TONIGHT! Why Lawyers Should Want Foreclosure Defense Cases and What They Are Missing $$$

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Tonight’s Show Hosted by Neil Garfield, Esq.

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This show is devoted to convincing the lawyers who will listen that they are missing out on something very profitable and important. Representing homeowners faced with foreclosure papers can and does present an opportunity for large paydays, consistent victories in court, and playing a part in changing the trajectory of home finance in this country and around the world.

In 2008 I presented a seminar that provided the essentials of foreclosure defense as we knew them at that time. We repeated it several times in different parts of the country. In that seminar, I also presented a business plan for lawyers to do it. It was the hub and spoke plan that allowed homeowners to pay monthly based upon the known length of time that any foreclosure would last.  About a dozen lawyers followed my instructions and made millions of dollars.

It’s time for a new push.

What Happened With Your “Loan” — By admitting that you received a loan you lose.

The plain truth is that homeowners are losing their cases through assymetry of information. They think they understand when they do not have a clue. They are admitting the obvious, which turns out to wholly untrue. In so doing they give the court no choice but to enter judgment aganst them. 


I am experimenting with new ways to present this. If you click on the above chart you will see that the application process is actually a dead end. Nobody actually agrees to lend any money. Nobody does lend money.

Money arrives later at the “closing” table but unknown to the borrower it is not a loan. Contrary to popular belief which is based on ignorance of the actual process, no loan is sold. No obligation is sold. Nobody ever becomes the owner of any loan or obligation. Nobody records a purchase of any loan obligation. And nobody maintains any loan account receivable.

Whether it is described as a loan broker or “loan originator” (for which there is no legal definition) it is there for the fees. It is not present to participate in any loan nor does it receive any profit from making a loan. It does not share in any profit from making a loan because there is no loan. There is no lender. Calling it a lender does not make it a lender.

But you can reverse that (and lose your case) by calling it a lender in your conversations, pleadings, motions, memoranda or argument in court.

  • As soon as you have done that, for purposes of that case, you have admitted the existence of the loan.
  • In so doing you have tacitly admitted that the loan broker or the originator was the lender.
  • In admitting that there was a lender you have identified the lender as the loan broker or originator.
  • By doing that you have admitted that the originator had ownership of the underlying obligation.
  • By admitting that, you have admitted that the originator or broker paid the money that appeared at the “closing table.”
  • By admitting that you have also admitted that the lender — or its “successor” — suffered an actual economic loss that was proximately caused by the “nonpayment” of the homeowner.
  • And so by admitting that you have admitted that the action for foreclosure is valid.

Just a word about “successors.” You will often find the word used. Sometimes “MERS and its successors.” Sometimes “MERS for XYZ and its successors.” A successor is a company who has purchased the obligation or who has purchased the company that owned the obligation. In residential transactions, there is almost no instance where such an event has occurred.

There are no successors. There are no companies even willing to pose as successors unless they are sham conduits — thinly capitalized to be thrown under the bus or thrown into bankruptcy. The way this is done is clever. Sometimes the sham is actually just a trade name masquerading as a company or a “trust.”

Trusts do not exist for legal purposes unless there is something of value entrusted to a person or company for purposes of administering that thing (res, in Latin) for the benefit of beneficiaries.

The place where many lawyers get hung up on that is that there exists an “allonge” or assignment of mortgage” or “assignment of beneficial interest” to, for example, U.S. Bank, as trustee for ABC-2006 certificates.

If you dig deep enough in discovery just under the surface you will find a “trust agreement.” The trust agreement never grants any powers to the administration of any affairs to the named trustee.  So U.S. Bank is actually prohibited from doing anything with the paper that is assigned to it. In fact, you will find that it lacks the right, power, or duty to even ask what is happening in “the trust.” So labeling it as trustee is merely window dressing and does not describe any trust relationship or position. But you can change all that and lose the case simply by your own reference to U.S. Bank as a trustee, which in turn admits the existence of a trust etc.

Note that the paper “entrusted” to the trustee is not for benefit of investors who, by the ay, are not beneficiaries of the trust. the securities broker is the beneficiary. And note also that the paper transfer of an interest in a mortgage is a legal nullity in all jurisdictions unless there is a contemporaneous transfer of ownership of the underlying obligation. This is further amplified by Article 9 §203 UCC, adopted in all US jurisdictions, that requires payment of value as a condition precedent for filing any foreclosure action.

Please also take notice of the fact that the purported delivery of the original note is mostly fiction since the original note was most likely destroyed shortly after the “Closing.” But even if delivery of the original note is deemed to have occurred, the possessor is neither a holder nor anyone else entitled to enforce it unless they received a delivery from someone who owned the underlying obligation or note.

This is where the Wall Street brokers have snookered the courts, the lawyers, and even homeowners themselves. A holder is someone who has possession and has the right to enforce. The case for foreclosure fails on this point unless, here it is again, the homeowner admits delivery or fails to contest it and allows the assumption of authority to enforce to operate without rebutting that presumption through discovery.

So when U.S. Bank or Bank of New York Mellon says it is appearing “not on its own behalf” you should take them at their word. They have no interest. Treating them as though they do have an interest only leads to the same series of conclusions described above causing the court of law to conclude that your defenses are both technical and dilatory. You have already admitted the case against you — so why are fighting it? That isn’t bias. It is the standard operating procedure. Courts are not exhibiting bias when they do that. They are following orders based upon centuries of legal precedent and statutes.

I have many followers who are adhering to the untenable notion that the courts are acting out of bias or even malice. They are not — even when the judge appears irritated. You must get off that tack which will gain you nothing and lead nowhere and get on board with a defense that actually does work, based on the facts and existing law. Getting angry with me for saying that homeowners are losing their cases rather than “banks” winning the case is a failure to recognize the fact that few people are able to make sense out of the process called “securitization” — a process that never actually happened in residential transactions with homeowners.

Neil F Garfield, MBA, JD, 73, is a Florida licensed trial and appellate attorney since 1977. He has received multiple academic and achievement awards in business and law. He is a former investment banker, securities broker, securities analyst, and financial analyst.


Nobody paid me to write it. I am self-funded, supported only by donations. My mission is to stop foreclosures and other collection efforts against homeowners and consumers without proof of loss. If you want to support this effort please click on this link and donate as much as you fee you can afford.

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  • But challenging the “servicers” and other claimants before they seek enforcement can delay action by them for as much as 12 years or more.
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Document Review for Dummies: Why homeowners and their lawyers get confused by documents proffered by foreclosure mills

It occurs to me that most questions I receive contain either an inquiry about the meaning of documents or statements as if they know the meaning of documents. So here is a short primer on reviewing documents that might help.


While this seems to be simply a matter of reading and common sense, there is more to it than that. If I draw a rough picture of a dollar bill and hand it to you, nobody will accept it as payment for anything even if the writing on it says “United States Currency” or “One Dollar.”

The reason for that is simply one short statement: No document is an event. And no label can change that. In the case of my artistic dollar, the event would have been a law that says anyone can draw a dollar bill and that everyone must accept it for all debts, public and private. No such preceding event has ever happened nor is it ever going to happen. People don’t issue currency.  Governments do that.

Labeling it as “one dollar” has no more meaning than angel wings in the snow. But while it is a lot less fun than angel wings, a really good fabricated picture of a dollar is likely to be accepted as if it was a real dollar bill. But passing the fake dollar is an illegal act subject to criminal and civil liability.

APPLICATION: Just because a document bears the label “deed,” “assignment” or “allonge” doesn’t make it so. But most homeowners, lawyers, judges and even regulators fail to recognize this basic common sense precept that has been enshrined in law since the law was first written. This error has even become doctrine, supported by legal presumptions if the face of the document confirms to what would ordinarily expect on the face of such a document.

EXAMPLE: An “assignment” is not an assignment of the mortgage unless (a) the grantor owns it and (b) the assignment also conveys ownership of the underlying debt (or the underlying debt was conveyed in a separate instrument by a grantor who owned the underlying debt). [NOTE: Even then the assignment might not be legally effective such as in the case where someone with toxic waste liability conveys the property to a dummy corporation to avoid being hit with damages, fines and penalties. The grantee must expressly or tacitly accept the assignment.] Ref: Article 9 §203 UCC.


The answer to this question there’s actually another question, to wit: what was the event in real life that the document was intended to memorialize?

This reminds me of what my contract professor in law school pounded into our heads on a daily basis, to wit: The note is not the debt — although it may be evidence of a debt.

The debt exists only in the event of a real-world transaction that is enforceable by law. In the case of loans, that is created upon delivery to the closing table. The debtor is the one who accepted that money with eh understanding he/she had to pay it back and the creditor is the one who gave him/her the money. The debt exists regardless f whether there was my written document. It exists independently of any written document.

If the Payee named on the promissory note is the one who paid money to the debtor/maker), the note is admissible evidence in court to prove the terms of repayment and the existence of the debt. In fact, the law has developed that such a note merges with the debt such that the maker and debtor are the same and the Payee and creditor are the same.

BUT if the Payee named on the promissory note is NOT the one who paid money to the debtor/maker), the note is NOT admissible evidence in court to prove the terms of repayment or the existence of the debt. HOWEVER, under modern law, the execution of the promissory note gives rise to its own independent liability of the maker regardless of whether there was any debtor-creditor relationship between maker and payee. Ref: Article 3 UCC.

Such liability can be enforced over the objection of the maker (that here was no real-world transaction giving rise to the obligation) if the party enforcing the note was a bona fide purchaser for value, acting in good faith and without knowledge of the borrower’s defenses at the time the note was purchased.

APPLICATION: Generally speaking, if there is no real-world event memorialized by the document proffered by a party in litigation, the document is inadmissible as proof of the matter asserted — i.e., that the homeowner owes a debt to the party seeking to enforce it. If there is some real-world event (i.e., the homeowner received the money), then the question becomes whether there existed a legal binding relationship between the Payee on the note and the party who paid the money.

BUT, if the party who paid the money did so with no intent to acquire it or retain ownership of the debt, directly or indirectly, then the payment to the homeowner must be categorized as something other than a loan.

There might still be a liability of the homeowner, but only after the court is able to look at the transaction as a whole, and determine the reason for payment and whether that reason was satisfied by the homeowner’s conduct — which in the case of mortgage loans means the execution of documents that might not have any real value except to start the process of the sale of securities having no relation to the ownership of the debt, note or mortgage.

Such a review would also take into account whether the real terms of the contract were disclosed and whether the homeowner had an opportunity to decline participation or bargain for other terms.

EXAMPLE: As explained above an assignment of mortgage is a legal nullity in all States unless the grantee has also paid value in exchange for a conveyance of ownership of the underlying debt —from someone who owns it. Article 9 §203 UCC, adopted in all 50 states, takes it one step further requiring such purchase before anyone could even e considered as a bona fide claimant to enforce a security instrument (mortgage or deed of trust).

So the question is ALWAYS whether such payment of value for the underlying debt ever occurred as an event in the real world.

BUT, an assignment of mortgage that APPEARS to be facially valid is often taken at face value by the homeowner, the lawyers, the course, and the regulators even though the document is not facially valid. Sometimes this is the result of ignorance or laziness. And that brings us to the next point.


This can be really tricky and unless you are prepared to really look at the signature block like you might look at a painting where various figures and shapes appear, you will probably tacitly admit the entire case against you. You have to look long and hard. Think “Where’s Waldo?”

Take absolutely nothing for granted.

So in court, the correct answer is “I don’t know.” After 10-20 years the homeowner has no idea what he/she signed. He/she doesn’t know if the document presented is real or fabricated. He/she, therefore, doesn’t know if that signature on that document is real or fake. SO why admit it? Tell the truth. You don’t know. Make them prove that the document is authentic, valid, and was properly signed by the homeowner(s) at the time fo the original transaction (note that I don’t call it “loan closing” anymore because I don’t think the transaction is legally or logically a loan).

Next on that assignment of mortgage or beneficial rights under a deed of trust: can you tell me in easy English who signed that document and on whose behalf the document was supposedly executed? On close examination in most cases, you cannot. If that cannot be determined from the face of the document then the document is not facially valid. If the document is not facially valid no legal presumptions can arise about its authenticity or validity.

APPLICATION: In most cases, the validity of an assignment cannot be determined without reference to “parol” (external) evidence. Such instruments are facially invalid unless there is something in the public official record that clears up the mystery. Only official public records carry the legal presumption of authenticity and validity as proof of the matter asserted.

NOTE THAT EVEN DOCUMENTS THAT APPEAR TO PASS THE FACIAL VALIDITY SMELL TEST MIGHT STILL BE EXCLUDED AS PROOF OF THE MATTER ASSERTED IF TIMELY OBJECTION IN PROPER FORM IS RAISED AS TO THE CREDIBILITY OF THE SOURCE: Self-proclaimed servicers are preferred by foreclosure mills as thought hey are third parties with no stake in the outcome of the litigation. Good discovery and motion practice could reveal that the reverse is true — the claimed servicer is really a foreclosure vehicle acting for concealed third parties and who goes out of business if the foreclosures are unsuccessful.


There are lots of it assumptions that you could make about such a signature block at the end of the document. None of them would be true. And none of them would make any sense. But it is custom and practice to ignore such signature block as though an authorized signature had occurred on behalf of a grantor who possessed something to grant.


      1. Does John Smith exist? [If you were creating a false document who would want to sign it with their real name?]
      2. Was John Smith an authorized signatory for Solvang?
      3. Was John Smith an employee who knew something about the content of what he was signing or did he just sign it because his job consisted of stamping it writing his signature on thousands of documents per day?
      4. Was John Smith employed by some other company that doesn’t appear on this signature block?
      5. Who owns Solvang? {If the answer is some investment bank then documents executed or created by them suffer from a lack of credibility that could bar their admission into evidence.]
      6. Is the power of attorney attached to the document?
      7. Is there any descriptive language that would enable the reader to ascertain the existence, provisions, and validity of any power of attorney at the time of signing? If not my opinion is that the document is facially invalid. External proof is required to determine whether such power exists and was granted by someone who (a) intended to grant it and (b) had ownership or control over the subject matter (i.e., the mortgage or deed of trust).
      8. Where does Make  A Wish Mutual Bank fit into the chain?
      9. Who is CSLOBS, Inc.?
      10.  Where and what is the registry of holders of certificates? See power of attorney analysis)
      11. Who are the holders of the certificates? [Since they are defined as the parties on whose behalf the document as executed, the absence of an actual name by which they could be identified renders the document facially invalid.]
      12. Are the holders of the certificates the owners of pro-rata shares of debts, notes or mortgages? How do we know that? If not, why are they mentioned?
      13. What exactly passes through where and who is involved in that?
Neil F Garfield, MBA, JD, 73, is a Florida licensed trial and appellate attorney since 1977. He has received multiple academic and achievement awards in business and law. He is a former investment banker, securities broker, securities analyst, and financial analyst.

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CLICK HERE ORDER ADMINISTRATIVE STRATEGY, ANALYSIS AND NARRATIVE. This could be all you need to preserve your objections and defenses to administration, collection or enforcement of your obligation.Suggestions for discovery demands are included.
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  • But challenging the “servicers” and other claimants before they seek enforcement can delay action by them for as much as 12 years or more.
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  • If you wish to retain me as a legal consultant please write to me at
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What to Think About on Appeal From an Unfavorable Trial Court Decision

In response to the rising number of requests for us to write briefs or narrations for briefs I submit this article which is my recent response to such a request. Here is an uncomfortable fact: most appeals arise because of mistakes made by the litigant in trial court, not the judge. All appeals MUST be based upon what did happen in the trial court not what should have happened. 


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Yes we write briefs or narration for briefs all the time. Costs run from a low of $6500 to a high (so far) of $15,000. It depends upon how much we need to do. Legal research alone is usually around $1500-$2500. You should have local counsel or appellate counsel to advise you on appellate procedure. There are time limits on everything including filing the notice of appeal which must state specifically what order is being appealed and that it is a final order. Sometimes people get kicked out of appellate process because their notice of appeal cited the wrong order and then the time limit for filing the correct notice has expired. It is very technical.

FACTOID: There are statistics on appeals. Generally only one in 6 appeals are successful by any measure and of those many of them are only partially successful requiring additional proceedings in the trial court. The higher you go in the hierarchy of appellate courts the less your chances your case will even be heard, much less decided in your favor. Neither the State nor the U.S, Supreme Court is under any obligation to hear your case. Of the 15% +/- that are “successful” at least half are criminal cases. That means cases involving a civil matter like foreclosure have about a 1 in 12 chance of being “successful” on appeal.
EXCEPTION TO THAT GENERAL RULE: It was pointed out to lawyers at a seminar at which bankruptcy judges were presenters, that the typical appeal from the decision of a bankruptcy judge is more susceptible to appeal than the ordinary decisions of courts of general jurisdiction. That is partly because bankruptcy judges) formerly called “magistrates” have limited jurisdiction and they frequently overstep their authority  to make any decision.
There are three separate and optional avenues for appeal. Most appeals from Bankruptcy court go to  a Bankruptcy Appellate Panel which is the least likely place to get a reversal. Second, many appeals are made direct to the Circuit Court of Appeals in which appellants typically don’t fare any better than the BAP. And lastly the one least used is an appeal to the Federal District Judge of general jurisdiction where the odds of success rise to 50%. The judges who pointed this out were perplexed why more people didn’t take that route.
When writing a brief, your audience is a clerk for the appellate judges. That is a young lawyer, so assume nothing. If you don’t grab the attention of the reader (clerk) immediately your appeal will be thrown onto the pile of cases that will be affirmed.
Appellate courts do not try cases — a fundamental fact that is often forgotten by lawyers and unknown to pro se litigants. Even if every judge on the panel thinks they would have decided the case differently they will probably affirm the trial judge’s decision. The principle working here is finality. The courts exist to create finality to disputes, for better or for worse. All decisions are viewed and reviewed in the context of preserving finality. The appellate court will only reverse a decision that is fundamentally wrong on the law. It will almost never reverse a decision that was wrong on the facts.
Most cases in which an appellate decision results in reversal are set up at trial. That means careful trial preparation such that a resistant judge is boxed into a corner and the issues for appeal are plain and simple. If your contested issue involves the judge’s discretion the trial court decision will be affirmed practically every time.
That said well crafted appeals that are presented with credibility and persuasion can still be filed with at least some prospect for success. Sloppy work will tank even the best case on appeal. Citations to the actual record on appeal are required — not arguing evidence that did not get into the court record (unless exclusion of evidence is the basis of the appeal). In foreclosure cases this is rare because the borrower lacks the evidence to “prove” a case.
The foreclosure case is about whether the party seeking the remedy of foreclosure was entitled to do so. Hence the issue in foreclosure cases is more often about the admission of evidence than the exclusion of evidence. Anyone can dash off a brief and “justify” a fee. Only lawyers well versed in the subject and the law surrounding the subject have any chance of producing an effective brief. The brief must be well-written with proper language, punctuation, grammar and context. It must be logical and persuasive. 

Beware of Magic Bullets

Departing from my usual format, there are a few things I want to say to people who are looking for relief from foreclosure and are hearing what they want to hear.

  • If someone tells you “just do this” they are partially or entirely wrong or worse.
  • Like everything life is complicated and that includes litigation. Any thought you are entertaining that you have some magic elixir in which you will summarily get a court order is delusional.
  • Every plan looks good on paper until it is implemented.

I am worried that those who in good faith are trying to find the magic bullet are promoting a misguided set of principles that will continue to make bad law. I admit that I contributed to this initially back in 2008 when I proposed that a quiet title action should wrap things up. I was dead wrong and the people who continue to pursue that strategy are always getting the same result: the homeowner loses and another case is either decided badly or worse, makes bad law with a legal opinion issued by a judge or panel of judges.

The truth is that a successful quiet title action is a rare bird along with similar strategies. And remember that an unenforceable document by one party is no reason to lift an encumbrance from the chain of title. In order to remove an encumbrance from the chain of title, the instrument must be completely void and no voidable. That means it should never have been recorded in the first place or that it is now void by operation of law. That is the ONLY circumstance in which a mortgage or deed of trust or assignment of mortgage can be lifted out of the chain of title.

I do agree with the strategy of attacking the assignments in a lawsuit or motion. The motions don’t get much traction but the lawsuits tend to do better if they are pursued aggressively and persistently, with full recognition that no bank or service is going to roll over and play dead even if you are completely correct on the law. Your opponents and their lawyers will do everything in their power to wear you down, undermine your confidence and the undermine the confidence of the lawyer representing the homeowner. Your strategy must be laser-focussed, supported by substantive law and procedure.

But I don’t agree that any lay person can accomplish an attack on assignments without a lawyer representing them. If the practice of law was just about the contents of a statute we wouldn’t need courts. It’s about procedure, rules of evidence and basic notions and biases of fairness.

It’s true that the substitutions of trustee, the assignments, the indorsements etc. are probably legally void. For the most part they are fabricated. An assignment of mortgage probably lacks any foundation.

But what you’re up against, for example, is the fact that an assignment of mortgage is often assumed to be an assignment of the debt and the note. An indorsement of the note is often assumed to be an assignment of the debt. Possession of the note is often assumed to be possession of the debt. Possession is then assumed to be the result of delivery. Delivery implies authority. Transfer of the note implies a transfer of the debt. Transfer of the debt implies the assignment of mortgage was proper under state statutes. And a proper assignment supports a declaration of default and foreclosure. A proper assignment means that party foreclosing is going to get the proceeds of sale on foreclosed property. End of story.

