchange Commission. JPMorgan shares closed at $43.40 on Monday.

    A White House official said Daley will sell his stake in his former employer.

    The administration has come under fire since Obama’s announcement that he would name a former banker to the pivotal role, which many experts describe as one of the most powerful positions in government. While business groups and various elected officials have hailed the choice as a move to repair the White House’s apparently fractured relationship with corporate America, those wary of Wall Street’s growing influence in Washington have denounced it as yet another sop to the nation’s largest banks.

    Daley’s holdings could present a conflict of interest, experts warn.

    “JPMorgan Chase is the nation’s second-largest bank. Anything and everything can involve them,” said Simon Johnson, a former chief economist at the International Monetary Fund who now teaches at the M.I.T. Sloan School of Management. Johnson, who’s been critical of the selection — warning that “Bill Daley now controls how information is presented to and decisions are made by the president

    ” — said it was “essential” for Daley to sell his stake.

  22. Rhode Island Attorney George E.Babcock with using Ibanez case from Massuchusetts today on special MERS Calendar in Superior Court in Rhode Island stops foreclosure dead in its tracks..: http://www.facebook.com/l.php?u=http%3A%2F%2Fwww.babcocklawoffices.com%2F&h=911e4

  23. I’d like to have a conversation with this person about some cases I have!


  24. I hope no one is naive enough to think Wells is the sole doer of these kinds of dastardly deeds.

  25. Wonderful! A real Whistleblower. I hope he gets lots and lots of money. WFB will not like that at all. It should make them sit up and take notice. I still want the upper level executes brought to trial and to jail. I have AHMSI on my loan, and they lost my documents 9 times. All the lenders/pretenders are crooks. I am sure they are all doing the same thing. http://www.challengingforeclosure.com Sirak@challengingforeclosure.com

  26. My story to a tee.
    The evil bank wins another. My home of over 25 years was “reverted back to lender” Friday. Game Over

    Sad thing is I won’t even be counted as a statistic for a HAMP approval or denial. The “bank ate my documents” isn’t a statistical category.

    I wish, with all the smart minds that came up with this program, someone couldn’t see there were no penalties, sanctions, fines or costs for the bank to just plain lie about someones application.

    There was no way around the “incomplete application excuse” it therefore didn’t have to be submitted for approval or denial, and therefore didn’t have to be graded! No extra credit for me submitting, re-submitting, re-re-submitting, re-re-re-submitting documents you get the idea.

    I did all that was asked of me, and turned in all requested documents, my HAMP was never acted on and my Sale date was postponed from 9-10, 11-5, 12-17, to 1-7. I did call and complain a week before each Sale date to get it postponed.

    Now I’m in Washington State and the non-Judicial Trustee used up the 120 days discretionary continuances on extending the Sale date and the Servicer Wells Fargo has run out the clock on a Freddie Mac loan.

    I tried all avenues from the US Treasury HAMP compliance to Freddie Mac borrower outreach trying to get the Sale date Canceled instead of Postponed while in modification.

    I do believe this is a slick way of foreclosing without admitting a HAMP modification denial. You just string along the homeowner until the clock runs out and then they claim their hands are tied due to the State foreclosure laws. Neat….

  27. It is simply unbelievable. These bankers are crooks, plain and simple. A few jail sentences to some high ranking employees and that includes lawyers defending these banks will go a long ways to getting other people to think about what they are doing and stop this fraud. As K. Denninger and W. Black would say, were are the jail sentences.? Nobody should be doing business with any bank these days, they will trick you and rob you w/o you even knowing it.

  28. Bank of America used the same Black Hole (I don’t think it’s a mere coincidence that we’ve heard this term from other banks’ employees) and the same delay with “lost” paperwork. Legal proof of fraud often pivots on proving a party’s “intent” to deceive or misrepresent. it has been said that intent is difficult to prove. How can this pattern NOT prove intent. When I first came online to “tell my story” and educate myself, I thought I had the worst imaginable story of abuse by the lender. I was taken aback when I saw case after case…hundreds, just like mine!

    The thing that really upset me was that during the banks delay, I was paying reduced payments trying to “protect” my chance of getting one of these nonexistent “permanent” loan mods.

    Something is wrong when the banks accept payments after a notice to accelerate and yet don’t apply the payment to the account until a full payment has accumulated. (The bank rep told me that’s how they handle it.) I also paid extra, as suggested, to apply to the escrow, but that wasn’t applied either.