So that is where you stand when your challenge begins. Don’t kid yourself. The task is daunting.

Those conclusions are all legally valid assumptions and presumptions because that is what the law says should be done with these documents and events. Facial validity is like possession — it’s 9/10 of the law.

If you think you can simply challenge these assumptions and presumptions and events and quickly get an order that completely undermines the parties attempting to foreclose — without going through a grueling court battle — you are simply wrong.

That said, thousands of homeowners have indeed won based upon such challenges. Nearly all of those cases have been buried under seals of confidentiality. The way they won was by educating the judge, one small piece at a time, using persuasive court techniques that nobody other than an experienced trial lawyer knows how to use. By the time the case ended, the court, unwilling to strike all such foreclosures, was careful to detail the specific abuses and gaps in the case against the homeowner.

Bottom Line: If you have the money and the time and the commitment to oppose these illegal foreclosures, by all means do it. And if you must do it pro se, know that the opposition will steamroll you on procedure and the laws of evidence. So you must have some knowledgeable lawyer giving you specific guidance as each point becomes an issue. Don’t pursue any strategy that promises to be a quick fix.


Jesinoski Revisited. Rescission is in the details.

It continues to be true that the statute is clear, the rules of procedure are clear, and the rules of evidence are clear — yet trial courts are adamantly opposed to allowing homeowners to use the power granted to them by Congress.

The second ultimate decision by the trial court that Jesinoski had to tender the money to Countrywide before the rescission could be effective is just as wrong as the same court’s prior decision that  the rescission would not be effective — a decision that was unanimously overturned by SCOTUS.  It put a condition on the effectiveness of rescission when SCOTUS clearly stated, and the statute clearly stated, that there were no conditions for the effectiveness of rescission other than the required notice.

Virtually everyone is ignoring the elephant in the living room, to wit: Countrywide was not a lender or even an aggregator. It was a conduit for an aggregator and far removed from the actual transfer of funds attendant to the apparent loan.

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The ultimate decision in the Jesinoski case was against the rescission. This was wrong and in flagrant disregard of the Jesinoski decision rendered by the SCOTUS. The decision simply stated that the rescission WAS effective the moment it was dropped in the mail (or delivered.) You can read the attack on me in Bob Hurt’s blog in the above link.

Rescission was effective starting with the mailing and uncontested delivery of the notice of rescission, if someone wants to challenge it they must do so in a lawsuit to vacate the effective instrument. This is the most basic procedural law — you don’t get relief without asking for it and the way you ask for it is by filing an pleading in court and getting a decision vacating the rescission notice. This trial court never vacated the rescission probably because it knew it had no power to do so.

You can’t get relief unless you first establish legal standing. SCOTUS said that the rescission was effective in this case and all others like it. It is uncontested that rescission caused the note and mortgage to immediately become void – not conditionally but actually.

So in order to bring a claim you would need to file a claim stating that you are being injured by a wrongfully delivered notice of rescission. That is called standing. The only party who could do that is the owner of the debt, since the ownership of the note and mortgage (void instruments now) is irrelevant. And THAT is where the trial court got it wrong (again). In the absence of a pleading from the owner of the debt, the trial court was devoid of jurisdiction to render any decision in which there rescission was ignored.


Hurt, a non lawyer, is apparently attempting to discredit a Federal law. But he is voicing the party line of the banks. The trial court was twice in error when it entered judgment against Jesinoski and if Jesinoski had the resources to appeal again they MIGHT well have won. It does appear that the “issue” in the trial court was whether the rescission stands. Clearly the opposition did not follow the requirements of statute.
BUT it is possible for the appellate courts to see this as harmless error since the factual finding of the trial court was that proper disclosure was given to Jesinoski. While that finding is also appealable, appellate courts are not likely to intervene in a  finding of fact unless there was absolutely nothing in the court record to justify that finding.
So in the end this is about evidence and the failure to present it.
Since rescission is all about proper disclosure and since Jesinoski failed to show that required disclosure was not given at the “closing” of the loan, it may be assumed that they would have lost in an action brought by Countrywide or its successor to vacate the rescission. But that is an advisory decision prohibited to any court.
The assumption is improper. That is why we have rules of procedure. If you want relief you must plead for it not simply argue about it. Countrywide never filed a pleading to vacate the rescission, as far as I know. And the rescission was never vacated even by this decision.
The trial court decided instead to accept the challenge from a party without standing (CW did not own the debt and their standing was entirely based upon the void note and mortgage). Inherent in the trial court’s erroneous decision was the presumption that was used to allow Countrywide to oppose the rescission — i.e., that because it supposedly had the original note and mortgage, it therefore owned the debt. The rest is history.

This decision assumes that Countrywide had standing apart from the note and mortgage, i.e., ownership of the debt. And it also assumes that there was an action filed by Countrywide to vacate the rescission. Neither of these was addressed, much less the 20 day requirement for filing such an action. Instead the trial court simply continued its error by ignoring the rescission because of its factual finding that disclosures had been properly given. But the disclosures were given by people who withheld basic information that is required under the statute, to wit: the identity the lender and the identity of the creditor (i..e., owner of the debt).

So this case went down because Jesinoski did not stick with the requirements of burden of proof, and the requirement that a party with standing make the challenge to the rescission within 20 days. Ignoring the 20 day limitation period results in placing a condition to the effectiveness of there rescission in contradiction to the express wording of Federal Statute and SCOTUS. There are no conditions. Jesinoski failed to press the rules of evidence, based upon the written opinion, which could have landed a victory.

Virtually everyone is ignoring the elephant in the living room, to wit: Countrywide was not a lender or even an aggregator. It was a conduit for an aggregator and far removed from the actual transfer of funds attendant to the apparent loan.

This is why I am offering a seminar on evidence on February 2, 2018. The devil is in the details. And too many foreclosure defense lawyers do not properly prepare to attack the details. The trial court decision is basically a political decision, not a legal one. So it continues to be true that the statute is clear, the rules of procedure are clear, and the rules of evidence are clear — yet trial courts are adamantly opposed to allowing homeowners to use the power granted to them by Congress.


Register now for Neil Garfield’s Mastering Discovery and Evidence in Foreclosure Defense webinar.

Deed Theft Scams: Why Not Prosecute the Banks Too?

It is supreme irony that individual scam artists are being prosecuted for false representations and deed theft — while the the institutional scam artists on Wall Street did the same thing raking in trillions of dollars, without a whiff of criminal prosecution.

Get a consult! 202-838-6345 to schedule CONSULT, leave message or make payments.


What the fraudster did in this case was reprehensible and criminal. Any person who does this deserves jail. So beware of anyone who suggests that they have some nifty way to save you from foreclosure if you just deed the property to them. It’s an industry. And it is based on your payment of rent while they zig and zag with the banks.

Beware of any who promises you guaranteed results. The only thing that will stop a foreclosure judgment or sale is a court order from a court of competent jurisdiction. In the real world of the justice system there is no such thing as guaranteed results.

But when you look at the details, it is impossible to distinguish between the fraud visited upon the victim in the article linked above and the fraud visited upon the same victim that put him in the position of losing his home to another complete stranger.

Consider this:

  • The “loan” you received was merely one part of a fraudulent scheme in which the money of third parties was swindled from them and then applied to create the illusion of your loan.
  • The note you signed was to the sales agent for the fraudulent scheme and not to the party whose money was used to make the “loan.”
  • By receiving the money you are obligated to pay it back. That’s called the debt.
  • By signing the note you are obligated to make payments to the payee on the note. That’s your second liability and it WILL be enforced if someone pays real money for your signed note, at least before it goes into default. That person would be a holder in due course.
  • By signing the mortgage deed or deed of trust, you have put your home up as collateral to guarantee payments on the fraudulent note, not to guarantee payment of the debt.
  • The mortgage deed or deed of trust are deeds. How is the above transaction different from conventional deed theft?
Quote from article:
“The scammers are no longer content with stealing $5,000. Now they want the whole house,” said Dina Levy, who heads the Homeowner Protection Program in the New York attorney general’s office, which has spread word about deed theft and prosecuted culprits.
Isn’t that what happened on Wall Street? No longer content to overcharge you for unaffordable loans the banks want your whole house. And no longer satisfied to take your house they want ten times the value of your house by “trading” in securities that everyone treats as non-securities under the 1999 law. But they are securities and they are in violation of SEC regulations and laws defining theft as a crime on the grandest scale ever seen in human history.

People Who Were Wrong Are the Winners — SO FAR

First of all I don’t think Geithner caused the financial crisis. He certainly contributed to it but it probably would have happened even if he had not undercut Sheila Bair at every opportunity; and yes he should have listened to other people who were saying that the corruption on Wall Street had reached epic proportions.

Second, I think that neither Geithner nor his predecessor, Hank Paulson, as Treasury secretaries, had a real understanding of the crisis at any time up through today. And their bosses, Presidents Bush and Obama were even more clueless. And while they are probably culpable for their negligence and mismanagement of the crisis, the foreclosure madness would have occurred anyway.

Third, it is my belief that the culprits on Wall Street with all their tentacles stretched out across the globe were unstoppable by anyone except a good government with the resources to actually get to the bottom of it. What was missing was the desire to get rid of the problem and the naivete of the leaders in government in failing to notice that the entire banking industry was engaged in faking transactions and documents — and failing to ask why that was necessary.

Fourth my opinion is that the fault lies with the failure of anyone in government to learn anything relevant about the industries they were supposed to be regulating. If they had done so, starting in 1983 when derivatives became adolescent, the adult would have been far more tame and the crises would have been averted entirely.

Homeowners did not create the crisis. Tens of millions of homeowners did not congregate in a room thinking up 450 loan products when there were only 4 or 5. And saying they had bad judgment would absolve almost any perpetrator of economic crime because his victim was too stupid.

The laws were already in place. It was knowledgeable people that were missing. We needed and had faithful servants of the people — but as a society and as a nation each country contributed to the enormous problem that has now been created. And we will keep paying for it as banks take over all commodities we hold dear and “legally” corner the markets with stolen cash and property.

In Nocera’s article on Bankrupt Housing Policy, he points out that ” in the course of perusing another new book about the financial crisis, “Other People’s Houses,” by Jennifer Taub, an associate professor at Vermont Law School, I was reminded of an effort that took place in the spring of 2009 that could have made an enormous difference to homeowners, one that would have required no taxpayer money and might well have become law with a little energetic lobbying from the likes of, well, Tim Geithner. That was an attempt, led by Dick Durbin, the Illinois senator, to change the bankruptcy code so that homeowners who were underwater could modify their mortgages during the bankruptcy process. The moment has been largely forgotten; Taub has done us a favor by putting it back on the table.”

He goes on to say that he had correspondence with Sheila Bair who was undermined and stomped on by the Obama administration for even thinking about relief to homeowners. She was head of the FDIC and prevented from doing her job by a bankrupt policy of save the banks and damn the homeowners. “Because, as Bair told me in an email, “It would have been a powerful bargaining chip for borrowers.” Without the ability to file for bankruptcy, underwater homeowners unable to pay their mortgages were helpless to prevent foreclosures. With it, however, servicers and banks were far more likely to negotiate the debt load. And if they weren’t, a bankruptcy judge would rule on the appropriate debt to be repaid. For all the talk about the need for principal reduction, this change would have been the easiest way to get it.”

According to Adam Levitin, in the same article by Nocera, this should have been a “no-brainer.” I take that too mean that as I have explained above, brains were in short supply during the worst of what we have yet seen of the economic crisis that most of us think is not even half over. Obama may be leaving the crisis as his legacy not because he caused it but because he didn’t do anything about it — or at least anything right.

And I obviously agree with Nocera’s ending comment — “Why is it that the fear of moral hazard only applies to homeowners, and not to the banks?”

Gretchen Morgenson says Geithner admitted he was inept at times. ““We were human.” But this fails to address head-on the possibility that he was a captured regulator, a man locked into the mind-set of the very bankers he was supposed to oversee.”

Gretchen reports without objection from Geithner — “Last week, I asked Sheila C. Bair, the former chairwoman of the Federal Deposit Insurance Corporation, for her recollection of these events. She replied with an email recalling that in 2006, she attended her first Basel Committee meeting, the international negotiations that Mr. Geithner was referring to. While there, she pushed unsuccessfully to raise bank capital levels.

Why was she unsuccessful? “I was actively undermined by the Fed, the New York Fed and the comptroller of the currency,” she said. “I later complained to Tim about the way his representative on the Basel Committee had undermined me. He was unapologetic.”

Gretchen has not been given the resources to prove the corruption on Wall Street, but she knows it is there and as the fourth estate the NY Times should have provided her with a blank check for what would have been a Pulitzer or even a Nobel prize. for now we can only agree with her — “We were the lenders of last resort and should have been paid an enormous premium for the use of our money. We were not.”

There are suddenly a spate of articles on what went wrong because Geithner wrote a book and is selling it enhancing his own fortunes while he presided over the worst hit the middle class has had in our history.

Here is what investigators should have been looking for:

Behind door number 1 were the fools. These are the money managers who for reasons the defy explanation did no due diligence and bought empty mortgage bonds issued by a trust that was never going to receive the money, the loans or the property.

Behind door number 2 were the wolves of Wall Street including all the different brokers, dealers, banks, rating agencies and insurers, all the mortgage brokers, real estate brokers, and closing agents and title companies all in league to take as much money as they could out of the system and the hide it behind shadow money equivalent to ten times all the actual money in the world.

Behind door number 3 are the victims. These are the people who knew nothing about mortgages, derivatives or anything else. In the end they were convinced by super salespeople that they could never understand how they could afford the loan nor could they even understand why they must do it anyway. In Florida alone 10,000 such sales people were convicted felons. And yet when we talk of moral hazard we speak of people, and not banks. Why is that?

The Big Cover-Up in Our Credit Nation

Regulators have confirmed that there were widespread errors by banks but that the errors didn’t really matter. They are trying to tell us that the errors had to do with modifications and other matters that really didn’t have any bearing on whether the loans were owned by parties seeking foreclosure or on whether the balance alleged to be due could be confirmed in any way, after deducting third party payments received by the foreclosing party. Every lawyer who spends their time doing foreclosure litigation knows that report is dead wrong.

So the government is actively assisting the banks is covering up the largest scam in human history. The banks own most of the people in government so it should come as no surprise. This finding will be used again and again to say that the complaints from borrowers are just disgruntled homeowners seeking to find their way out of self inflicted wound.

And now they seek to tell us in the courts that nothing there matters either. It doesn’t matter whether the foreclosing party actually owns the loan, received delivery of the note, or a valid assignment of the mortgage for value. The law says it matters but the bank lawyers, some appellate courts and lots of state court judges say that doesn’t apply — you got the money and stopped paying. That is all they need to know. So let’s look at that.

If I found out you were behind in your credit card payments and sued you, under the present theory you would have no defense to my lawsuit. It would be enough that you borrowed the money and stopped paying. The fact that I never loaned you the money nor bought the loan would be of no consequence. What about the credit card company?

Well first they would have to find out about the lawsuit to do anything. Second they could still bring their own lawsuit because mine was completely unfounded. And they could collect again. In the world of fake REMIC trusts, the trust beneficiaries have no right to the information on your loan nor the ability to inquire, audit or otherwise figure out what happened tot heir investment.

It is the perfect steal. The investors (like the credit card company) are getting paid by the borrowers and third party payments from insurance etc. or they have settled with the broker dealers on the fraudulent bonds. So when some stranger comes in and sues on the debt, or sues in foreclosure or issues of notice of default and notice of sale, the defense that the borrower has no debt relationship with the foreclosing party is swept aside.

The fact that neither the actual lender nor the actual victim of this scheme will ever be compensated for their loss doesn’t matter as long as the homeowner loses their home.  This is upside down law and politics. We have seen the banks intervene in student loans and drive that up to over $1 trillion in a country where the average household is $15,000 in debt — a total of $13 trillion dollars. The banks are inserting themselves in all sorts of transactions producing bizarre results.

The net result is undermining the U.S. economy and undermining the U.S. dollar as the reserve currency of the world. Lots of people talk about the fact that we have already lost 20% of our position as the reserve currency and that we are clearly headed for a decline to 50% and then poof, we will be just another country with a struggling currency. Printing money won’t be an option. Options are being explored to replace the U.S. dollar as the world’s reserve currency. No longer are companies requiring payments in U.S. dollars as the trend continues.

The banks themselves are preparing for a sudden devaluation of currency by getting into commodities rather than holding their money in US Currency. The same is true for most international corporations. We are on the verge of another collapse. And contrary to what the paid pundits of the banks are saying the answer is simple — just like Iceland did it — apply the law and reduce the household debt. The result is a healthy economy again and a strong dollar. But too many people are too heavily invested or tied to the banks to allow that option except on a case by case basis. So that is what we need to do — beat them on a case by case basis.

Here it is: Nonjudicial Foreclosure Violates Due Process in Complex Structured Finance Transactions

No, there isn’t a case yet. But here is my argument.

The main point is that we are forced to accept the burden of disproving a case that had not been filed — the very essence of nonjudicial foreclosure. In order to comply with due process, a simple denial of the facts and legal authority to foreclosure should be sufficient to force the case into a courtroom where the parties are realigned with the so-called new beneficiary is the Plaintiff and the homeowner is the Defendant — since it is the “beneficiary” who is seeking affirmative relief.

But the way it is done and required to be done, the Plaintiff must file an attack on a case that has never been alleged anywhere in or out of court. The new beneficiary anoints itself, files a fraudulent substitution of trustee because the old one would never go along with it, and then files a notice of default and notice of sale all on the premise that they have the necessary proof and documents to support what could have been an action in foreclosure brought by them in a judicial manner, for which there is adequate provision in California law.

Instead nonjudicial foreclosure is being used to sell property under circumstances where the alleged beneficiary under the deed of trust could never prevail in a court proceeding. Nonjudicial foreclosure was meant to be an expedient method of dealing with the vast majority of foreclosures when the statute was passed. In that vast majority, the usual procedure was complaint, default, judgment and then sale with at least one hearing in between. Nearly all foreclosures were resolved that way and it become more of a ministerial act for Judges than an actual trier of fact or judge of procedural rights and wrongs.

But the situation is changed. The corruption on Wall Street has been systemic resulting in whole sale fraudulent fabricated forged documents together with perjury by affidavit and even live testimony. Contrary to the consensus supported by the banks, these cases are complex because the party seeking affirmative relief — i.e., the new “beneficiary” is following a complex script established long before the homeowner ever applied for a loan or was solicited to finance her property.

The San Francisco study concluded, like dozens of other studies across the country that most of the foreclosures were resolved in favor of “strangers to the transaction.” By definition, the use of several layers of companies and multiple sets of documents defining two separate deals (one with the investor lenders and one with the borrower, with the only party in common being the broker dealer selling mortgage bonds and their controlled entities) has turned the mundane into highly complex litigation that has no venue. In non-judicial foreclosures the Trustee is the party who acts to sell the property under instructions from the beneficiary and does so without inquiry and without paying any attention to the obvious conflict between the title record, the securitization record, the homeowner’s position and the prior record owner of the loan.

The Trustee has no power to conduct a hearing, administrative or judicial, and so the dispute remains unresolved while the Trustee proceeds to sell the property knowing that the homeowner has raised objections. Under normal circumstances under existing common law and statutory authority, the Trustee would simply bring the matter to court in an action for interpleader saying there is a dispute that he doesn’t have the power to resolve. You might think this would clog the court system. That is not the case, although some effort by the banks would be made to do just that. Under existing common law and statutory law, the beneficiary would then need to file a complaint, verified, sworn with real exhibits and that are subject to real scrutiny before any burden of proof would shift to the homeowner. And as complex as these transactions are they all are subject to simple rules concerning financial transactions. If there was no money in the alleged transaction then the allegation of a transaction is false.

It was and remains a mistake to allow such loans to be foreclosed through any means other than strictly judicial where the “beneficiary” must allege and prove ownership and the balance due on the loan owed to THAT beneficiary. Requiring homeowners with zero sophistication in finance and litigation to bear the initial burden of proof in such highly complex structured finance schemes defies logic and common sense as well as being violative of due process in the application of the nonjudicial statutes to these allegedly securitized loans.

By forcing the parties and judges who sit on the bench to treat these complex issues as though they were simple cases, the enabling statutes for nonjudicial foreclosure are being applied unconstitutionally.

The most important thing about cross examination in foreclosure cases

Whether it is on voir dire, which is a limited examination before the witness testifies to determine the legal competency of the witness, or on actual cross examination, the object is to bring out facts that are helpful in making your case or defending your position. When I teach cross examination, I refer to the triad — three things you must do in order to reach your goal. The three things are first to have a simple question with a goal in mind. Second to listen to the answer. Third, is the follow up, because you knew the probable answer and now you want to bring home your point. This applies to every question.

The first requires preparation for trial in which you decide your narrative and then develop the key points necessary to bring the court to the point where the trier of fact (mostly judges in foreclosure cases) joins your narrative. You’ll know if they have joined you or are leaning that way by their ruling on objections, by the questions they ask — and one warning sign that you are losing them is when they ask you for the relevancy of your question. Without preparation and a strong narrative to which you are committed, you won’t be able to answer the question about relevancy and you will have no issue preserved for appeal. You are probably looking to establish a question of ownership of the loan and to establish a question of the balance due, if any. The details on this are left out of this article because the opposition reads this and will be ready for you if we publish the series of retreads that apply to trying a foreclosure case.

Second is listening. This is something that lawyers need to do and is the reason they were hired in the first place. The homeowner is too emotionally attached to listen. They hear but they don’t listen and they don’t understand the significance of the question or the answer. Coming to court with a list of questions is a good idea. But many lawyers and pro se litigants fail because of the difference between hearing and listening. The answer is that most people just hear what’s being said. Others take the time to actually listen to what’s being said. There is a significant and monumental difference between hearing and listening. Hearing means that someone “hears” what’s being said and then translates the message into a meaning for himself. When you listen, however, you also take an extra moment to think about the person who’s speaking. It’s only then that you’ll have a clear understanding of what is trying to be conveyed. And only then can you move on to the third step.

The third step is follow-up. This is often confused with moving on to the next question. But your first question in the triad is merely the set up. The real stuff is in your follow-up because you actually listen to exactly what is being said. If the lawyer for the bank asks if the witness is familiar with the books and records of the Servicer, your objection is going to be leading, lack of foundation, and potentially hearsay. If you don’t object then the testimony comes in simply because you failed to object and thus preserve the issue for appeal. You will be subject to the same objections from the other side if you don’t have your ducks in a row.

So if the witness says he is “familiar” with the books and records, you should ask why, and then follow up with questions directed at how he prepared, how he actually knows (personal knowledge) that there was a loan from ABC, and exactly what he looked at in terms of documentation or computer screens. The answers will surprise you in some cases. Take the time to listen to the surprise answer and pause a moment on what you want to do with it and how you can make that answer serve the interests of your client.

Student Loans Are The Next Major Crack in Our Finance


COMBO Title and Securitization Search, Report, Documents, Analysis & Commentary CLICK HERE TO GET COMBO TITLE AND SECURITIZATION REPORT


Disclosure to Student Borrowers:

Editor’s Comment: 

“We have created a world of finance in which it is more lucrative to lose money and get paid by the government, than to make money and contribute to society.  In the Soviet Union the government ostensibly owned everything; in America the government is a vehicle for the banks to own everything.”—Neil F Garfield

While the story below is far too kind to both Dimon and JPMorgan, it hits the bulls-eye on the current trends. And if we think that it will stop at student loans we are kidding ourselves or worse. The entire student loan mess, totaling more than $1 trillion now, was again caused by the false use of Securitzation, the abuse of government guaranteed loans, and the misinterpretation of the rules governing discharge ability of debt in bankruptcy.

First we had student loans in which the government provided financing so that our population would maintain its superior position of education, innovation and the brains of the world in getting technological and mechanical things to work right, work well and create new opportunities.

Then the banks moved in and said we will provide the loans. But there was a catch. Instead of the “private student” loan being low interest, it became a vehicle for raising rates to credit card levels — meaning the chance of anyone being able to repay the loan principal was correspondingly diminished by the increase in the payments of interest.

So the banks made sure that they couldn’t lose money by (a) selling off the debt in securitization packages and (b) passing along the government guarantee of the debt.  This was combined with the nondischargability of the debt in bankruptcy to the investors who purchased these seemingly high value high yielding bonds from noncapitalized entities that had absolutely no capacity to pay off the bonds.  The only way these issuers of student debt bonds could even hope to pay the interest or the principal was by using the investors’ own money, or by receiving the money from one of several sources — only one of which was the student borrower.

The fact that the banks managed to buy congressional support to insert themselves into the student loan process is stupid enough. But things got worse than that for the students, their families and the taxpayers. It’s as though the courts got stupid when these exotic forms of finance hit the market.

Here is the bottom line: students who took private loans were encouraged and sold on an aggressive basis to borrow money not only for tuition and books, but for housing and living expenses that could have been covered in part by part-time work. So, like the housing mess, Wall Street was aggressively selling money based upon eventual taxpayer bailouts.

Next, the banks, disregarding the reason for government guaranteed loans or exemption from discharge ability of student loan debt, elected to change the risk through securitization. Not only were the banks not on the hook, but they were once again betting on what they already knew — there was no way these loans were going to get repaid because the amount of the loans far exceeded the value of the potential jobs. In short, the same story as appraisal fraud of the homes, where the prices of homes and loans were artificially inflated while the values were declining at precipitous rate.

Like the housing fraud, the securitization was merely trick accounting without any real documentation or justification.  There are two final results that should happen but can’t because Congress is virtually owned by the banks. First, the guarantee should not apply if the risk intended to be protected is no longer present or has significantly changed. And second, with the guarantee gone, there is no reason to maintain the exemption by which student loans cannot be discharged in bankruptcy. Based on current law and cases, these are obvious conclusions that will be probably never happen. Instead, the banks will claim losses that are not their own, collect taxpayer guarantees or bailouts, and receive proceeds of insurance, credit default swaps and other credit enhancements.

Congratulations. We have created a world of finance in which it is more lucrative to lose money and get paid by the government, than to make money and contribute to the society for which these banks are allowed to exist ostensibly for the purpose of providing capital to a growing economy. So the economy is in the toilet and the government keeps paying the banks to slap us.

Did JPMorgan Pop The Student Loan Bubble?

Back in 2006, contrary to conventional wisdom, many financial professionals were well aware of the subprime bubble, and that the trajectory of home prices was unsustainable. However, because there was no way to know just when it would pop, few if any dared to bet against the herd (those who did, and did so early despite all odds, made greater than 100-1 returns). Fast forward to today, when the most comparable to subprime, cheap credit-induced bubble, is that of student loans (for extended literature on why the non-dischargeable student loan bubble will “create a generation of wage slavery” read this and much of the easily accessible literature on the topic elsewhere) which have now surpassed $1 trillion in notional. Yet oddly enough, just like in the case of the subprime bubble, so in the ongoing expansion of the credit bubble manifested in this case by student loans, we have an early warning that the party is almost over, coming from the most unexpected of sources: JPMorgan.

Recall that in October 2006, 5 months before New Century started the March 2007 collapsing dominoes that ultimately translated to the bursting of both the housing and credit bubbles several short months later, culminating with the failure of Bear, Lehman, AIG, The Reserve Fund, and the near end of capitalism ‘we know it’, it was JPMorgan who sounded a red alert, and proceeded to pull entirely out of the Subprime space. From Fortune, two weeks before the Lehman failure: “It was the second week of October 2006. William King, then J.P. Morgan’s chief of securitized products, was vacationing in Rwanda. One evening CEO Jamie Dimon tracked him down to fire a red alert. “Billy, I really want you to watch out for subprime!” Dimon’s voice crackled over King’s hotel phone. “We need to sell a lot of our positions. I’ve seen it before. This stuff could go up in smoke!” Dimon was right (as was Goldman, but that’s another story), while most of his competitors piled on into this latest ponzi scheme of epic greed, whose only resolution would be a wholesale taxpayer bailout. We all know how that chapter ended (or hasn’t – after all everyone is still demanding another $1 trillion from the Fed at least to get their S&P limit up fix, and then another, and another). And now, over 5 years later, history repeats itself: JPM is officially getting out of student loans. If history serves, what happens next will not be pretty.

American Banker brings us the full story:

U.S. Bancorp (USB) is pulling out of the private student loans market and JPMorgan Chase (JPM) is sharply reducing its lending, as banking regulators step up their scrutiny of the products.

JPMorgan Chase will limit student lending to existing customers starting in July, a bank spokesman told American Banker on Friday. The bank laid off 24 employees who make sales calls to colleges as part of its decision.

The official reason:

“The private student loan market is continuing to decline, so we decided to focus on Chase customers,” spokesman Thomas Kelly says.

Ah yes, focusing on customers, and providing liquidity no doubt, courtesy of Blythe Masters. Joking aside, what JPMorgan is explicitly telling us is that it can’t make money lending out to the one group of the population where demand for credit money is virtually infinite (after all 46% of America’s 16-24 year olds are out of a job: what else are they going to?), and furthermore, with debt being non-dischargable, this is about as safe a carry trade as any, even when faced with the prospect of bankruptcy. What JPM is implicitly saying, is that the party is over, and all private sector originators are hunkering down, in anticipation of the hammer falling. Or if they aren’t, they should be.

JPM is not alone:

Minneapolis-based U.S. Bank sent a letter to participating colleges and universities saying that it would no longer be accepting student loan applications as of March 29, a spokesman told American Banker on Friday.

“We are in fact exiting the private student lending business,” U.S. Bank spokesman Thomas Joyce said, adding that the bank’s business was too small to be worthwhile.

“The reasoning is we’re a very small player, less than 1.5% of market share,” Joyce adds. “It’s a very small business for the bank, and we’ve decided to make a strategic shift and move resources.”

Which, however, is not to say that there will be no source of student loans. On Friday alone we found out that in February the US government added another $11 billion in student debt to the Federal tally, a run-rate which is now well over $10 billion a month an accelerating: a rate of change which is almost as great as the increase in Apple market cap. So who will be left picking up the pieces? Why the Consumer Financial Protection Bureau, funded by none other than Ben Bernanke, and headed by the same Richard Cordray that Obama shoved into his spot over Republican protests, when taking advantage of a recessed Congress.

“What we are likely to see over the next few months is a lot of private education lenders rethinking the product, particularly if it appears that the CFPB is going to become more activist,” says Kevin Petrasic, a partner with law firm Paul Hastings.

“Historically there’s been a patchwork of regulation towards private student lenders,” he adds. “The CFPB allows for a more uniform and consistent approach and identification of the issues. It also provides a network, effectively a data-gathering base that is going to enable the agency to get all the stories that are out there.”

The CFPB recently began accepting student loan complaints on its website.

“I think there’s going to be a lot of emphasis and focus … in terms of what is deemed to be fair and what is over the line with collections and marketing,” Petrasic says, warning that “the challenge for the CFPB in this area is going to be trying to figure out how to set consumer protection standards without essentially eviscerating availability of the product.”

And with all private players stepping out very actively, it only leaves the government, with its extensive system of ‘checks and balances’, to hand out loans to America’s ever more destitute students, with the reckless abandon of a Wells Fargo NINJA-specialized loan officer in 2005. What will be hilarious in 2014, when taxpayers are fuming at the latest multi-trillion bailout, now that we know that $270 billion in student loans are at least 30 days delinquent which can only have one very sad ending, is that the government will have no evil banker scapegoats to blame loose lending standards on. And why would they: after all it is this administration’s sworn Keynesian duty to make every student a debt slave in perpetuity, but only after they buy a lifetime supply of iPads. Then again by 2014 we will have far greater problems (and for most in the administration, it will be “someone else’s problem”).

For now, our advice – just do what Jamie Dimon is doing: duck and hide for cover.

Oh, and if there is a cheap student loan synthetic short out there, which has the same upside potential as the ABX did in late 2006, please advise.

Countrywide settlement pays fraction to investors – Shell Game Continues

EDITOR’S NOTE: The shell game continues. While the media picks up stories about “settlements” giving rise to the presumption that Countrywide Home Loans and Bank of America and the rest of the securitization players committed various violations of statutes, duties, rules and regulations, the main point gets lost. Where is this money going and WHY? What is the tacit or express admission in paying that money and what effect does it have on the average homeowner sitting with a loan whose obligation is being paid in these settlements?

Think about it. If Bank of America, which now owns Countrywide, is paying “fractions” to investors who purchased mortgage bonds then who is it that owns the underlying mortgages and loans? Did Bank of America pay the investors do it under a reservation of rights (subrogation) to enforce the underlying loans? If not, then why are they foreclosing? All evidence is to the contrary. There is no subrogation under these purchases, insurance, credit default swaps or any other contract — not that I ever saw and not that my sources in the industry tell me was ever even contemplated much less executed. The same holds true for all those bonds the Federal Reserve is holding.

If Bank of America is paying “fractions” to investors who purchased mortgage bonds, why was it a fraction? Is it because the value of the bond was much lower than the price paid by the investor? Is it just a convenient settlement? Or is it because the investors have also received funds from other sources?

This is what I am referring to when I address “factual constipation.” How are these payments being allocated? Did the owners of the bonds actually have any definable interest in the underlying mortgage loans? If they did, why are these payments not being allocated to the obligations or payments due under those underlying mortgage loans? If they didn’t, why did they get paid anything? How will we ever know without getting a full accounting from all the parties that claim some stake or ownership interest or receivable interest in me is underlying mortgage loans?

It is black letter law as well as common law dating back centuries that nobody can collect the same debt more than once. If they do collect more than once there is a clear right of action by the borrower to collect the excess payment through a lawsuit for unjust enrichment, breach of contract and other causes of action. Here we have an intentional act designed to collect the same debt multiple times. In my opinion this does not merely indicate the presence of an action for fraud, it clearly shows an interstate pattern of racketeering that at one time in our history had the Department of Justice and the FBI busy putting people in jail.

Only in America where the news has turned into an entertainment blitz used by those with the most power and the most money to get their message across, even if it is a total lie. Somehow many if not most people have the impression that the borrowers and the securitized mortgages executed between 2001 and 2009 are not entitled to the relief that any other debtor is entitled to receive––that is the obligation has been reduced for any reason, the borrowers should get credit and if any party receives money in excess of the net amount due after credits, the creditor becomes the debtor owing money to the former borrower.

The bullet point that is being used to distort the perception of our citizens and policymakers is that these borrowers should not get a  “free house.” Without getting a full accounting from all parties that advanced funds to and from the original investors who purchased mortgage bonds or collateralized debt obligations and related hedge products, there is no way of knowing the amount of the credit which is due to the borrower. Yes, it is possible that the amount received by the various intermediaries in the securitization chain exceeded the original obligation due from the borrower.

In that case, the borrower owes nothing to the originating lender or the successors to that lender. But if there is still a class of investor or institution that can prove a loss resulting from the nonpayment of the obligation by the borrower (as opposed to non-payment from other parties in the securitization chain) then the law allows that party to recover the loss from those that caused it.  That probably includes the borrower, which means that we are not seeking a free house, we are seeking a truthful accounting.

BUT the fact that this obligation theoretically exists does not mean and never did mean under any legal decision in existence that the obligation should be paid to anybody who claims it. By all substantive and procedural law, the obligation is payable to one who proves the obligation and to one who proves it is owed to them and nobody else.

Yet in the view of many judges the challenge by the borrower is viewed as a delay tactic or an attempt to use technical deficiencies to a gain a free house on a lawn that the borrower sought but could not pay.  No doubt this is true in some cases. But in nearly all the cases, armies of salespeople using names like “loan expert” pounded on doors and rang the phones of people who had no thought of borrowing money on homes, in many cases, that were debt-free and had been in the family for generations. Now many of those homes are bank owned property.

The simple question that needs to be posed to anyone who looks at the borrower as anything other than a victim is which is more likely? Did the owners of 20 million homes enter into a conspiracy to defraud the financial system, half society and our taxpayers? Did these people have the sophistication, education, knowledge, experience or training to pull off such a caper? Or is it more likely that the Wall Street titans stepped over the line and instead of increasing liquidity for the benefit of consumers and small businesses, used their position to deplete the resources of unsuspecting citizens, pension funds, financial institutions and governmental units from the top federal levels down to the smallest local geographical areas?

Countrywide settlement pays fraction to investors

By ALAN ZIBEL (AP) – Aug 3, 2010

WASHINGTON — Former shareholders of fallen mortgage giant Countrywide Financial Corp. are in line to recoup a fraction of their investments now that a Los Angeles judge has approved a settlement worth more than $600 million settlement.

The payoff doesn’t come close to compensating for the money lost by investors. But it could prompt more lenders to settle legal disputes at the center of the housing bust.

Bank of America, which bought Countrywide two years ago, agreed to pay $600 million to end a class-action case filed against the company. KPMG, Countrywide’s accounting firm, will pay $24 million.

Several New York pension funds who served as lead plaintiffs alleged that Countrywide hid how risky its business had become during the housing market’s boom years. Calabasas, Calif.-based Countrywide was once the nation’s largest mortgage lender.

The agreement stands to return about 40 cents per share of Countrywide’s common stock, before legal fees and expenses. Consider that the stock peaked at $45 a share in February 2007, before the financial crisis. So an investor who held 100 shares could bank on receiving $40 for an investment that was once worth $4,500.

Shareholders did receive 0.1822 shares of Bank of America’s stock for each share of Countrywide they owned when Bank of America acquired Countrywide. That worked out to about one share for every 5.5 shares of Countrywide stock. Shares of Bank of America closed at $14.34 on Tuesday. So that same 100 shares of Countrywide would be worth about $261 today in Bank of America stock.

Add the $40 from the settlement and those shares are now worth little more than $300.

Lawyers for the pension funds are requesting $56 million, or 4 cents per share, for fees and other costs.

Investors “will be compensated for a significant portion of the legal damages that they suffered as a result of what we believe was a violation of the securities laws,” said Joel Bernstein, a lawyer for the pension funds. “They won’t be compensated for every penny of that.”

Bank of America has been trying to put Countrywide’s legal problems behind it. In June, the Charlotte, N.C.-based company agreed to pay $108 million to settle the Federal Trade Commission’s charges that Countrywide collected outsized fees from about 200,000 borrowers facing foreclosure.

It reached a settlement Monday primarily to keep legal fees from escalating, a bank spokeswoman said.

“Countrywide denies all allegations of wrongdoing and any liability under the federal securities laws,” said Shirley Norton, a spokeswoman for Bank of America. “We agreed to the settlement to avoid the additional expense and uncertainty associated with continued litigation.”

Plaintiffs attorneys have pursed lawsuits against numerous lenders and investment banks in the wake of the housing market’s devastating downturn, and the Countrywide settlement could encourage even more such cases, said Paul Hodgson, a senior research associate at The Corporate Library, an independent corporate governance research firm.

“There are a lot of suits out there waiting to get launched,” Hodgson said. “I think this is the opening of the floodgates.”

Former Countrywide CEO Angelo Mozilo, former President David Sambol, former CFO Eric Sieracki and former board members were named in the litigation but are not contributing to the settlement.

But it does not end their legal problems. More than a year ago the Securities and Exchange Commission brought civil fraud charges against Mozilo and the two other former executives. Mozilo, the most high-profile individual to face charges from the government in the aftermath of the financial crisis, has denied any wrongdoing.

For Countrywide, “This is only a chapter and not the end of the book,” said John Coffee, a securities law professor at Columbia University.

Foreclosure Prevention 1.1

Nobody ever thought that returning a lady’s purse to her after a purse snatcher ran away with it was a gift. So why is anyone contesting returning the purse to homeowners who had their lives snatched from them?

The baby steps of the Obama administration are frustrating. Larry Summers, Tim Geithner and those who walk with Wall Street are using ideology and assumptions instead of reality and facts.

First they started with the idea of modifications. That would do it. Just change the terms a little, have the homeowner release rights and defenses to what was a completely fraudulent and deceptive loan transaction (and a violation of securities regulations) and the foreclosure mess would end. No, it doesn’t work that way.

The reality is that these homeowners are being drained every day and displaced from their lives and homes by the consequences of a scheme that depended upon fooling people into signing mortgages under the false assumption that the appraisal had been verified and that the loan product was viable. All sorts of tricks were used to make borrowers think that an underwriting process was under way when in fact, it was only a checklist, they were even doing title checks (using credit reports instead), and the viability of the loan was antithetical to their goals, to wit: to have the loans fail, collect on the insurance and get the house too without ever reporting a loss.

Then it went to modification through interest rate reduction and adding the unpaid monthly payments to the end of the mortgage. Brilliant idea. The experts decided that an interest rate reduction was the equivalent of a principal reduction and that everything would even out over time.

Adding ANYTHING to principal due on the note only put these people further under water and reduced any incentive they had to maintain their payments or the property. Reducing the interest was only the equivalent of principal reduction when you looked at the monthly payments; the homeowner was still buried forever, without hope of recovery, under a mountain of debt based upon a false value associated with the property and a false rating of the loan product.

Adding insult to injury, the Obama administration gave $10 billion to servicing companies to do modifications — not even realizing that servicers have no authority to modify and might not even have the authority to service. Anyone who received such a modification (a) got a temporary modification called a “trial” (b) ended up back in foreclosure anyway (c) was used once again for unworthy unauthorized companies to collect even more illegal fees and (d) was part of a gift to servicers who were getting a house on which they had invested nothing, while the real source of funds was already paid in whole or in part by insurance, credit default swaps or federal bailout.

Now the Obama administration is “encouraging” modifications with reductions in principal of perhaps 30%. But the industry is pushing back because they don’t want to report the loss that would appear on their books now, if a modification occurred, when they could delay reporting the “loss” indefinitely by continuing the foreclosure process. The “loss” is fictitious and the push-back is an illusion. There is no loss from non-performance of these mortgages on the part of lending banks because they never lent any money other than the money of investors who purchased mortgage-backed bonds.

You want to stop the foreclosures. It really is very simple. Stop lying to the American people whether it is intentional or not. Admit that the homes they bought were not worth the amount set forth in the appraisal and not worth what the “lender” (who was no lender) “verified.” Through criminal, civil and/or administrative proceedings, get the facts and change the deals like any other fraud case. Nobody ever thought that returning a lady’s purse to her after a purse snatcher ran away with it was a gift. So why is anyone contesting returning the purse to homeowners who had their lives snatched from them?

BAC assigned a note in 2010 that they sold in 2003

Editor’s Note: Recontrust appears to be wholly owned by Bank of America. This particular deal looks like a “reconstituted” mortgage backed security comprised of new securities which are “backed” by old mortgage backed securities which in turn are backed by a list of “loans” which may or may not exist, and which certainly have at least in part been paid in whole or in part through insurance, credit default swaps and federal bailout.