    In light of how the bank refuses payments from borrowers because the payment does not clear the amount owed, what happens when the bank DID accept a partial payment? Would it be deemed a settlement of the amount owed? If so, wouldn’t partial payment accepted by the bank during loan mod delays, be a settlement each month? I am probably not on the right track with this, but I am very curious about this dynamic.

    This brings to mind the legal doctrine of laches…could it help our defense? Here’s a definition:

    laches n. the legal doctrine that a legal right or claim will not be enforced or allowed if a long delay in asserting the right or claim has prejudiced the adverse party (hurt the opponent) as a sort of “legal ambush.” (Wikipedia)

    I did not cause the delay, as I fully cooperated, submitting documents by fax six times. During the banks delay arrears accrued so high that I no longer could qualify for a loan mod, and my house was forced underwater.

    Also, is a bank responsible under the Privacy Act to protect confidential documents it requires containing all personal identifiers–name, address, SSN, income, and even an authorization to retrieve tax returns?

  29. Wells Fargo is just one layer in the “Onion” that is fully aware of it’s purpose to shield the Core.

    People are being lied to. Oh, but soon, when the market goes a little more, the mods will suddenly start happining with speedy precision! People are going to be overjoyed that the goverment finally forced the banks to act.

    My neighbors just got a wonderful mod from “RUN” * Name changed to protect the guilty.

    They got there payments reduced to HALF!

    They got to go into the bank, and on camera sign all these nice neat loan docs agreeing to pay the rest of there life. They still owed $300,000 more then the box was worth, but they get to keep it! It’s theirs.

    Never mind that what they originally signed was fraudulent, they just reaffirmed. Its super-tighty now. Even the boys at Shawshank could not loosen those shorts up.
    Just wait people, the mods will sonn be pumping out faster then Big Mac’s at Mickey D’s.

  30. It’s about time we had a whistle blower for Wells Fargo. I’m sick of their BS presenting themselves and their pristine paperwork with “very little errors.” It’s high time their “sterling” reputation was brought to light so we can see the real tarnish for what it is.

    Three times (Wachovia) claimed they had no record of my loan modification paperwork!! I got fed up and that’s when I sent out a debt validation letter and QWR, tender of payment, Rescission letter, etc. No response, of course.
    In fact, the latest is that they claim no record of a FedEx I sent to their payoff department, though anyone can go on the FedEx site and see it was received. They offered to open an “investigation.”
    Big deal!!
    Meanwhile, their agents are busy trying to evict us, climbing our fences, trying to pry open our locks.
    My friend just had a UD trial last week. Their agents showed up in court and blatantly tried to videotape them with their cell phone! The bailiff had to escort them out. These people are mean and greedy bastards and try to make homeowners look like criminals.

    I have reviewed my UD paperwork and a friend’s and they both contain fraud and forgery. If anyone wants the evidence, let Niel know and I will forward it to him.
    We are in southern California.


  31. I dont think CHASE is different. I send more than
    200 pages to CHASE ,even certified and the never
    received them. I feel the mailman would eat them.

  32. We homeowners need to start Quai Tam en masse
    and Lawyersand Settlements may be a foothold.
    We can start with all MERS ‘as nominee’ fraud, add the loan modification fraud, demand Quiet Title … again, en masse, which would overload their system of dirty dealings against qualified mods.
    Any suggestions as to another avenue to begin??

  33. I received a letter from The Offices of the President in Des Moine from a subordinate that was supposed to help me. He said on paper that Wells Fargo will only stop the sheriff’s sale 6 times. He said that Robosigning is ok in Wis because a judge goes over the papers.

  34. and a big Thank YOU whisle blower

  35. we welcome and should encourage whistle blowers.

    we love and need you to step forward with documentation, pictures, movies, copies, eecordinga, names, dates, cases, addresses, etc.

    the more info the better are there lawyers willing to wotk with these people?

    are there any whistle blowers for BAC, FIRST MAGNUS, MORTGAGE IT, MERS, ETC.

    WER NEEDS TO BE AWAre so they have a successful Outing and limited risk of being cought.

    many people do not come forward because they have no idea of what to do.

  36. BINGO! sounds just like BOA

  37. Two words
    chain of title
    Co Mingling of funds.

    Those are our only real issues.

    Neil Garfield Be strong and courageous
    May G-d Give you stregth.

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