From the comment Section of the Blog:

ReconTrust filed a NOD on behalf of BAC “servicer” for GRS Mort. Trust 2003-9, seven days later filed an assignment to GSR Mort. Trust of the deed of trust and note dated 8-13-03. I had no notice of GRS or Recontrust until seven years later. It looks like BAC assigned a note in 2010 that they sold in 2003. It also appears a pattern of fraud is occuring with all of us as their victims. If anyone knows what GSR Mortgage stands for please inform. I any one is interested in exposing the pattern let me know. I have 40 days before the notice of sale. I’m also pursuing this pro se.

Cuomo Spotted Appraisal Fraud as Core Problem in 2007

WaMu faulted on home loans

Colluded to inflate property values, N.Y. attorney general says


New York’s attorney general has accused Washington Mutual Inc. of pressuring a real estate appraisal company to deliver inflated home values in order to justify making loans, a practice that some appraisers have complained of increasingly in recent years.

The suit filed Thursday in a New York court by Attorney General Andrew Cuomo doesn’t name Seattle-based WaMu as a defendant. Instead, it charges First American Corp. and its eAppraiseIT subsidiary of engaging in “deceptive, fraudulent and illegal business practices.”

But WaMu figures prominently in the complaint: EAppraiseIT “improperly allows WaMu’s loan production staff to hand-pick appraisers who bring in appraisal values high enough to permit WaMu’s loans to close, and improperly permits WaMu to pressure eAppraiseIT appraisers to change appraisal values that are too low to permit loans to close.”

Cuomo said the actions of First American and Washington Mutual are indicative of widespread problems in the home-lending and appraisal businesses, and have contributed to turmoil in the housing market.

“It’s about time,” said Richard Hagar, who owns American Home Appraisals on Mercer Island, teaches anti-fraud classes and helped write Washington’s mortgage laws. “I have been surprised that no investigations have been started earlier on something like this.”

Graham Albertini, a former WaMu appraiser who now works for Hagar and teaches appraisal classes, said the bank’s appraisal process has been increasingly problematic since 2002.

“Starting in 2002 they shifted the emphasis from quality to quantity,” he said.

Appraisers have been complaining with increasing vehemence in recent years about the kind of pressure Cuomo described, saying it has enabled buyers to overpay, leaving many with mortgages for more than their homes were worth.

The traditional role of appraisers was to provide some protection for lenders, who wanted to make sure they could recoup their money if they had to foreclose. But in recent years, appraisers have increasingly been getting their work from mortgage originators representing lenders and banks that almost immediately sell off mortgages to Wall Street investors.

Meanwhile, a hot home market caused buyers to bid prices to new heights. Now that prices have started to level off in the Seattle area and decline elsewhere, some buyers are finding they cannot sell their homes for what they owe, leaving them with few alternatives to foreclosure.

“A lot of this doesn’t get revealed until you have a downturn in the housing market,” said Scott Jarvis, director of the state Department of Financial Institutions.

Washington Mutual said in a statement it is “surprised and disappointed by the allegations. … We are suspending our relationship with eAppraiseIT until we can further investigate the situation. We have absolutely no incentive to have appraisers inflate home values. In fact, inflated appraisals are contrary to our interests. We use third-party appraisal companies to make sure that appraisals are objective and accurate.”

“We vehemently disagree with (Cuomo’s) characterization of the facts,” Kenneth DeGiorgio, First American’s general counsel, said in a call with analysts, according to Bloomberg News. “We’re confident that once we’ve had the opportunity to set forth our response before an impartial arbiter, our activities will be found to be appropriate.”

Hagar said Washington Mutual never pressured him on an appraisal.

“That changed about five-ish years ago,” he said. “We started getting some pressure and they started looking for lesser appraisers — not the best qualified, but anyone who could get it done fast and cheap.”

But Hagar also said appraiser pressure is an industrywide problem, and acknowledged that WaMu has a better reputation than many lenders.

Albertini said WaMu had great standards for appraisals until 2002, when the company started automating much of its appraisal review work.

WaMu took no action in cases where reviews of homes that ended up in foreclosure found the original appraisal had been bad, Albertini said. “They would still hire that appraiser and they would never do anything to get that appraiser in trouble.”

In 2005, the company created a separate group of appraisers to quickly look over appraisals without doing a full review, and paid incentives based on how many they OK’d, Albertini said.

One 2006 appraisal pegged a West Seattle house at $2.5 million above its true value by comparing it with homes in Medina, but WaMu went ahead with the refinance loan, Albertini said. “They would pretty much just disregard what I did and then loan on the original appraisal.”

Albertini said he never received any pressure from WaMu managers to do anything wrong.

The lawsuit cites numerous e-mails that Cuomo says indicate the pressure Washington Mutual put on appraisers to be compliant, flexible and bank-friendly by delivering an appraisal price that met or exceeded the sales price. In one e-mail, a First American executive says the company could receive additional business from WaMu if disputes over appraisals are resolved.

In another e-mail, eAppraiseIT’s president signaled the company’s acquiescence to WaMu’s insistence that business be steered to “proven appraisers”: “We have agreed to roll over and just do it.”

Those e-mails “were not the idle chatter of disgruntled, low-level employees,” said Eric Corngold, executive deputy attorney general for economic justice.

EAppraiseIt executives on several occasions expressed uneasiness over the arrangement with WaMu and even concern that it might be illegal, e-mails cited in the suit indicate.

While investigators have pursued high-profile fraud cases in recent years, day-to-day pressure to meet inflated values has not been a priority, Hagar said. Washington regulators acknowledged this earlier this year, saying they have small staffs, few appraisers file formal complaints and pressure cases were often hard to pursue.

Hagar has been looking for action from federal regulators, given the size of banks such as WaMu. “It’s very, very difficult for any single state agency to go out after them,” he said. “Bravo that the attorney general from New York has the resources to go after them.”

Albertini noted that few appraisers ever get in trouble for bad appraisals, and penalties tend to be small.

“I think all it would take for appraisers to wise up and change is hearing about a few of them getting in trouble,” Albertini said. “There’s been nobody going after the bad appraisers.”

Washington Mutual wasn’t named as a defendant, Cuomo said, because state attorneys general are pre-empted from filing legal actions against financial institutions such as WaMu that are federally chartered.

Cuomo said his office will notify federal regulators of his office’s findings, adding that “the federal government is asleep at the switch once again.” Cuomo, who served as secretary of Housing and Urban Development in the Clinton administration, said the issue of appraisal fraud isn’t new. “We learned these lessons over 20 years ago” in the wake of the savings and loan crisis.

A spokesman for the federal Office of Thrift Supervision, which regulates WaMu, said it had just become aware of the suit and wasn’t able to comment.

The news delivered another hit to WaMu’s stock, already reeling from the hit to its earnings from housing-market turmoil. WaMu stock closed at $25.75, down $2.13 per share. Since trading at more than $45 this year, Washington Mutual has slid to its lowest closing price since October 2000.


New York Attorney General Andrew Cuomo is using e-mails as the basis for much of his case against a major real estate appraiser he accuses of “caving” in to pressure from a lender to inflate property values. Cuomo says the internal e-mails are also evidence of collusion between eAppraiseIT, a subsidiary of First American Corp., and Washington Mutual Inc. Excerpts:

  • Sept. 27, 2006: First American’s vice chairman said a Washington Mutual executive told him that cooperating could lead to more business: “If the appraisal issues are resolved and things are working well he would welcome conversations about expanding our relationship.”
  • Feb. 22, 2007: eAppraiseIT’s president told senior executives at First American: “We have agreed to roll over and just do it …”
  • April 4, 2007: eAppraiseIT’s executive vice president warned First American: “We as an AMC (Appraisal Management Co.) need to retain our independence from the lender or it will look like collusion … eAppraiseIT is clearly being directed who to select. The reasoning … is bogus for many reasons including the most obvious — the proven appraisers bring in the values.”SOURCE: New York State Office of the Attorney General/The Associated Press
  • P-I reporter Bill Virgin can be reached at 206-448-8319 or

    “System is Broken” — there is no clear title and no clear answers, which is why most foreclosure actions should fail or be reversed

    Mortgage market clouds who owns woman’s house

    Submitted by Jose Semedey — Thank You


    The Atlanta Journal-Constitution

    Sunday, January 25, 2009

    Twenty years ago, Zella Mae Green bought a modest brick ranch house in DeKalb County with an American ideal in mind. The single mother of four, who raised her children working low-wage jobs, wanted to own something someday. And she wanted to pass something on.

    “I was thinking that if anything would ever happen to me, the children would have a place they could come and stay,” said Green, a seamstress who is 68. “Their father passed away when they were young.”

    Enlarge this image

    Zella Mae Green has been in a stalemate with mortgage lenders for years trying to learn who holds the note on her Decatur home and how much she really owes.
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    Green says she has done her part, making payments on the house she bought for $40,000 to the series of lenders who have managed her mortgage over two decades.

    But Citigroup and Wells Fargo say Green has failed miserably as a homeowner and is nine years behind on her payments. And they want to take the house.

    “Nine years? There ain’t no way,” Green said. “Ain’t no way you can stay someplace for nine years without paying anything.”

    Determining whether a homeowner is truly years behind on a mortgage seems like a straightforward question.

    But Green and a string of lenders have been arguing about the matter in court for years now — with no resolution in sight. Her lawyer says the lenders have not even proven who owns the mortgage, let alone established how much Green owes.

    Citigroup and Wells Fargo and the lawyers representing them declined to be interviewed for this article, citing pending litigation.

    Green’s case illustrates the complexities of the modern mortgage market and just how difficult it can be to unwind the history of a mortgage. Most mortgages are originated by one lender, then sold — often repeatedly — to other lenders or groups of investors. Other companies are often brought in to process payments and manage escrow accounts.

    For the thousands of homeowners who are behind on mortgage payments or in a dispute about how much is owed, getting accurate information about a loan can be difficult. Negotiating a resolution — especially when a series of lenders and managers has been involved — can be even harder.

    “Here is a homeowner who wants to get her mortgage worked out so she can pay it,” said Howard Rothbloom, Green’s attorney. “She can’t get it done.”

    Question of ownership

    Green picked out her house 20 years ago. It’s a two-bedroom, one-bath brick ranch with about 1,000 square feet. Green borrowed $40,250 from All Georgia Mortgage at an interest rate of 10 percent in 1988. She felt sure she could handle the $353 payments with her job at J.C. Penney.

    “I was excited about it because I knew one day it would be mine,” said Green, now a great-grandmother.

    The home’s interior today is a reflection of Green. It’s adorned with fancy curtains and pillows she made — the kind she creates in her seamstress job for an upscale decorating company. And it’s the place her family gathers to enjoy Green’s home cooking.

    Trouble with the mortgage began years ago, she said, when she mailed in money orders that she says were applied to the wrong account — something she believes went on for at least seven months.

    The mortgage companies involved with the loan at that time have since sold it.

    Green said she sought help from several housing agencies and attorneys over the years, trying to get credit for all the payments she has made. “They told me it’s the biggest mess they have ever seen,” she said.

    All Georgia Mortgage Co. originated Green’s loan, but it has been owned or managed by at least seven parties over the years. Citigroup now says it owns the loan and Wells Fargo is managing the payments.

    Green acknowledged paying her mortgage late sometimes over the years, but she said she always made up for it. She has filed for bankruptcy four times since 1989 — usually when a lender threatened foreclosure.

    Lenders in Georgia can proceed with a foreclosure without the involvement of any court. Bankruptcy automatically stops a foreclosure, and the court generally serves as the forum for resolving mortgage disputes.

    Green said the bankruptcies were the only way to try to figure out what happened to her payments and to keep her house.

    Complicated accounts

    Green’s case sounds extreme. But lawyers who represent homeowners say most mortgage lenders rely on such complicated accounting systems that experts have to be hired to even read the history of payments and charges.

    “The payment histories are designed by these servicing companies to be gobbledygook,” said William J. Brennan Jr., an attorney at Atlanta Legal Aid and national expert on mortgage lending. “Knowing what somebody owes is crucial. They will give you a number, but if you want to see if that’s right — good luck.”

    A payment history provided by lenders in Green’s case is complicated. It shows numerous credits on the same day for relatively small amounts, listed as “payment rec’d,” but shows no change in the account’s balance.

    The history also appears to show her account being within months of being current, then suddenly more than seven years behind and then current again in 2000.

    Green filed for bankruptcy protection for a fourth time in 2004 with the help of Rothbloom, an attorney with a successful record of challenging mortgage lenders.

    “I’m just trying to find out two things: What Ms. Green’s proper loan balance is and who she owes it to,” Rothbloom said.

    So far, who owns the mortgage has not been resolved.

    A lender proves ownership of a mortgage by producing the “promissory note,” the document signed at closing in which the borrower agrees to the debt. The note is valuable and can be bought and sold by lenders. But like a personal check, it is only valuable in its original form.

    Green’s lenders have admitted in court documents they can’t find her note. Legal experts say that’s a big deal.

    “There is no excuse for the inability of mortgage lenders to know where the note is,” said Frank Alexander, an Emory University law professor and a leading expert on real estate law. “Without the note, you have virtually nothing. That is the one thing that is always locked in a vault.”

    The lender says everybody knows that Citigroup owns the note. If Green thought otherwise, they say in court documents, why would she send Citigroup her payments?

    Rothbloom says that’s not good enough. “Their answer is, ‘We have a copy,’” Rothbloom said. “My answer is, ‘I have a copy, too.’ “

    Katherine Porter, a University of Iowa law professor, found in a study that lenders routinely fail to file required documents in bankruptcy cases to prove what consumers owe. And their accounting systems, she said, make it hard for them to track the history of payments over the life of a loan, especially when numerous lenders are involved.

    Porter said Green’s case illustrates how complicated these cases can become.

    “If she can’t get this information through litigation and with a skilled attorney, what happens to people facing foreclosure who sent their check in and can’t get the lender to admit it?” Porter said.

    ‘System is broken’

    In legal filings, the lenders say Green has never been able to keep up with the payments. They cite her numerous bankruptcies and the fact that Green participated in a federal program designed to help struggling homeowners between 1997 and 2000.

    Rothbloom said payment records appear to show her loan was current in 2000, when under the management of the U.S. Department of Housing and Urban Development. He said it’s possible HUD’s program transferred past-due payments to the end of the loan to allow Green to stay in the house.

    “Anything is a possibility,” Rothbloom said. “That’s why we sued. To find out what’s going on.”

    What Rothbloom knows, he said, is that Green has made every payment since 2004. Still, he has made no progress getting lenders to agree to a settlement in a case involving a house that DeKalb County values at $67,000.

    “Why do they want this house?” Rothbloom said. “The answer is the system is broken.”

    MERS MEMBERSHIP INFORMATION Reveals Index to Securitization and Investors: Allegation that MERS is authorized or even nominal beneficiary is false

    Sample Link: validatembrsearch.jsp?as_mbrsearch=1006937



    Sample Response Record:

    Corporate Name: West Coast Servicing, Inc.
    Address: 17011 Beach Blvd., #300
    City,State,Zip: Huntington Beach, CA 92647
    Toll Free Number: (866) 574-2001
    Direct Number: (714) 596-6333
    Fax Number: (714) 596-6333
    Primary Contact: Cameron Clayton
    Member Org ID: 1006937
    Lines Of Business: Originator, Servicer, Subservicer, Investor, Document Custodian
    eRegistry Participant: No
    eDelivery Participant: No

    #1 Lending LLC
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    ACCU Funding Corporation, LLC
    Accurate Fidelity Mortgage Corporation
    Ace Mortgage Funding LLC dba Millennium Funding Group
    Ace Mortgage Funding, LLC
    Acopia, LLC
    Acre Mortgage & Financial, Inc.
    ACT Lending Corporation
    Action Mortgage, LLC
    Adams Mortgage, LLC & Adams Mortgage LLC dba Front Range Mtg
    Added Value Inc
    Adelo Mortgage, Inc.
    Admiral Mortgage, Inc
    Advance Mortgage & Investment Company of N. Florida Inc.
    Advance Mortgage Corporation
    Advance Mortgage Source Inc dba S. Carolina Mortgage Assc
    Advanced Concepts Enterprises Inc
    Advanced Financial Services, Inc. (aka AFS Financial, Inc.)
    Advanced Lending Group dba Nationwide Lending Group
    Advanced Mortgage Marketing LLC dba Equity One Mortgage
    Advanced Mortgage Services
    Advanced Mortgage Systems, LLC
    Advantage Home Loans, LLC
    Advantage Investors Mortgage Corporation
    Advantage Loans, Inc.
    Advantage Mortgage of Michigan
    Advantage Mortgage of S. Florida
    Advantage One Mortgage, Inc.
    Advantage Residential Mortgage Company
    Advantage/Universal Mortgage Inc dba Advantage Mortgage
    Advantix Lending, Inc.
    Advent Mortgage Corp.
    Advent Mortgage LLC
    Adventas, Inc.
    Adventure Mortgage, Inc.
    Advisor Net Mortgage LLC
    Advisors Mortgage Group LLC
    Advisor’s Mortgage, LLC
    Aegis Correspondent Corporation
    Aegis Funding Corporation
    Aegis Lending Corporation
    Aegis Mortgage Corporation
    Aegis Wholesale Corporation
    AFC Mortgage
    Affiliated Funding Corporation
    Affiliated Mortgage Company
    Affiliated Mortgage LLC dba YSU Lending
    Affinity Bank
    Affinity Group Mortgage Services LLC
    Affinity Mortgage Brokers Inc
    Affinity Mortgage LLC dba Catholic Home Loan
    Agape Financial Group
    Agency Mortgage Corporation (Retail)
    Agency Mortgage Corporation (Wholesale)
    Agents & Builders Mtg. Co., LLC
    Agfirst Farm Credit Bank
    Aggresive International, Inc
    Aggressive Mortgage
    AGI Mortgage Lending of Indiana
    Agire Mortgage Corporation
    AHL, Mortgage, Inc.
    AHM Acceptance, Inc.
    AIG Federal Savings Bank
    Air Academy Federal Credit Union
    Air Academy Service Corp.
    AKT American Capital Corporation
    Alabama Housing Finance Authority
    Alabama Telco Credit Union
    Alacrity Lending Company
    Alameda Mortgage Corporation, A California Corporation
    Alarion Bank
    Alaska Eastern Partners
    Alaska Louisiana Partners
    Alaska Seaboard Partners Limited Partnership
    Alaska USA Federal Credit Union
    Albany Mortgage Group
    Alcova Mortgage
    Alera Financial LLC
    Alerus Financial, N.A.
    Alethes, LLC
    Aliant Bank
    Alkan Mortgage Corp dba Certified Mortgage Planners
    All Access Mortgage Corporation
    All American Consulting, LLC dba All American Mortgage
    All American Home Lending LLC
    All American Home Lending, Inc.
    All American Home Mortgage Corp.
    All American Home Mortgage, LLC
    All American Lending, LLC
    All American Mortgage Corporation
    All California Mortgage dba All American Mortgage
    All Finance Mortgage, Inc.
    All Home Lending, Inc
    All Nation Funding Corp.
    All Star Mortgage
    All Star Mortgage Corp
    All Star Mortgage Corporation
    All State Home Mortgage Inc.
    All Western Mortgage, Inc.
    Allegro Home Loans LLC
    Allegro-Mortgage Inc.
    Allen Mortgage LC
    Allen Tate Mortgage Services, Inc.
    Alliance Bancorp
    Alliance Bank Corporation
    Alliance Financial Resources
    Alliance Financing Mortgage Corp.
    Alliance Home Funding LLC
    Alliance Home Mortgage
    Alliance Home Mortgage Inc.
    Alliance Lending Inc.
    Alliance Mortgage Banking Corp.
    Alliance Venture Mortgage, LLC
    Allied Commercial Services Inc. dba Capital Mortgage Group
    Allied Financial, LLC dba Iron Mortgage
    Allied Home Mortgage Capital Corporation
    Allied Home Mortgage Corporation
    Allied Mortgage Group, Inc.
    Allied Mortgage Professionals, Inc.
    Allsource Mortgage Inc.
    Allstar Mortgage Services LLC
    Allstate Home Mortgage, LLC
    All-Times Mortgage, Inc.
    Alpha Mortgage Corporation
    Alpha Mortgage USA
    Alpine Bank
    Alpine Mortgage LLC
    Alpine Mortgage Services, Inc.
    ALS – Wilmington Trust Co
    ALS 2000-1
    ALS 2000-2
    ALS 2001-2
    ALS FNMA Trust 2001-T1
    ALS FNMA Trust 2001-T3
    ALS FNMA Trust 2001-T4
    ALS in Trust for SASCO
    ALS Private Investor – Washington Trust
    ALS SASCO 2001-4A
    ALS SASCO 2001-5
    ALS SASCO 2001-6
    ALS SASCO 2001-7A
    ALTA Financial Corp
    Alta Financial Inc. dba Alta Financial Mortgage
    Alterna Mortgage Co.
    Alternative Financing Corporation
    Alternative Funding Corp
    Alternative Mortgage Options, Inc.
    Alternative Mortgage Solutions, Inc.
    Alternative Resource Services Inc
    Altura Credit Union
    Amalgamated Bank
    Amalgamated Bank (NY)
    Ambeck Mortgage Associates
    Amber Financial Group, LLC
    AMC Mortgage Services Inc.
    AmCap Mortgage Ltd
    Amera Corporation dba Amera Mortgage Corporation
    Amera Mortgage Corporation
    Ameribanc Corporation
    Ameribank – Warehouse
    Ameribank Mortgage Company LLC
    America South Mortgage Corp.
    American Acceptance Mortgage, Inc
    American Acceptance Mortgage, Inc.
    American Advantage Mortgage Company, L.L.C.
    American Bancshares Mortgage Corporation
    American Bank
    American Bank & Trust
    American Bank and Trust
    American Bank of Commerce
    American Bank of Texas N.A.
    American Benefit Mortgage Inc.
    American Capital Home Loans, LLC
    American Capital Mortgage Bankers, Ltd.
    American Chartered Bank
    American Dream Funding Corporation
    American Eagle Federal Credit Union
    American Eagle Mortgage Inc
    American Enterprise Bank of Florida
    American Equity Mortgage
    American Family Funding, Inc.
    American Family Mortgage, Inc.
    American Federal Bank
    American Federal Mortgage Corporation
    American Fidelity Mortgage Bankers, Inc.
    American Fidelity Mortgage Corp.
    American Fidelity Mortgage Services, Inc.
    American Fidelity, Inc.
    American Financial Funding Corp.
    American Financial Lending, Inc.
    American Financial Mortgage Corporation
    American Financial Network, Inc DBA Realty Mortgage Alliance
    American Financial Resources Inc.
    American Financial Resources Incorporated
    American Financial Services
    American Financing Corporation
    American First Credit Union
    American First Real Estate Services, Inc.
    American Freedom Group, Inc
    American Freedom Mortgage Inc.
    American General Financial Services of Arkansas dba MorEquit
    American General Mortgage
    American Guardian Financial Group Inc.
    American Heritage Capital, LP
    American Heritage Mortgage Co, LLC
    American Home Equity Corporation
    American Home Free Mortgage, LLC
    American Home Lending Inc. DBA American Home Residential Inc
    American Home Lending USA, LLC
    American Home Loan Center, LLC dba Centric Mtg & Natl Invest
    American Home Loans LLC
    American Home Mortgage Company
    American Home Mortgage Corp dba American Home Mortgage
    American Home Mortgage Holdings, Inc.
    American Home Mortgage Investment Corp.
    American Home Mortgage Services, Inc.
    American Home Mortgage Servicing, Inc.
    American Home Mortgage, Inc.
    American Homefront Mortgage Funding
    American Homestar Mortgage, LLC
    American Homestead Mtg. LLC
    American Independent Association
    American Interbanc Mortgage
    American Internet Mortgage, Inc.
    American Investors Bank and Mortgage
    American Land Title Association
    American Lending Group
    American Lending Group, Inc.
    American Lending Network, Inc.
    American Liberty Mortgage & Loan Corporation
    American Liberty Mortgage Inc
    American Loan Centers
    American Midwest Mortgage Corp
    American Money Centers Inc.
    American Mortgage & Financial Services LLC
    American Mortgage Advisors, Inc.
    American Mortgage Associates, Inc AR
    American Mortgage Company
    American Mortgage Corp of South Alabama DBA Mid America Mort
    American Mortgage Corporation
    American Mortgage Corporation.
    American Mortgage Exchange, Inc.
    American Mortgage Express
    American Mortgage Express dba Millennium Funding Group
    American Mortgage Express Financial
    American Mortgage Funding Corporation
    American Mortgage Group, Inc. (AZ)
    American Mortgage Group, LLC
    American Mortgage Home, Inc.
    American Mortgage Investment Partners II
    American Mortgage Investment Partners LLC
    American Mortgage Network, Inc.
    American Mortgage of Montana, Inc.
    American Mortgage Service Company
    American Mortgage Services, Inc.
    American Mortgage Specialists Inc.
    American Mortgage, Inc
    American National Bank – Denver
    American National Bank dba Res Mort Services & Peoples Nat’l
    American National Mortgage Corp DBA Affordable Mortgage Solu
    American Pacific Mortgage Corp. dba American Pacific Funding
    American Partners Bank
    American Pioneer Financial Services, Inc.
    American Portfolio Mortgage Corp.
    American Prime Finance Services
    American Residential Mortgage LP
    American Savings Bank
    American Security Mortgage Corp.
    American South Lending, Inc.
    American Southwest Mortgage Corp
    American State Bank/Home Loan Center
    American Sterling Bank
    American Trust & Savings Bank
    American Trust Bank Mortgage LLC
    American Unified Mortgage, Inc.
    American Union Financial Services, Inc.
    American United Mortgage Corp
    American USA Mortgage P.A.
    American West Bank
    Americana Mortgage, Inc
    AmericanBank, NA
    Americanwest Bank
    Americap Financial, Inc
    Americapital Funding Corp
    Americare Inv Group dba Premier Capital Lending Group
    Americas First Choice Lending
    Americas First Home Mortgage Company
    America’s First Mortgage Lending Co
    America’s Home Loan Inc.
    America’s Home Mortgage, LLC
    America’s Lending Solutions LTD
    America’s Mortgage Alliance, Inc
    America’s Mortgage Banc, Inc.
    America’s Mortgage LLC
    America’s Mortgage Resource Inc.
    America’s Servicing Company
    Americasun Financial
    Americor Lending Group
    Americorp Credit Corporation
    AmeriCU Credit Union
    Amerifinancial Mortgage Corp.
    Amerifirst Financial Corp
    AmeriFirst Financial, Inc.
    Amerifund Financial Inc. dba All Fund Mortgage
    Amerifund Home Mortgage LLC
    Amerifund Lending Group dba ALG Real Estate Services Inc.
    Amerihome Loan Inc.
    Amerihome Mortgage Company, LLC
    AmeriMortgage Bankers, LLC
    Ameri-National a div of National Bank of Kansas City
    Ameripath Mortgage
    Ameriprise Financial Inc DBA Ameriprise Bank FSB
    AmeriPro Funding, Inc.
    Amerisave Mortgage Corporation
    AmeriServ Financial Bank
    AmeriSouth Mortgage Company
    AmeriStar Home Mortgage Corp of Pennsylvania
    AmeriStar Mortgage Corporation
    Ameristar Mortgage.
    Ameritrust Mortgage Bankers, Inc.
    Ameritrust Mortgage Company, LLC
    Ameritrust Mortgage Corporation
    Amherst Funding Group LP
    AMS Financial, Inc, dba Advanced Mortgage Services
    Amstar Mortgage Corporation
    AMTEC Funding Group LLC
    AmTrust Bank, A Federal Savings Bank
    Amtrust Mortgage Corporation
    Anchor Bank Farmington NA
    Anchor Bank, N.A.
    Anchor Funding Inc.
    Anchor Home Mortgage
    Anchor Mortgage Services, Inc.
    Ancient City Mortgage, Inc.
    Andes Financial Inc.
    Ann Arbor Mortgage Company LLC
    Annandale State Bank
    Answer Capital Incorporated dba Answer Capital Mortgage
    Answer One Mortgage, Inc.
    Anthem Enterprises Inc
    Apex Funding Inc.
    Apex Lending Inc.
    Apex Mortgage LLC
    Appalachian Community Bank
    Apple Valley Mortgage, Inc.
    Approved Financial Corp
    Approved Funding Corp.
    Approved Home Lending, Inc.
    Approved Home Mortgage, Inc (ME)
    Approved Home Mortgage, Inc.
    Approved Mortgage Funding LLC
    Approved Mortgage Loans, Inc.
    Approved Mortgages Inc.
    Apreva Financial Corporation dba Apreva Funding
    Arbor Homes Mortgage LLC
    Arbor Mortgage Corporation
    Arbor Realty NPAP Holdings LLC
    Arboretum Mortgage Corporation
    Arbotco Financial Corporation
    ARC 2000 BC-1
    ARC Westwood Home Saver Fund I, LP
    Arcadian Mortgage Corporation
    Arcata Investments 2, LLC
    Arce Financial, LLC
    Arch Mortgage Corporation
    Archer Mortgage
    Archway Mortgage, LLC
    Archwood Mortgage LLC
    Arden Mortgage Co
    Ardent Financial Corporation
    Arisen Mortgage Corporation
    Aristar Mortgage Company
    Arizona Federal Credit Union
    Arizona State Credit Union
    ARK LA TEX Financial Services dba Benchmark Mortgage
    Ark Mortgage, Inc.
    Arlington Capital Mortgage LLC
    ARMC – Alliance Residential Mtg Corp dba Alliance Res Mtg
    Array Financial Group Inc.
    Arrowhead Central Credit Union dba Arrowhead Credit Union
    Artisan Mortgage, LLC (OH)
    Arvest Mortgage Company
    Ascella Mortgage, LLC.
    Ascent Home Loans, Inc.
    Asheford Funding Group LLC
    Ashore Funding, Inc.
    Ashworth Funding Inc.
    Ask for a Loan, Inc.
    Aspen Leaf Mortgage, LLC
    Aspen Mortgage LLC
    Aspire Financial Inc dba
    Asset Capital Mortgage, Inc.
    Asset Direct Mortgage LLC
    Asset Management Holdings, LLC
    Asset Management West 10 LLC
    Asset Management West 6, LLC
    Asset Management West 7, LLC
    Asset Management West 8 LLC
    Asset Management West 9, LLC
    Asset Management West LLC
    Asset Mortgage Corporation
    Assets Recovery Center Investments, LLC
    Assets Recovery Center LLC
    Associated Bank NA
    Associated Mortgage Corporation
    Assurance Financial Group LLC
    Assured Lending Corp.
    Assured Mortgage Bankers Corp.
    Assured Mortgage, Inc.
    Assurity Financial Services, LLC
    Astoria Federal Savings and Loan Association
    At Home Mortgage Corp.
    Atlanta Intown Mortgage, Inc.
    Atlantic Pacific Mortgage Corporation
    Atlantic Bay Mortgage Group LLC
    Atlantic Coast Federal
    Atlantic Coast Mortgage Group, Inc.
    Atlantic Coast Mortgage Services
    Atlantic Federal Credit Union
    Atlantic Financial, Inc.
    Atlantic First Financial Corporation
    Atlantic Home Lending Inc.
    Atlantic Home Loans d/b/a Atlantic Home Loans Lcnsd Mtg Bnkr
    Atlantic Home Mortgage, Inc.
    Atlantic Mortgage Services Inc.
    Atlantic National Bank
    Atlantic States Bank – Florida
    Atlantis Financial Group, Inc. dba Atlantis Mortgage
    Atlantis Mortgage Co., Inc.
    Atlas Mortgage Company LLC
    Atlas Mortgage, Inc.
    Auburn Bank
    Augusta Mortgage Co.
    Augustine E Asinobi dba Zomek Mortgage/Realty Inc.
    Aurgroup Financial Credit Union
    Aurora Contract Services, Inc.
    Aurora Financial Group, Inc.
    Aurora Loan Services LLC
    Aurora Loan Services, Inc., Repurchase Lending Division
    Aurora Mortgage LLC
    AUS Financial Services, Inc.
    Austin Perry Financial Corporation
    Automated Finance Corporation
    Availent Mortgage
    Avalon Mortgage, Inc.
    Avanta Federal Credit Union
    Avanti Financial Network LLC
    Avaris Capital
    Avelo Mortgage, L.L.C.
    Aventus, Inc.
    Avenue Bank
    Avenue Mortgage Corporation
    Avery Financial Group Inc.
    Avex Funding Corporation
    Avista Solutions
    Avizen Lending Solutions Inc
    Avrus Financial and Mortgage Services Inc
    Axent Funding LLC
    Axia Financial LLC
    Axiom Financial, LLC
    Axiom Mortgage Bankers Corp.
    Axis Bancorp Inc.
    Axis Financial, LLC
    Axis Mortgage & Investments, a/d/o The Biltmore Bank of Ariz
    Axis Mortgage & Investments, L.L.C.
    B&A Mortgage, Inc.
    B. R. Mortgage LTD
    Back Bay Inc dba Mtg Approval Serv(MA), Approved Mtg Serv(FL
    Badger Funding Corp
    Bahl & Bahl, Inc.
    Baker Mortgage Company, Inc.
    Baker Ronan Financial dba First Nations Financial
    Baker Street Mortgage
    Baltimore County Savings Bank, FSB
    Banc Investments Group/Pacific Coast Bankers’ Bancshares
    Banc of America Securities LLC (Global ABS)
    Banc Ohio Financial
    BancCap Advisors LLC
    Banco Popular National Association
    Banco Popular North America, South Florida Region
    Bancocorp Mortgage Inc
    BancorpSouth Bank Mortgage Division
    Bangor Savings Bank
    Bank Independent (Mortgage Lending)
    Bank Mortgage Solutions LLC
    Bank of America Warehouse Lender
    Bank of America, N.A.
    Bank of America, N.A.
    Bank of America, NA – Reverse Mortgage
    Bank of America, NA (formerly Fleet National Bank)
    Bank of America, National Association
    Bank of America, Ntnl Assoc Trustee/Custodian for WAMU/WMMSC
    Bank of America.
    Bank of Ann Arbor Wholesale Lending Division
    Bank of Bartlett
    Bank of Blue Valley (Internet)
    Bank of Blue Valley (Retail)
    Bank of Charles Town
    Bank of Colorado
    Bank of Commerce
    Bank of Elmwood
    Bank of England Mortgage Company dba England Lending
    Bank of Florida
    Bank of Idaho
    Bank of Illinois in Normal
    Bank of Internet USA
    Bank of Jackson Hole
    Bank of Lake Mills
    Bank of Lee’s Summit
    Bank of Little Rock Mortgage Corporation
    Bank of New England
    Bank of New York Trust Company, N.A.
    Bank of North Carolina
    Bank of Oklahoma
    Bank of Ruston
    Bank of San Angelo, N.A., a Branch of First Natl Bk of Balli
    Bank of St. Augustine
    Bank of Tennessee
    Bank of the Cascades
    Bank of the Prairie
    Bank of the Wichitas
    Bank of Utah
    Bank of Whitman
    Bank One Trust Company, NA
    Bank One, NA (Conduit)
    Bank United FSB
    Bank VI
    Bankers Bank
    Bankers Choice Mortgage Corp.
    Bankers’ Financial, Inc
    Bankers First Mortgage Inc.
    Bankers Home Mortgage, Inc
    Bankers Mortgage Corporation
    Bankers Mortgage of Pasco County, Inc.
    Bankers Mortgage Trust Inc
    Bankers Trust Co NA
    Bankerswest Funding Corporation
    Bankline Mortgage Corporation
    Banktrust of AL
    Bankwest (MN)
    Banner Bank
    Banner County Bank
    Banyan Financial Group Inc.
    Barclays Bank PLC
    Barclays Pacific Lending Corp.
    Barkwood Mortgage Solutions, Inc.
    Barnacle Mortgage, Inc.
    Barnes Banking Company
    Barr Group, Inc.
    Barrington Capital Corporation
    Barrington Mortgage Corp
    Barrons Mortgage Corporation
    Barrons Mortgage Group LTD dba
    Bartlett Mortgage, Inc.
    BasePoint Analytics
    Bay Banc Mortgage Corporation
    Bay Capital Corp.
    Bay Equity LLC
    Bay Financial Savings Bank FSB
    Bay Lending Corp
    Bay National Bank
    Bay to Bay Lending LLC
    Bay Valley Mortgage Group d/b/a Pacific Bay Lending Group
    BayCal Financial Mortgage Corporation
    Baymont Financial, LTD
    BayPort Credit Union
    BayRock Mortgage Corporation
    Bayshore Financial Corporation
    Bayside Mortgage Services Inc.
    Baytree Lending Company
    Bayview Financial Group, LLC dba Garrow Mortgage
    Bayview Home Mortgage Corp
    Bayview Loan Servicing, LLC
    BBC Funding Corporation, DBA X Loan
    BBVA Bancomer USA
    Beach First National Bank
    Beach Mortgage Co. Inc.
    Beacon Financial Mortgage Bankers
    Bear Stearns
    Beazer Mortgage Corporation
    Bednar Inc.
    Bell America Mortgage, LLC Dba Bell Mortgage
    Bell Home Loans Inc.
    Bella Home Mortgage
    Bellevue Home Mortgage
    Belmont Savings Bank
    Beltway Capital, LLC
    Belvidere Networking Enterprises
    Benchmark Financial Services, Inc.
    Benchmark Funding Corporation
    Benchmark Home Mortgage Inc.
    Benchmark Lending Group, Inc.
    Benchmark Mortgage, Inc.
    Benchmark Mortgage, LLC DBA Grandmark Mortgage
    Beneficial Capital Management Corp.
    Benefit Equity Mortgage LLC
    Benefit Funding Corporation
    Bentwood & Bowden Mortgage Group, Inc
    Bergin Financial, Inc.
    Berkshire Bank
    Berry Hill Inc dba Blue Heron Mortgage Company
    Best Mortgage, Inc.
    Best Rate Funding Corp.
    Bi-Coastal Mortgage Inc.
    Big Sky Western Bank
    Billings Federal Credit Union
    Biltmore Financial Bancorp, Inc.
    Biltmore Mortgage & Associates
    Birmingham Bancorp Mortgage Corporation
    BJK Winston Enterprises Inc dba Financial Advantage Home Loa
    BJV Financial Services Inc dba Forum Mortgage Bancorp
    Blackhorse Mortgage Corp
    Blair Services of America Inc.
    Bloomfield State Bank
    Blount Ventures, Inc. dba Blount Mortgage
    Blue Chip Mortgage Wholesale, LLC
    Blue Ridge Investments LLC
    Blue Saphire Investments, (CA) Inc
    Blue Star Financial Services, Inc.
    Blueleaf Lending LLC
    BM Real Estate Service Inc
    BNC Mortgage, Inc.
    BNC National Bank
    Boehck Mortgage Co
    Boeing Employees’ Credit Union DBA BECU
    Bogman, Inc.
    Bondcorp Realty Services, Inc.
    Boone Bank & Trust Co
    Borel Private Bank & Trust Company
    Borrowers Choice Mortgage, Inc.
    Boston Private Bank & Trust Company
    Bottomline Mortgage, Inc.
    Boulder West Financial Services Inc.
    Boulevard Bank
    Boulevard Mortgage Corporation
    Bradford Bank
    Bradford Mortgage Company
    Bradford National Bank
    Brainerd Savings and Loan Association
    Branch Banking & Trust Company
    Brand Mortgage Group LLC
    Bravo Credit Corp.
    Bremer Bank, N.A.
    Brenner Mortgage Corp.
    Brentwood Mortgage Services, Inc.
    Brian A. Cole & Associates LTD dba First Nations Mtg of Ohio
    Bridgeport Lending LLC
    Bridgewater Capital, Inc.
    Bridgewater Savings Bank
    Brier Mortgage Corp.
    Bright Mortgage Group, Inc.
    Bright Vision Mortgage Inc.
    Brighten Lending
    Brimfield Bank
    Briner, Incorporated
    Britton & Koontz Bank National Association
    Broadview Mortgage Corporation
    BrooksAmerica Mortgage Corp.
    Brookside Mortgage Corporation
    Brownstone Mortgage & Investments LLC
    Bryco Funding Inc
    BSI Financial Services, Inc
    BSM Financial DBA Bank Source Mortgage
    Buckingham Mortgage Corporation
    Buddy’s Little Man Inc dba Harbor Financial Mortgage
    Budget Mortgage Bankers, L.T.D.
    Buffalo Federal Savings Bank
    Builder Mortgage Company, Inc.
    Builders Mortgage LLC
    Burke & Herbert Bank & Trust Company
    Busey Bank
    Bush & Hewitt Holding, Inc dba Direct Funding
    Business Bank of Skagit County
    Butler Mortgage Inc.
    Buyers Way Home, LLC
    BWM Mortgage LLC
    Byron Bank
    C & T Mortgage LLC
    C and F Mortgage Corporation
    C&G Financial Services Inc
    C.U. Financial, Inc
    C2CL, Inc.
    Cadence Bank, N.A.
    Cal Coast Mortgage Corp.
    California Bank & Trust
    California Empire Bancorp, Inc.
    California Financial Group Inc dba California Financial Serv
    California Housing Finance Agency
    California Mortgage Advisors, Inc.
    California Mutual Funding
    California Nova Financial, Inc.
    California State Teachers’ Retirement System
    Cali-Land, Inc. DBA Cali-Land Bankers Home Loan
    Calisto Group Inc dba Metro Lending Services
    Calliance Realty Fund, LLC
    CalPacific Mortgage Inc.
    CALPERS (Private)
    CalPers Retained Servicing
    Calvert Mortgage Company
    Cambridge Financial Serivces dba Cambridge Home Loans
    Cambridge Funding Group Inc
    Cambridge Home Capital, LLC
    Cambridge Mortgage Corporation
    Cambridge Mortgage Group, LLC
    Cambridge Savings Bank
    Cameron Financial Group, Inc.
    Campbell & Fetter Bank
    Campbell Financial Services, Inc.
    Canyon National Bank
    Capaha Bank
    Cape Bank
    CapFund Lending
    CapGrow Home Mortgage, LLC
    Capital Access Mortgage, Inc.
    Capital Advantage Mortgage, Inc.
    Capital Alliance Advisors Incorporated
    Capital American Mortgage Company
    Capital Assistance Corp
    Capital Bank
    Capital Center LLC
    Capital City Bank
    Capital Concepts, Inc
    Capital Credit Union
    Capital Direct Financial
    Capital Financial Associates, Inc. dba CFA Mortgage
    Capital Financial Bancorp, Inc.
    Capital Financial Ent. Inc. dba Capital Mortgage Services
    Capital Financial Group
    Capital Financial Mortgage Corp
    Capital Financial Services
    Capital Funding Mortgage Company LLC
    Capital Hill Mortgage Co., Inc.
    Capital Lending
    Capital Lending Group LLC
    Capital Lending Source, LLC
    Capital Mortgage Associates LLC
    Capital Mortgage Corporation
    Capital Mortgage Finance Corp
    Capital Mortgage Funding L.L.C.
    Capital Mortgage Inc
    Capital Mortgage Services, Inc
    Capital One Home Loans LLC
    Capital One Home Loans, LLC
    Capital One, National Association
    Capital Plus Mortgage and Underwriting Services Inc.
    Capital Quest Mortgage, Inc.
    Capital Reverse Mortgage Group
    CapitalMark Bank & Trust
    CapitalSouth Bank
    Capitol Commerce Mortgage Company
    Capitol Credit Union Service Organization, LLC
    Capitol Mortgage Services, Inc.
    Capstar Lending, LLC
    Capstar Mortgage Bankers, Inc.
    Capstone Bank
    Capstone Direct Inc.
    Capstone Lending Corp
    Capstone Mortgage Ind. dba Baker Group
    CapWest Mortgage Corporation
    Cardinal Banc and Mortgage Corp
    Cardinal Financial Company, Limited Partnership
    Cardinal Mortgage Inc.
    Cardinal Mortgage, P.L.L.C
    Carlton Mortgage Services, Inc.
    Carnegie First Lending Services
    Carolina Bank
    Carolina Commerce Bank
    Carolina Mortgage / CDJ, Inc
    Carolina Mortgage Company of Fayetteville
    Carolina Mortgage Group, Inc
    Carolina State Mortgage Corporation
    Carr and Carr Enterprises Inc. dba Carr Mortgage Funding
    Carrington Mortgage Services LLC
    Carrollton Mortgage Services, Inc.
    Carter Lending Inc.
    Carver Federal Savings Bank
    Casa Blanca Mortgage Inc. d/b/a Shearson Mortgage
    Casa Gran Real Estate Inc dba Padre Mortgage
    Casa Linda Mortgage, LTD
    Casa Mortgage Inc.
    Cascade Bank
    Cash Fast Finance, LLC dba Blue Financial
    Cash Out Mortgage Corporation
    CashCall, Inc.
    Cass County Bank
    Castle & Cooke Mortgage LLC dba Box Home Loans for Utah loan
    Castle Mortgage
    Castle Mortgage of Green Bay, Corp.
    Castle Rock Financial Corp
    Castlerock Mortgage, LTD
    Castleview Home Loans
    Castlewood Home Loans, LLC
    Catalyst Lending Inc.
    Catholic and Community Credit Union
    CB&T Mortgage, LLC
    CBC Companies
    CBC National Bank dba First National Bank of Nassau County
    CBSK Financial Group dba American Home Loans
    CDC Federal Credit Union
    CDC Financial Group Inc
    CDC Mortgage Capital Inc.
    Cedar Mortgage Company
    Cedar Rapids Bank and Trust Company
    Cedar River Mortgage L.L.C.
    CedartStone Mortgage, LLC
    Celbrity Mortgage LLC
    Celtic Bank Corporation
    Cenlar FSB
    Centennial Bank
    Centennial Bank (AR)
    Centennial Bank Inc.
    Centennial Bank.
    Centennial Mortgage and Funding, Inc.
    Center State Mortgage
    Centier Bank
    Centra Credit Union
    Central Alabama Mtg., Inc.
    Central Banc Mortgage Corporation
    Central Bancompany
    Central Bancshares
    Central Bank
    Central Bank and Trust Co
    Central Bank of Jefferson County, Inc.
    Central Bank of Kansas City
    Central Jersey Mortgage Corporation
    Central Mortgage Bancorp, Inc.
    Central Mortgage Company
    Central National Bank
    Central National Mortgage
    Central Pacific Bank
    Central Pacific Home Loans
    Central Pacific Mortgage
    Central Rockies Mortgage Corp.
    Central Texas Mortgage Corp.
    Centric Mortgage
    Centrue Bank
    Centurion Mortgage Inc.
    Century Bank
    Century Bank (New Mexico)
    Century Bank FSB
    Century Bank of Kentucky Inc
    Century Mortgage Company dba Century Lending Company
    Century Pacific Mortgage Corporation
    CEREF Partners 1 LP
    Certified Funding, LP
    Certified Home Loans of Florida
    CES Credit Union, Inc.
    CF Bank
    CFS Mortgage Corporation
    CFSC Capital Corp. VIII
    Challenge Financial Investors Corp.
    Champion Bank
    Chapel Hill Mortgage, LLC
    Chapel Mortgage Corporation
    Charlotte Home Equity LLC
    Charter Bank
    Charter Capital Corp dba First Capital Group
    Charter Mortgage Company, Inc.
    Charter One Bank N.A.
    Charter Wholesale Mortgage
    CharterWest Mortgage, LLC
    CharterWest National Bank
    Chartwell Mortgage Funding, LLC
    Chase Home Finance LLC
    Chase Manhattan Mtg. – Deerfield
    Chatham & Associates, Inc.
    Chemical Bank
    Chemtov Mortgage Group Corp.
    Cherry Creek Mortgage Company, Inc.
    Chervenic Mortgage Group LLC
    Chesapeake Bank of Maryland
    Chesapeake Unlimited, Inc. dba Chesapeake Home Mortgage
    Cheviot Savings Bank
    Chevy Chase Bank, FSB
    Cheyenne State Bank
    CHI Financial, LP
    Chicago Bancorp
    Chicago Financial Services, Inc.
    Chicago Mortgage Funding, LLC
    Chicago Mortgage House, LLC
    Chicago Mortgage Solutions Co dba Interbank Mortgage Co
    Chicago United Mortgage, Inc.
    Chicagoland Home Mortgage Corp.
    Chimera Investment Corporation
    CHL for CAMC (Distressed Assets)
    CHL for Hudson SB, N.A.
    CHL for Ohio SB
    CHL for Truman Capital Advisors
    CHL Mortgage Buyout Trust 98-A
    Choice Bank
    Choice Bank (AZ)
    Choice Capital Funding, Inc
    Choice Finance Corp.
    Choice Lending Corp. dba Choice Lending Group
    Choice Lending Group, L.L.C.
    Choice Lending Inc.
    Choice Mortgage Corp.
    Choice One Mortgage, Inc
    ChoiceAmerica Lending, LLC
    Christen E. Keller dba 1st Sheffield Mortgage
    Christopher E. Hobson, Inc. dba Franklin Fin. Integrated Mtg
    Churchill Mortgage Corporation
    Cimarron Mortgage Company
    Cincinnati Federal Savings and Loan Association
    Circle One Mortgage Company
    Cirrus Mortgage
    CIS Financial Services, Inc.
    CIT Group, Inc.
    Citadel Servicing Corporation
    Citi Residential Lending
    Citibank (West) FSB
    Citibank, FSB
    Citibank, NA
    Citifinancial Mortgage Company, Inc.
    Citigroup Global Markets Realty Corp
    Citiline Mortgage Company of Colorado Springs, Inc.
    CitiMortage, Inc. as Master Servicer for TVLB
    CitiMortgage, Inc.
    CitiMortgage, Inc. as Master Servicer for Various Investors
    Citimutual Corporation dba CIMU Wholesale
    Citizens Bank
    Citizens Bank (Delaware)
    Citizens Bank (OR).
    Citizens Bank (TN)
    Citizens Bank Mortgage Company, LLC
    Citizens Bank Mortgage Corporation, LLC
    Citizens Bank N.A.
    Citizens Bank of Ada
    Citizens Bank of Connecticut
    Citizens Bank of Massachusetts
    Citizens Bank of New Hampshire
    Citizens Bank of Pennsylvania
    Citizens Bank of Rhode Island
    Citizens Bank Tri-Cities
    Citizens Commerce National Bank
    Citizens Community Bank
    Citizens Community Bank Mortgage Division
    Citizens Fidelity Mortgage Corp.
    Citizens Financial Mortgage Inc.
    Citizens First Mortgage
    Citizens First Mortgage LLC
    Citizens First Wholesale Mortgage Company
    Citizens Home Loan, Inc.
    Citizens Mortgage Corp
    Citizens Mortgage Corporation.
    Citizens National Bank of Greater St. Louis
    Citizens Security Bank & Trust Company
    Citizens South Bank
    Citizens State Bank dba CSB Mortgage
    Citizens State Bank Norwood Young America
    Citizens State Bank of Cortez
    Citizens Trust Mtg Corp dba CTM Finance Corp.
    Citizens Union Bank
    City Bank & Trust Co.
    City Bank dba City Bank Mortgage
    City Capital Mortgage Banking Corp.
    City National Bank
    Cityfirst Mortgage Services, LLC
    Citywide Home Loans, A Utah Corporation
    Citywide Mortgage Associates, Inc.
    Citywide Mortgage Corp.
    CJ Unlimited
    Clarion Mortgage Capital, Inc.
    Clark Welsh Mortgage Group, Inc.
    Classic Bank, N.A.
    Classic Home Financial, Inc.
    Classic Home Loans
    Classic Mortgage Corp and Delaware Classic Mortgage Corp
    Clayson Mitchell Mortgage Services, LC
    Clayton Lender Solutions
    Clear 2 Close Mortgage Co. LLP
    Clear Progress, Inc.
    Clear Vue Capital Corporation
    Clearinghouse Community Development Financial Institution
    Clearwater Holdings Inc. dba Clearwater Home Mortgage
    Clearwater Mortgage, LLC DBA Clearwater Mortgage
    Cleveland Street Mortgage
    Clifton Savings Bank
    CLO Funding Corporation, Inc.
    Clybourn Financial Services, Inc.
    CMG Lending
    CMG Mortgage, Inc.
    CML Direct DBA Creative Mortgage Lending
    CMLC Funding Inc
    CMS Capital Group, Inc., dba Clear Mortgage Solutions
    CNBS Financial Group Inc
    Coast 2 Coast Funding Group
    Coast Capital Inc dba Coast Capital Mortgage
    Coast Mortgage Corporation
    Coastal Bend Mortgage Inc dba Global Mortgage Group
    Coastal Capital Corp dba Clearlight Mort. dbaThe Mort. Shop
    Coastal Federal Credit Union
    Coastal Finance LLC
    Coastal Mortgage
    Coastal Mortgage Corporation
    Coastal Mortgage Services, Inc.
    Coastal States Mortgage Corporation
    CoastalStates Bank
    Coastway Credit Union
    Cobalt Mortgage, Inc.
    Coconut Grove Bank
    Collateral Security LLC
    Colombo Bank FSB
    Colonial Bank
    Colonial Bank (AL)
    Colonial Home Mortgage Company
    Colonial Mortgage Services Co of America
    Colonial Savings, F.A.
    Colonial Virginia Mortgage LLC
    Colony Mortgage Lenders, Inc.
    Colorado Capital Bank
    Colorado Capital Funding, Inc.
    Colorado Capital Group, LLC
    Colorado Federal Savings Bank
    Colorado Home Funding Inc dba American Home Funding
    Coltate Capital LLC dba Onyx Financial Group LLC
    Columbia Mortgage & Funding Corp
    Columbia Mortgage Corp.
    Columbia River Bank dba CRB Mortgage Team
    Com Unity Lending
    Combank Mortgage Company
    ComCor Mortgage, a division of Southport Bank
    Comerica Bank (Warehouse Lending)
    Comerica Bank, A Texas State Chartered Bank
    Commander Financial Corporation
    Commerce Bank/ North
    Commerce Bank/Harrisburg NA
    Commerce Mortgage Corp.
    Commercial Bank
    Commercial Bank – TN
    Commercial Bank & Trust Co.
    Commonfund Mortgage Corp
    Commonwealth Bank
    Commonwealth Bank and Trust Company
    Commonwealth Mortgage Group LLC
    Commonwealth Mortgage of Texas LP
    Commonwealth of Massachusetts, Division of Banks
    Community Banc Mortgage Corp.
    Community Banc Mortgage LLC
    Community Bancshares Mortgage Co.
    Community Bank
    Community Bank – Wheaton/Glen Ellyn
    Community Bank & Trust
    Community Bank Missoula, Inc.
    Community Bank of Mississippi
    Community Bank of Northern Virginia
    Community Bank of Oak Park River Forest
    Community Bank of the Ozarks, Inc.
    Community Bank of the South
    Community Banks of Colorado dba Bankers Mortgage
    Community Banks of Colorado Mortgage Division AFG
    Community Central Mortgage Company, LLC
    Community Financial Corporation
    Community Financial Services Bank
    Community First Bank
    Community First Bank (AR)
    Community First Bank (IN)
    Community First Bank of Howard County
    Community First Mortgage Inc.
    Community First National Bank
    Community First National Bank of West Plains
    Community FirstBank
    Community Home Financial Services, Inc
    Community Home Loans LLC
    Community Home Mortgage LLC
    Community Lending Services
    Community Mortgage
    Community Mortgage Co. dba Community Mortgage Corp.
    Community Mortgage Corporation
    Community Mortgage Group Inc.
    Community Mortgage Services, Inc.
    Community National Bank
    Community National Bank & Trust of Texas
    Community National Bank (KS)
    Community National Mortgage Inc dba First Community Mortgage
    Community Pride Bank
    Community Pride Mortgage Company
    Community Resource Bank
    Community Resource Mortgage, inc.
    Community Shores Bank
    Community Trust Bank
    Community West Bank NA
    CommunityBank of Texas, N.A.
    Companion of Greer Mortgage Corp LLC
    Compass Bank
    Compass Bank f/k/a Texas State Bank
    Compass Mortgage, Inc.
    Competitive Capital Corporation
    Competitive Mortgage Services Corp. dba Competitive Mortgage
    Complete Mortgage, Inc.
    Complete Service Lending dba Complete Mortgage & Financial S
    Comstock Mortgage
    Conaught Enterprise Corporation dba Sterling Financial Inves
    Concord Financial Inc.
    Concord Mortgage Company.
    Concord Mortgage Corp
    Concord Mortgage, Inc
    Concordia Bank & Trust Company
    Confidence Mortgage LLC
    Conglomerated Mortgage Services, Inc.
    Connecticut Community Bank, N.A.
    Consolidated Capital Mortgage
    Consolidated Consultants Inc
    Consolidated Funding Corp. dba Consolidated Home Mortgage
    Consolidated Mortgage Services, Inc.
    Construction Capital Source, LC
    Consumer First Mortgage Inc.
    Consumer Home Mortgage Corp of America
    Consumer Research Mortgage, LLC
    Consumer Solutions, LLC
    Consumers Choice Mortgage Company
    Consumers Morgage, LLC
    Consumers Mortgage Corporation
    Consumers Mortgage Corporation of Ohio
    Contemporary Mortgage Services, Inc
    Contemporary Realty Solutions, Inc.
    Continental American Mortgage Corporation
    Continental Home Loans Inc.
    Continental Mortgage
    Continental Mortgage Bankers, Inc
    Continental Mortgage Corporation
    Contour Mortgage Corporation
    Convergent Financial LLC dba Convergent Financial
    Coppermark Bank
    Coral Mortgage Bankers Corp
    Corby Mortgage Services Inc.
    Core Mortgage Group LLC
    Core Star Financial Group
    Corinthian Capital Group, Inc.
    Corinthian Mortgage Corporation
    Cornerstone Bancor Mortgage Corp
    Cornerstone Bank
    Cornerstone Bank (ND)
    Cornerstone Bank (ND.)
    Cornerstone Bank.
    Cornerstone Community Bank
    Cornerstone Credit Union
    Cornerstone Federal Credit Union
    Cornerstone Home Mortgage Corp dba MHI Mortgage
    Cornerstone Lenders LLC
    Cornerstone Mortgage Center Inc.
    Cornerstone Mortgage Company
    Cornerstone Mortgage Group, LTD
    Cornerstone Mortgage, Inc.
    Corporate Investors Mortgage Group, Inc.
    Corridor Mortgage Group Inc.
    Corvus Funding, Inc.
    Coulombe & Evered LLC
    Country Bank
    Country Bank for Savings
    Country Club Bank NA
    Country Club Mortgage
    CountryPlace Mortgage, Ltd.
    Countrywide Bank, FSB
    Countrywide Financial Corporation
    Countrywide Warehouse Lending
    County Bank
    County Trust Mortgage Bankers Corp
    Countywide Mortgage Company
    Courtesy Mortgage Company, A California Corporation
    Courtyard Financial Inc.
    Covenant Bank
    Covenant Mortgage LLC
    Coverdale Mortgage Corp.
    Cowlitz Bank dba Bay Mortgage
    CPCA Trust, I
    Craig Kuper dba Shorecrest Mortgage
    Cream City Mortgage Company, Inc.
    Creative Mortgage Concepts, Inc.
    Creative Mortgage Solutions
    Creative Mortgage Solutions, Inc.
    Credit Financial Services, LLC dba Alliance Mortgage Group
    Credit Northeast Inc.
    Credit Suisse Financial Corporation
    Credit Suisse First Boston LLC
    Credit Union Mortgage Association
    Credit-Based Asset Servicing and Securitization LLC
    Crescent Bank
    Crescent Mortgage Company, a Delaware Corp.
    Crescent Mortgage Services, Inc.
    Crest Financial Inc
    Crestar Mortgage Corporation
    Crestline Funding Corp
    Crestwood Financial, LTD
    Crete Tomalka Mortgage, LLC
    CreveCor Mortgage Inc.
    Cromwell Mortgage, Inc
    Cronin Financial Services LLC
    Cronus Capital Group Corp.
    Cross Capital LLC
    Cross Keys Bank
    Cross River Bank
    Crosscountry Mortgage, Inc.
    Crossfire Financial Network, Inc.
    Crystal Clear Mortgage, LLC
    Crystal Mortgage Corp.
    CS Financial Inc.
    CSMC Inc. dba Direct Mortgage Funding
    CSW Financial LLC dba Titan Wholesale
    CTW Financial Services Inc.
    CTX Mortgage Company
    CU Home Mortgage Solutions, LLC
    CU Mortgage Network, LLC
    CU Mortgage Service LLC
    CU WEST MORTGAGE #1002900
    Cullman Savings Bank
    Cunningham and Company
    Curtis Mortgage Company, Inc.
    CUSO Mortgage, Inc.
    CUSO of Hawaii Inc.
    CUsource, LLC
    Custom Equity Mortgage LLC
    Custom Home Lending LLC
    Custom Home Loans
    Custom Mortgage Corp dba Custom Residential Mortgage
    Custom Mortgage Lenders
    Custom Mortgage Solutions, Inc.
    Custom Mortgage, Inc.
    CVK Enterprises, Inc. dba Affinity Mortgage Service
    CWM Partners LP dba Citywide Mortgage
    CWMBS 2000-11
    CWMBS 2001-2
    CWMBS 2001-6 Group 1
    CWMBS2000-1, Bank of New York as Trustee
    CWMBS2000-2, Bank of New York as Trustee
    Cypress Point Funding, Inc.
    CyVex Group, Inc. dba CyVex Mortgage, Inc.
    D&C Financial Corp
    D&E Realty Financing and Investment LLC
    D&L Enterprises LLC dba Arch City Lending
    D&R Financial Group LLC
    D. White & Co. LLC
    D.L. Evans Bank
    Dacotah Bank
    Dakota Blue Mortgage LTD
    Dakota Community Bank
    Dallas Home Loans, Inc.
    Darien Financial Services Inc.
    Darren Mitchell Brennan dba Brennan Mortgage Group
    DAS Acquisition Company, LLC
    Dash Funding, LP.
    Data Mortgage Inc, dba Essex Mortgage
    DataVerify, Inc.
    David M. Whitsell dba Principal Results
    David Petrie
    Davis Insurance, Inc
    Daylight Discount Mortgage Corp.
    DB Structured Products, Inc.
    DCG Home Loans Inc.
    DD Acquisition Sub LLC
    De Anza Capital Inc
    De Oro Inc dba De Oro Home Loans
    Dean S. Berrett dba Berrett Mortgage Services
    Deborah M. Gorman & Associates Home Loans, LLC
    Decade Systems Corporation
    Decision One Mortgage Company, LLC
    Deere Employees Credit Union
    Deichmann Mortgage Inc
    Del Mar Datatrac Inc. dba Del Mar Database
    Del Norte Refi, LLC
    Del Norte, Inc.
    Del Sur Corp dba Camino Real Mortgage & Star One Mortgage
    Del Webb Mortgage Corporation
    Delaware State Housing Authority
    Dell Franklin Financial
    Delta Funding Corporation
    Delta Home Loans, Inc dba Go Loan
    Delta Trust Mortgage Corporation
    Denali Alaskan Federal Credit Union
    Denny Hecker Mortgage, LLC
    Denver Mortgage Company
    Department of Housing and Urban Development
    Derek A. Jones dba Legacy Mortgage Group
    Desert Community Bank, a division of East West Bank
    Desert Hills Bank
    Design Mortgage
    Desportes & Selig LLC
    Destin First Bank
    Deutsche Bank AG New York Branch
    Deutsche Bank National Trust Company
    Deutsche Bank National Trust Company Americas
    Deutsche Bank National Trust Company Americas as Trustee
    Deutsche Bank National Trust Company as Trustee
    Deutsche Bank Trust Company Americas.
    Developer’s Mortgage Company
    Devine Lending, LLC
    DFB Mortgage, Inc.
    DFC Mortgage Services, Inc.
    DGG Financial Corporation dba Drexel Lending Group
    DHA Financial, Inc. dba Denver Home Approval
    DHI Mortgage Company
    Diablo Funding Group, Inc dba Bay Bancorp
    Diamond Bank
    Diamond Bank FSB
    Diamond Hills Investment Inc. dba Bankers Direct
    Diamond Mortgage, Inc.
    Digital Docs
    Digital Docs, Inc.
    Digital Docs.
    Digital Risk, LLC.
    Direct Access LLC
    Direct Equity Mortgage, LLC
    Direct Lending Inc
    Direct Loan America, Inc (R)
    Direct Mortgage Corp
    Direct Mortgage Inc.
    Directions Equity LLC
    Directors Financial Corp.
    Directors Mortgage, Inc.dba USA Direct Funding
    Distinctive Home Lending Inc
    Diversified Capital Corporation of Tennesee
    Diversified Home Mortgage
    Diversified Mortgage
    Diversified Mortgage Corporation
    DMH Mortgage LLC
    Doc Tech Inc
    Doc Tech, Inc. dba Document Express, Inc.
    Document Processing Systems, Inc.
    Document Processing Systems, Inc. (DPS)
    Document Systems, Inc – Doc Magic
    Document Systems, Inc. – Doc Magic
    Dollar Mortgage Corporation
    Dollarhide Mortgage & Lending
    Domestic Bank
    Dominion Mortgage Corporation
    Domond Financial Services, Inc. dba First Executive Mortgage
    Double Tree Mortgage
    Douglas County Bank
    Dovenmuehle Mortgage, Inc.
    Dover Mortgage Company
    Downeast Mortgage Corporation
    Downs Financial
    Dragas Mortgage Company
    Drake Mortgage Corp
    Draper & Kramer Mortgage Corp. DBA 1st Advantage Mortgage (1
    Draper & Kramer Mortgage Corp. DBA 1st Advantage Mortgage (2
    Dream America, LLC
    Dream Home Financial, LLC
    Dream House Mortgage Corporation
    Dreambuilder Investments Funding III
    Dreambuilder Investments, LLC
    Drew Mortgage Associates
    Dryades Savings Bank FSB
    Duke University Federal Credit Union
    Dunne & Company Mortgage Lenders Inc
    Durango Mortgage LLC
    DuTrac Community Credit Union
    Duxford Financial, Inc.
    Dwight B. Delozier dba LoanStarr Mortgage
    DYBN Financial Corporation
    Dyck-O’Neal, Inc
    Dynamax Mortgage, Inc.
    Dynamic Capital Mortgage, Inc.
    Dynamic Financial Consultants, Inc
    Dynamic Mortgage Financial Corp
    Dynamic Mortgage Solutions, LLC
    Dynasty Mortgage, Inc.
    Dyne Financial LLC
    E Mortgage Direct, Inc.
    E*Trade Bank
    E*Trade Mortgage
    E*Trade Savings Bank
    E*Trade Wholesale Lending Corp.
    Eagle Home Loans Inc.
    Eagle Home Mortgage, LLC
    Eagle National Bank
    Eagle Savings Bank
    Earth Mortgage, LP
    East West Mortgage Company
    East Bay Mortgage, Inc.
    East Coast Mortgage and Financial Services Inc.
    East Coast Mortgage Corporation
    East Coast Mortgage Group, Inc.
    East Coast Mortgage Lenders Inc
    East Penn Bank division of Harleysville National Bank
    East West Bank
    East West Home Loan Corporation
    Eastern Bank
    Eastern Financial Home Loans Corp dba Pacific Direct Lending
    Eastern Mortgage Co. Inc.
    Eastern Utah Community Federal Credit Union
    Eastland Financial Corporation
    ebanc Funding, Your Mortgage Lender, LLC
    ECC Capital Corp.
    Edgartown National Bank
    Edgewater Lending Group Inc
    Edmond Mortgage, Inc.
    Educated Mortgage Services LLC
    Effective Mortgage, Inc.
    e-Lend Mortgage, LLC
    Elite Financial Investments Inc.
    Elite Home Loans, Inc.
    Elite Mortgage & Investments, LLC
    Elite Mortgage Group, Inc.
    Elite Mortgage Network, Inc
    Elizabeth A. Smith dba The Mortgage Group
    Ellie Mae
    Elm Street Financial, LLC
    E-Loan, Inc.
    Elpis Lending Group Inc
    Embassy Mortgage Group, Inc.
    EMC Holdings LLC dba Englewood Mortgage Company
    EMC Mortgage Corporation
    Emerald Financial LTD.
    Emerald Lending, LLC
    Emery Federal Credit Union
    eMortgage Management LLC
    Empire Financial
    Empire Home Loan Corp.
    Empire Mortgage IX, Inc.
    Empire Mortgage LLC
    Empire Mortgage LLC V
    Empire Mortgage LLC VII
    Empire Mortgage VI, Inc.
    Empire Mortgage X, Inc.
    Empire Mortgage XI, Inc.
    Empire Mortgage XIII, Inc.
    Empire State Bank NA
    EmpireAmerica LLC
    Empirica Development Corporation
    Encompass Lending Corp
    Encore Credit Corporation
    Endeavor Capital LLC dba Homestead Financial Mortgage
    Enteprise Mortgage Group, LLC
    Enterprise Bank & Trust
    Enterprise Bank and Trust Company
    Enterprise Bank, N.A.
    Entrust Financial Corporation
    Entrust Mortgage, Inc
    eOption Loan, LLC
    EPI Mortgage Center, Inc.
    Equifirst Corporation
    Equifund, Inc.
    Equihome Mortgage Corp
    EquiPlus, Inc.
    Equipoint Financial Network, Inc.
    Equisource Home Mortgage Corporation
    Equitable Home Mortgage, Inc.
    Equitable Mortgage Corp.
    Equitable Mortgage Corporation
    Equitable Mortgages of Nebraska Inc
    Equitable Trust Mortgage Corporation
    Equity Achievement Group, LLC
    Equity Bank, NA
    Equity Consultants, LLC
    Equity Financial Inc
    Equity Lending, LLC
    Equity Loans LLC
    Equity Mortgage Corporation
    Equity National Funding Group, Inc.
    Equity Now Inc.
    Equity One, Inc.
    Equity Plus, Inc.
    Equity Resources, Inc.
    Equity Services, Incorporated
    ESB Financial
    Essex Mortgage dba Alliance Lending Group
    Essex Savings Bank, FSB
    Etekcapital, LLC
    Euro Mortgage Bankers Inc.
    Eustis Mortgage Corporation
    Evanston Insurance Company c/o Universal Assurors Agency Inc
    Ever Bank
    Everbank Reverse Mortgage Company, LLC
    Everest Group, Inc. dba Kapt Mortgage
    Everett Financial Inc dba Supreme Lending
    Evergreen Home Loans
    Evergreen Mortgage Corporation dba Evergreen Ohana Group
    Evergreen Mortgage Services LLC
    EverHome Mortgage Company
    Evest Mac Funding 1
    Evestmac Funding II LLC
    Evolution Funding Group, LLC.
    Evolve Mortgage Services Inc.
    Excel Bank dba Excel Mortgage Company
    Excel Financial Group, LLC
    Excel Funding
    Excel Home Loan, Inc.
    Excel Mortgage Network Inc
    Excellence Mortgage, LTD.
    Executive Financial Services Co Inc
    Executive Home Loans, Inc.
    Executive Lending Group, Inc.
    Executive Mortgage Group
    Executive Mortgage LLC
    Executive Mortgage of Michigan LLC
    Executive Mortgage Services, Inc.
    Expedia Mortgage Company
    Expedient Mortgage, Inc.
    Expedited Financial Services Inc., dba MORTGAGE EXPEDITORS
    Experience Mortgage Inc
    Experienced Mortgage Professionals, Inc.
    Expert Mortgage Company of Northeast Ohio LTD
    Express Capital Lending
    Express Financial Corp
    Express Loan America, Inc. dba Express Loan America
    Express Mortgage
    Express Mortgage Group Inc dba Express Mtg Fndg Group Inc
    Express One Mortgage Corp.
    Extraco Banks, N.A., d.b.a. Extraco Mortgage
    Eykis Financial Services, Inc.
    EZ Funding Corporation
    EZ Mortgage Lending
    ezEscrow, Inc., dba Settleware Secure Services
    F and B Acquisition Group LLC
    F&M Bank Iowa
    F&T Mortgage, Inc.
    F.T. Financial Inc
    Fairfield County Bank
    Fairfield Financial Mortgage Group, Inc.
    Fairmont Funding Ltd.
    Fairpark Mortgage Inc.
    Fairway Funding Group, Inc
    Fairway Independent Mortgage Corp.
    Fairway Mortgage Inc.
    Faith Financial Group
    Faith Mortgage, LLC
    Falcon Capital Funding LLC
    Family Choice Mortgage Corporation
    Family Finance Mortgage LLC
    Family First Mortgage
    Family First Mortgage Inc
    Family Home Finance LLC
    Family Trust Mortgage Group LLC
    Fannie Mae
    Fannie Mae (Reverse Mortgages)
    Farmers & Merchants Bank
    Farmers & Merchants Bank of St. Clair
    Farmers and Merchants Bank
    Farmers and Merchants Bank (FL)
    Farmers and Merchants Bank of Long Beach
    Farmers Bank & Trust N.A.
    Farmers State Bank
    Farmers State Bank of Alto Pass
    Farwell Lending LLC a subsidiary of Cambridge Savings Bank
    FASLO Solutions, LLC
    Fay Servicing LLC
    Fayette County National Bank
    FBC Mortgage LLC
    FCI Lender Services, Inc.
    FDB Mortgage, Inc.
    FDIC as Receiver for First National Bank of Nevada
    FDIC as receiver for Franklin Bank SSB
    FDIC As Receiver for Franklin Bank, S.S.B.
    FDIC as receiver for Miami Valley Bank
    FDIC as Receiver of Netbank
    Fearon Financial, LLC
    Fed Funding Mortgage Corporation
    Federal Deposit Insurance Corporation
    Federal Guaranty Mortgage Corporation
    Federal Home Loan Bank of Atlanta
    Federal Home Loan Bank of Boston
    Federal Home Loan Bank of Chicago, as MPF
    Federal Home Loan Bank of Cincinnati
    Federal Home Loan Bank of Dallas
    Federal Home Loan Bank of Indianapolis
    Federal Home Loan Bank of New York
    Federal Home Loan Bank of Pittsburgh
    Federal Home Loan Bank of San Francisco
    Federal Home Loan Bank of Seattle
    Federal Home Loan Bank of Topeka
    Federal Home Loan Mortgage Corporation
    Federal Mortgage Company Inc
    Federated Home Mortgage, Inc.
    Federated Lending Corporation
    Federated Mortgage Corporation
    Federation of Appalachian Housing Enterprises, Inc.
    Fidelity & Trust Mortgage, Inc.
    Fidelity Bank
    Fidelity Bank (MI)
    Fidelity Bank, Wichita Falls
    Fidelity Financial Mortgage Corp dba Fidelity Mtg Capital
    Fidelity Funding Mortgage Corp.
    Fidelity Home Mortgage Corporation
    Fidelity Information Services
    Fidelity Mortgage Corporation
    Fidelity Mortgage Group Inc.
    Fidelity Mortgage Lending, Inc.
    Fidelity Mortgage, Inc.
    Fidelity One Mortgage
    Fidelity One Mortgage, LLC
    Fidelity Savings Bank (PA)
    Fidelity State Bank & Trust Co.
    Fieldstone Mtg. dba Broad Street Mtg.
    Fifth Third Bank
    Fifth Third Bank (f/n/a Crown Bank FSB)
    Fifth Third Bank (f/n/a Crown Bank)
    Fifth Third Bank (f/n/a First Charter Bank)
    Fifth Third Mortgage Company
    FIMI dba Forum Mortgage
    Finance America, LLC
    Finance Factors,. LTD
    Financial Builders FCU
    Financial Capital Inc.
    Financial Consolidation & Mortgage Corp. dba FCMC
    Financial Mortgage Corporation
    Financial Mortgage, Inc.
    Financial One Mortgage Corporation
    Fine Mark National Bank & Trust
    First Access Mortgage Corp.
    First Alliance Mortgage Corp of Delaware
    First Allied Mortgage, dba Federal Finance
    First Alternative Mortgage Corp.
    First American Bank and Trust Company
    First American Bank Home Mortgage
    First American Bank, NA
    First American CoreLogic
    First American Default Information Services LLC
    First American Equity Corporation
    First American Fulfillment Solutions
    First American Funding Co. LLC
    First American Mortgage Trust
    First American National Bank Association
    First Arkansas Mortgage Company
    First Atlantic Bank
    First Atlantic Mortgage Services, Inc.
    First Bank (VA)
    First Bank and Trust of Mississippi
    First Bank d.b.a. First Bank Mortgage
    First Bank Mortgage, A Division of First Bank of Georgia
    First Bank NC
    First Bank of Idaho
    First Bank of the Lake
    First Banking Center
    First Brunswick Mortgage
    First California Bank
    First California Mortgage Company
    First Call Mortgage Company
    First Capital Financial Resources
    First Capital Fin’l Services Corp dba Full Compass Lending
    First Capital Mortgage Group, Inc.
    First Capital Mortgage Services Inc.
    First Capital Mortgage, LLC
    First Capstone Mortgage LLC
    First Centennial Mortgage Corp.
    First Central Savings Bank
    First Central State Bank
    First Century Bank, N.A.
    First Choice Bank
    First Choice Financial Corp.
    First Choice Funding Group Ltd.
    First Choice Funding, Inc.
    First Choice Lending Group, LP
    First Choice Mortgage
    First Choice Mortgage Services Inc.
    First Citizens Bank & Trust Co.
    First Citizens Bank and Trust Company Inc
    First Citizens National Bank
    First City Bank of Florida
    First City Mortgage, Inc.
    First Coast Lending Inc
    First Coastal Mortgage LLC dba HH Mortgage
    First Collateral Services, Inc.
    First Collinsville Bank
    First Colony Mortgage Corporation
    First Colorado Trust LLC
    First Commercial Bank
    First Commercial Bank of Florida, Inc.
    First Commonwealth Mortgage Corp
    First Community Bank
    First Community Bank (MO)
    First Community Bank of Crawford County
    First Community Credit Union
    First Community Credit Union of Houston
    First Community Mortgage
    First Community Mortgage
    First Community Mortgage a Division of First Community Bank
    First Community Mortgage Inc.
    First Consolidated Mortgage Company
    First Continental Mortgage and Investment Corp.
    First Continental Mortgage, Ltd.
    First County Bank
    First Covenent Financial Group, LLC
    First Credit Union
    First Dakota National Bank
    First Eastern Mortgage Corporation
    First Educators Credit Union
    First Equity Financial Corp. dba First Equity Home Loans
    First Equity Financial LLC dba First Equity Financial
    First Equity Lending, Inc.
    First Equity Mortgage Bankers, Inc.
    First Equity Mortgage Inc.
    First Equity Mortgage Services, Inc.
    First Equity Mortgage, Inc. (AL)
    First Family Mortgage, Inc.
    First Fed Mortgage, Inc
    First Federal Bank
    First Federal Bank of California
    First Federal Bank of the Midwest
    First Federal Bank, FSB
    First Federal of Charleston
    First Federal Savings and Loan Association of Newark
    First Federal Savings Bank
    First Federal Savings Bank (IN)
    First Federal Savings Bank of Twin Falls
    First Federal Savings Bank- TN
    First Fidelity Bank, NA
    First Fidelity Financial, Inc.
    First Financial Bank NA
    First Financial Bank, NA
    First Financial Bank.
    First Financial Company
    First Financial Equities, Inc.
    First Financial Home Mortgage Corp
    First Financial Mortgage
    First Financial Mortgage Corp
    First Financial Mortgage Corp (KY)
    First Financial Services Inc (MI)
    First Financial Services, Inc.
    First Financial Solutions LLC
    First Financial Trust Mortgage, LLC
    First FL Lending of Tampa Bay, Inc.
    First Florida Bank
    First Florida Home Loans
    First Florida Lending Corporation
    First Florida Mortgage Network, Inc.
    First Franklin Financial Corporation
    First Funding Financial Services, Inc.
    First Funding Group, LLC
    First Greensboro Home Equity, Inc.
    First Guaranty Financial Corporation
    First Guaranty Mortgage Corporation
    First Hallmark Mortgage Corp
    First Harrison Bank
    First Hawaiian Bank
    First Home Financial Services, Inc
    First Home Mortgage Corporation
    First Home Savings Bank
    First Hope Bank
    First Horizon Home Loans, a div. of FTB
    First Houston Mortgage Ltd
    First Illinois Mortgage Inc.
    First Independent National Bank
    First Integrity Mortgage Services, Inc.
    First International Bank and Trust
    First Internet Bank of Indiana
    First Interstate Bank
    First Interstate Financial
    First Jersey Mortgage Services Inc.
    First Liberty Financial Group LLC dba First Liberty Fin Mtg
    First Liberty Mortgage LLC
    First Lincoln Loan Services, LLC
    First Lincoln Mortgage Corp.
    First Madison Loan Services LLC
    First Madison Mortgage Corp
    First Magnus Financial Corporation
    First Maine Mortgage LLC
    First Mark Mortgage Company, Inc
    First Merchants Corporation
    First Michigan Bank
    First Mid-Illinois Bank & Trust N.A.
    First Minnesota Bank
    First Missouri National Bank
    First Mortgage Banc Corporation
    First Mortgage Company, L.L.C.
    First Mortgage Corp.
    First Mortgage Corporation of South Carolina
    First Mortgage Group, Inc.
    First Mortgage of Indiana, Inc.
    First Mutual Bank
    First Mutual Corp
    First Mutual Mortgage Corporation
    First Mutual Mortgage, Inc.
    First National Bank
    First National Bank Alaska
    First National Bank Crossett
    First National Bank Fox Valley
    First National Bank Garden City
    First National Bank In Alamogordo
    First National Bank of America
    First National Bank of Arizona (RAPP)
    First National Bank of Bastrop
    First National Bank of Central Florida
    First National Bank of Chester Cnty through American Home Bk
    First National Bank of Christiansburg
    First National Bank of Durango
    First National Bank of Fabens
    First National Bank of Midland
    First National Bank of Monahans dba Texas Hills Bank
    First National Bank of Montana
    First National Bank of Nassau County a/d/o CBC National Bank
    First National Bank of Northern California
    First National Bank of Omaha
    First National Bank of Pennsylvania
    First National Bank of Santa Fe
    First National Bank of the South
    First National Bank of Trenton
    First National Bank of Wyoming
    First National Bank South Dakota
    First National Bank, Sallisaw
    First National Home Mortgage Corp
    First National Mortgage Banc Inc. dba Eagle Mortgage
    First Nation’s Home Finance Corp.
    First Niagara Bank
    First NLC Financial Services, LLC
    First Northstar Inc. dba Minnesota Mortgage Connection
    First Ohio Banc & Lending
    First Old Capital Inc dba Old Capital Residential Lending
    First Omni Mortgage Lending
    First Option Mortgage
    First Pacific Mortgage Co. Inc
    First Pacific, Inc.
    First Palmetto Mortgage, Inc.
    First Peoples Bank
    First Portfolio Mortgage Corporation
    First Quality Mortgage Company
    First Rate Capital Corp.
    First Reliance Bank
    First Republic Mortgage Corporation dba
    First Residential Mortgage Network, Inc.
    First Residential Mortgage Services Corporation
    First Roosevelt, LLC
    First Savings Mortgage Corporation
    First Security Bank – AR
    First Security Bank of Bozeman
    First Security Bank of Missoula
    First Security Mortgage Company
    First Security Mortgage Services, Inc.
    First Security Trust Bank
    First Service Mortgage
    First Service Mortgage, Inc.
    First Solution Lending, Inc.
    First Source Mortgage, Inc.
    First Southwestern Financial Services
    First State Bank
    First State Bank – IL
    First State Bank (27364)
    First State Bank (IN)
    First State Bank (TX)
    First State Bank and Trust Co
    First State Bank Mortgage Company, LLC
    First State Bank of Middlebury
    First State Bank of the Florida Keys
    First State Bank of Wyoming
    First State Home Loan
    First State Mortgage
    First Suffolk Mortgage Corporation
    First Switzerland Financial
    First Tennessee Bank National Association
    First United Bank
    First United Bank and Trust Company
    First United Home Loans
    First United Mortgage Banking Corp.
    First United Mortgage Company Inc
    First United Mortgage Corporation
    First West Mortgage Bankers LTD
    First Western Bank & Trust
    First Western Funding, LLC
    First Western Mortgage Corporation
    First Western Mortgage, Inc.
    First Wholesale Mortgage Corporation
    First Wisconsin Financial, Inc.
    First World Mortgage Corporation
    FirstBank Holding Company of Colorado/FirstBank of Colorado
    Firstco Mortgage Corp.
    FirsTier Bank Mortgage Division
    Firstline Mortgage Inc.
    FirstMac Corporation
    FirsTrust Mortgage
    Fischer and Fritchel Home Mortgage Co. LLC
    Fiserv – Unifi Products Group
    Fiserv -MortgageServ
    Fiserv Solutions, Inc.
    Fisher Financial Group, Inc. dba NationsChoice Mortgage
    Fitzgerald Mortgage Corp.
    Fitzgerald Mortgage, Inc.
    Five Points Bank
    Five Points Bank of Hastings
    Five Star Financial, Inc.
    Five Star Partnership, LLC DBA Five Star Mortgage
    Flagship Financial Services, Inc.
    Flagship Mortgage Banc Inc a Wholly Owned Subsidiary of Old
    Flagship Mortgage Corporation
    Flagstar Bank
    Flaherty Funding Corporation
    Flat Branch Mortgage, Inc
    Flathead Bank
    FlexPoint Funding Corporation
    Florida Capital Bank Mortgage
    Florida Citizens Bank
    Florida Community Bank
    Florida Parishes Bank
    Floridian Financial Mortgage, LLC
    Flower Bank FSB
    FM Financial Services, Inc. dba Foundation Mortgage
    FM Lending Services, LLC
    FM Mortgage Corporation
    FMWF Trust
    FNT Mortgage Series 2000-1
    Focus Financial & Mortgage
    Forem Capital Inc.
    Foresight Mortgage Corporation
    Forest Park National Bank & Trust Co.
    Fortes Financial, Inc.
    Fortress Financial, LLC
    Fortress Mortgage, Inc
    Fortune Lending Corporation
    Fortune One Mortgage Corporation
    FORUM Credit Union dba FORUM Mortgage
    Foundation Capital Group Inc.
    Foundation Financial Group LLC
    Foundation Financial Services, Inc.
    Foundation Mortgage
    Foundation Mortgage Company Inc.
    Foundation Mortgage Corporation
    Founders Bank
    Founders Bank & Trust
    Fountain Grove Mortgage
    Fowlaw Enterprises, Inc. dba Oakridge Financial Services
    Fox Funding, Inc.
    Fox Mortgage, Inc
    Franek Home Loans dba East Coast Lending
    Frank, Weinberg & Black, P.L.
    Franklin American Mortgage
    Franklin Credit Management Corporation
    Franklin First Financial Ltd dba Franklin First Mtg Bankers
    Franklin Loan Center
    Franklin Mortgage Company
    Franklin Savings and Loan Company
    Freedom Bank
    Freedom Choice Mortgage LLC
    Freedom Financial Mortgage Corporation
    Freedom Financial Solutions, Inc.
    Freedom First Federal Credit Union
    Freedom Lending, LLC
    Freedom Mortgage Corporation
    Freedom Mortgage Corporation – NJ
    Freeland, Rogers, LLC DBA Foundation Mortgage Group
    Freeman Webb Mortgage Corporation
    Freestand Financial Holding Corp
    Freestone Enterprises, Inc. dba Freedom American Mortgage
    Frels Enterprises, Inc dba Mortgage Associates of Texas
    Fremont Bank
    Fremont Reorganizing Corp f/k/a Fremont Investment & Loan
    Friendswood Financial, LTD
    FRMC Financial Inc. dba First Republic Mortgage Corporation
    Frontier 2000 Mortgage & Loan, Inc.
    Frontier Bank FSB dba El Paseo Bank
    Frontier Bank, National Association
    Frontier Financial Inc. dba Frontier Mortgage
    Frontier Investment Co., dba Rainland Mortgage Company
    Frontier Lending Company, LLC
    Frontier National Bank
    FTN Financial Warehouse Lending
    FUCM Private Investor – 1000010455 (NON MEMBER)
    FUCM Private Investor – 1000110455 (NON MEMBER)
    FUCM Private Investor – 1000210455 (NON MEMBER)
    FUCM Private Investor – 1000310455 (NON MEMBER)
    Full House Mortgage, Inc.
    Fulton Bank dba Fulton Mortgage Company
    Funding Resources Mortgage Corp.
    Funding Solutions Inc
    Fusion Home Loans, LLC
    G Squared Financial LLC
    Gabriel Mortgage, LLC
    Garden City Bank
    Garden City State Bank
    Gardner Financial Services LTD dba Gardner Financial Service
    Gateway Bank Mortgage, Inc.
    Gateway Bank, F.S.B.
    Gateway Business Bank dba Mission Hills Mortgage Bankers
    Gateway Capital Mortgage Corp
    Gateway Financial Corporation
    Gateway Financial Services, Inc.
    Gateway Funding Diversified Mortgage Services LP
    Gateway Mortgage Group
    Gateway Residential Funding
    GB Home Equity LLC A Wisconsin Limited Liability Company
    GBC Funding
    GCM Mortgage Inc.
    GCS Federal Credit Union
    GD LLC dba GLF Funding dba Guaranty Lenders Funding
    GD Mortgage Inc
    GE HF Holdings, Inc.
    GE Money Bank
    Gecko Mortgage Incorporated
    Gemini Bancorp, Limited
    GenEquity Mortgage, Inc.
    General Mills Federal Credit Union
    General Mortgage Company
    General Mortgage Corporation of America
    General Mortgage Finance Corp
    Genesee Regional Bank
    Genesis Mortgage Corporation
    Geneva Mortgage Corp
    Geneva Mortgage Services LLC
    Geneva State Bank
    Genisys Financial Corp.
    GEO Financial, Inc dba Blue Water Mortgage Co
    GEO Mortgage Services Inc
    GEO-Corp, Inc. dba Interstate Bancorp
    George Mason Mortgage Corporation
    Georgetown Mortgage Inc dba Home Source Mortgage
    Georgetown Mortgage, Inc.
    Georgia Bank and Trust
    Georgia Banking Company dba GBC Funding
    Georgia Banking Company dba National Mortgage Alliance
    Georgia Home Mortgage Network Inc.
    Gerber Federal Credit Union
    German American Bancorp
    Gershman Investments Corp.
    Gesa Credit Union
    GF Mortgage Inc. dba Greystone Financial
    GFI Mortgage Bankers Inc
    GHS Mortgage dba Windsor Mortgage
    Gilpin Financial Services, Inc.
    GL Financial Services, LLC
    Glacier Bancorp, Inc.
    Glacier Bank
    Glendive BN FCU
    Glenn Computer Corporation
    Glenwood Financial, LLC
    Global Advisory Group dba Mortgage Lending Group
    Global Credit Union
    Global Equity Lending Inc.
    Global Financial Services
    Global Funding Solutions, LLC
    Global Home Loans and Finance
    Global Lending Inc.
    Global Lending Solutions, LLC
    Global Lending, LLC
    Globe Mortgage America LLC
    GMAC Bank
    GMAC Bank – Document Custody Services
    GMAC Bank (1)
    GMAC Mortgage, LLC
    GMC Lending Services Inc.
    GMI Home Loans, LLC dba GMI Funding
    GMS Funding L.L.C.
    GNL Inc., dba Freedom Mortgage & Loan
    Go Blue, Inc. dba The Mortgage Group
    Goal Mortgage Funding, Inc.
    Gold Bank
    Gold Mortgage Banc Inc.
    Gold Star Mortgage Financial Group Corporation
    Golden Empire Mortgage, Inc.
    Golden Equity Mortgage Corp.
    Golden First Mortgage Corp
    Golden Rule Mortgages, Inc.
    Golden West Funding, Inc.
    Goldenwest Credit Union
    Goldman Sachs Bank USA
    Goldman Sachs Mortgage Company
    Golf Savings Bank
    Gordon Lending Corporation
    Gorman & Gorman Residential Mtg. Svs., Inc.
    Gotham Mortage Corporation
    Govell Funding Group LLCdba CT Home Loans
    Government National Mortgage Association
    Grabill Bank
    Grace America Mortgage LTD
    Grace Funding Inc.
    Grand Bank, NA
    Grand Rivers Community Bank
    Grand Valley National Bank
    Grande Homes, Inc. dba GHI Mortgage
    Granite Mortgage & Construction Finance Inc
    Granite Mortgage Corp
    Graystone Funding Company LLC dba Graystone Mortgage LLC
    Graystone Mortgage LLC
    Graystone Solutions, Inc.
    Great Country Mortgage Bankers, Corp.
    Great Eastern Mortgage & Investment Inc
    Great Florida Bank
    Great Horizons, Inc. dba Great American Mortgage
    Great Lakes Bank, NA
    Great Lakes Mortgage & Inv Inc.
    Great Lakes Mortgage Brokers LLC
    Great Northern Bank
    Great Northern Financial Corporation
    Great Northern Financial Group, Inc.
    Great River Federal Credit Union
    Great Southern Bank
    Great Western #1 Inc.
    Great Western Bank
    Great Western Financial Group
    Great Western Financial Services, Inc
    Great Western Home Loans
    Greater Acceptance Mortgage Corporation
    Greater Atlanta Mortgage Co.
    Greater Atlantic Mortgage Corporation
    Greater Financial Mortgage Corp
    Greater Iowa Credit Union
    Greater Midwest Mortgage Corp
    Greater Nevada Mortgage Services
    Greater Northwest Mortgage Inc.
    Greater Potomac Mortgage Company
    Greater United Home Funding, Inc.
    GreatHouse Mortgage, Inc
    Green Bay Mortgage Headquarters, LLC DBA Green Bay Mortgage
    Green Planet Mortgage, LLC
    Green Planet Servicing LLC
    Green Tree Servicing LLC
    Greenback Funding Inc.
    Greenco Financial Mortgage Bankers
    Greenfield Co-Operative Bank
    Greenfield Mortgage Corporation
    Greenlight Financial Services
    Greenpark Mortgage Corporation
    GreenPoint Mortgage Funding Inc.
    Greentree Mortgage Company, L.P.
    Greenwich Capital Financial Products, Inc
    Greenwich Investors XXVI, LLC
    Greenwood Properties LLC
    Greg Bissmeyer dba GB Mortgage
    Gregg & Valby Mortgage Services
    Greystone Bank (R)
    Greystone Financial Group
    Griffin Lending LLC #84861
    Grimaldi Capital Funding, Inc.
    Group One Mortgage Corporation
    Group One Mortgage Inc.
    Grovebay Financial, Inc
    Groves Funding Corporation
    GSB Mortgage Inc.
    GSC Capital Corp
    GSF Mortgage Corporation
    GTKY Credit Union Inc
    Guaranteed Home Mortgage Company, Inc.
    Guaranteed Mortgage Brokers Inc
    Guaranteed Rate, Inc
    Guaranty Bank (MO)
    Guaranty Bank (Texas)
    Guaranty Bank, FSB
    Guaranty Federal Financial Corp.
    Guaranty Trust Company
    GuardHill Financial Corp.
    Guardian Financial Network Inc.
    Guardian Mortgage, Inc.
    Guardian Nationwide Mortgage Inc.
    Guidance Mortgage Group, LLC
    Guidance Mortgage LLC
    Guild Mortgage Company
    Gulf Atlantic Funding Group, Inc.
    Gulf Coast Bank & Trust Co. Non Mortgage
    Gulf Coast Bank and Trust Company
    Gulf Coast Community Bank
    Gulf Coast Mortgage Inc
    Gulf Coast Principle, LLC
    Gulf States Mortgage
    Gulfstream Business Bank
    Gum Tree Mortgage, LLC
    GVC Mortgage Inc dba Preferred Capital
    H & R Block Mortgage
    H&H Financial Group LLC dba Life Mortgage Group
    H&R Block Bank
    H.M.M. Enterprises, Inc.
    Habersham Bank
    Habitat Mortgage Company Inc
    Hallmark Home Mortgage
    Hallmark Mortgage Services, Inc.
    Hamilton Federal Bank
    Hamilton Group Funding Inc.
    Hamilton Mortgage Corporation
    Hamilton National Mortgage Company
    Hammer Mortgage, Inc.
    Hammond Securities Co., LLC
    Hancock Bank
    Hanover Mortgage Company
    Happy State Bank
    Harbor Financial Mortgage Corporation
    Harbourton Mortgage Investment Corporation
    Hargrow & Associates Inc dba MH&A Financial Service
    Harris Nesbitt Corp. (As Agent for Fairway Finance Co., LLC.
    Harry Mortgage Company
    Hart West Financial
    Hartford Financial Services Inc.
    Hartland Mortgage Centers Inc
    Harvest Financial.Net, Inc DBA Harvest Financial
    Hawthorn Bank
    Hawthorne Capital Corp
    Hawthorne Credit Union
    Hayhurst Mortgage, Inc.
    HBC Investment Group, Inc. dba All-American Mortgage
    HCI Mortgage
    HCL Finance, Inc.
    Hearthside Lending Corp.
    Heartland Bank
    Heartland Bank.
    Heartland Community Bank
    Heartland Credit Union
    Heartland Funding Corp
    Heartland Home Finance Inc
    Heartland Mortgage Company
    Heartland Mortgage Company LC
    Heartland National Bank
    Heartwell Mortgage Corporation
    Hedlund Mortgage LLC
    Hela Corporation dba Integra Pacific Mortgage
    Helpbringer Mortgage Services, Inc.
    Hemant Shah dba NJ Mortgage Services
    Hemisphere National Bank, Mortgage Division
    HengerRast Mortgage Corporation
    Heritage Financial Group, LLC
    Heritage Mortgage & Loan, Inc
    Heritage Mortgage Services, LLC
    Heritage Oaks Bank
    Heritage Plaza Mortgage, Inc.
    Heritage Savings Bank
    Herman-Morrie Enterprises Inc. dba Hawaii’s Premiere Mtg. Co
    Hernandez Services Inc.
    HF Financial Corp
    HFC – Beneficial
    HFN – Consumer Orig.
    HIgh Point Mortgage Corp
    High Tech Lending
    Highland Banc, Inc
    Highland Federal Savings & Loan
    Highland Financial Co., LLC.
    Highmark Federal Credit Union
    Hillcrest Bank
    Hills Bank and Trust Company
    Hilton Head Mortgage, LLC
    Hilton Mortgage Corporation II
    Hinds Mortgage Inc
    HL Mortgage, LLC
    HMC – Home Mortgage Consultants, Inc.
    HMC Funding Inc.
    HNB Mortgage
    Hogar Mortgage
    Home 123/New Century
    Home Bank SB
    Home Capital Funding
    Home Capital, Inc.
    Home City Federal Savings Bank of Springfield
    Home Equity Solutons LTD
    Home Express
    Home Fed Realty Corp
    Home Federal Bank ID
    Home Federal Savings and Loan
    Home Federal Savings Bank
    Home Finance of America
    Home Inc.
    Home Financial, Inc.
    Home Financing Center Inc.
    Home Financing Unlimited, Inc.
    Home Funding Corporation
    Home Funding Finders, Inc.
    Home Loan Center dba Lending Tree Loans
    Home Loan Consultants
    Home Loan Consultants Inc
    Home Loan Corporation
    Home Loan Funding Inc
    Home Loan Mortgage Company
    Home Loan Mortgage Corporation
    Home Loan Network
    Home Loan Professionals, LLC dba Home Loan Professionals
    Home Loan Services, Inc.
    Home Loan Specialists Inc.
    Home Loans USA Inc. (Orange)
    Home Mortgage Associates, Inc.
    Home Mortgage Corporation
    Home Mortgage Desk Corp.
    Home Mortgage Finance Group Corp
    Home Mortgage Inc.
    Home Mortgage Lending, LLC
    Home Mortgage Resources Inc
    Home Mortgage Solutions, Inc.
    Home Mortgage, Inc.
    Home N Mortgage, Inc.
    Home National Bank N.A.
    Home Savings & Loan Co. of Youngstown, Ohio
    Home Savings & Trust Mortgage
    Home Savings bank
    Home Savings Mortgage
    Home Service Associates, Inc.
    Home South Mortgage Corporation
    Home State Bank & Trust Co
    Home State Mortgage Group
    Home Team Equity, LLC
    Home Town Mortgage Inc
    Home USA Mortgage, Inc.
    Home Vest LLC
    HomeAmerican Mortgage Corporation
    HomeBanc N.A.
    Homebound Mortgage, Inc.
    Homebuyers Financial LLC
    Homebuyer’s Resource Group, LLC
    HomeComings Financial, LLC
    HomeComings Wholesale Funding
    Homefield Financial Inc.
    HomeFirst Mortgage LLC
    HomeFirst Mortgage Services LLC
    Homefront Mortgage Group LLC
    Homeland Capital, LLC
    Homeland Mortgage LLC
    Homeline Mortgage Corp
    Homelink Mortgage Inc
    HomeLoan USA Corporation, Inc.
    Homeowners Financial Group USA, LLC.
    Homeowners Financial Services, Inc.
    Homeowners Friend Mortgage Company, Inc.
    Homeowners Mortgage Enterprises, Inc.
    HomeOwners Mortgage of America, Inc., Inc.
    HomePoint Mortgage Group LLC
    HomePromise Corporation
    HomEq Servicing
    Homequest Capital Funding LLC
    Homeservices Financial, LLC
    Homeservices Lending, LLC Series A (CA)
    Homeservices Lending, LLC Series A DBA Mortgage South
    Homesource Funding Group
    Homesource Lending Inc.
    Homespring Financial LLC
    Homespun Mortgage Corporation
    HomeStar Financial Corporation
    Homestar Lending Corporation
    Homestar Mortgage Services (Vendor)
    Homestar Mortgage, Inc.
    HomeStart Mortgage Corporation
    Homestead Financial Services, Inc.
    Homestead Funding Corp
    Homestead Mortgage Company LLC dba Homesite Mortgage
    Homestead Mortgage Corporation
    Homestead Mortgage Inc.
    Homestead-USA, Inc.
    HomeStreet Bank
    HomeTech Mortgage Corporation
    Hometown America Incorporated
    Hometown Bank of Corbin
    Hometown Equity Mortgage of St. Louis, Inc.
    HomeTown Financial Group, Inc.
    HomeTown Lenders LLC
    Hometown Lending
    HomeTown Mortgage Services, Inc.
    Hometown Security Mortgage Inc
    Hometowne Lending L.L.C.
    HomeTrust Bank
    Hometrust Mortgage Company
    HomeTrust Mortgage Inc.
    Hometrust Mortgage Services LLC
    HomeValue Mortgage, Inc.
    Homevest Mortgage Corporation
    Homeview Lending
    Homewide Lending Corp.
    Homewise Inc.
    Honda Federal Credit Union
    Honesdale National Bank
    Honor State Bank
    Hopewell Federal Credit Union
    Horizon Bank
    Horizon Bank (MN)
    Horizon Bank, Mortgage Warehousing Division
    Horizon Bank, N.A.
    Horizon Direct, Inc. dba Commitment Lending
    Horizon Financial Group, Inc.
    Horizon Mortgage Corp. DBA Americhoice Residential Funding
    Horizon National Bank
    Horizon National Lending
    Housing & Neighborhood Development Services, Inc. dba HANDS
    Housing Opportunity Comm. – Non-Member Investor
    Housing Solutions, Inc.
    Houston Prime Mortgage, LLC
    Houstonian Mortgage Group, Inc. DBA Westin Mortgage Group
    Howard Bank
    Howard Hanna Financial Services, Inc.
    Howard Hanna Mortgage Services
    HSBC Bank USA
    HSBC Bank USA as Trustee
    HSBC Bank USA, NA – Non-Affiliate
    HSBC Bank USA, National Association
    HSBC Mortgage Corporation, USA
    HSBC Mortgage Services
    HSBC Mortgage Services Warehouse Lending Inc
    HTFC Corporation DBA HTFC Mortgage Bankers, Miracle Funding
    Hudson City Savings Bank
    Humbert Mortgage
    Humphries Mortgage Inc.
    Hunt Mortgage
    Hunter Financial Group LLC
    Huntingdon Valley Bank
    Huntington Community Mortgage Bankers
    Huron Valley Financial Inc
    Hyde Park Bank
    Hyperion Capital Group LLC
    Hyperion Capital Group, LLC
    IAA Credit Union
    iApprove Lending
    Iberia Mortgage Corp.
    IBEX Networks, Inc.
    Idaho Banking Company
    Idaho First Bank
    Idaho Independent Bank
    Ideal Home Loans, Inc
    Ideal Mortgage Specialists, Inc
    Identico Inc. dba Constantine Mortgage Services
    IDS, Inc
    IFG Mortgage Services, Inc.
    iFreedom Direct Corporation
    Ikon Mortgage Lenders, Inc.
    Illinois Mortgage Funding Corporation
    Iltis Lending Group Inc.
    Imath Inc dba 21st Century Mortgage
    IMC Funding Group, Inc. Inc.
    Impac Funding Corporation
    Impac Mortgage Acceptance Corporation dba Impac Funding Corp
    Impac Warehouse Lending Group
    Impact Mortgage Group, Inc.
    Imperial Lending LLC
    IMS Mortgage Services
    Independence Community Bank
    Independence Financial Corporation
    Independent Capital Group, Inc
    Independent Financial Mortgage, Inc
    Independent Mortgage
    Independent Realty Capital Corp.
    Indiana Members Credit Union
    Indianapolis Neighborhood Housing Partnership
    Indigo Fincancial Group, Inc
    IndyMac Federal Bank FSB
    I-Net Mortgage Corp
    Infinite Financial Corporation dba Metropolitan Home Mtg
    Infinite Mortgage Services, LLC
    Infinity Financial Corp
    Infinity Financial Network LLC
    Infinity Funding Corp.
    Infinity Group Services
    Infinity Home Mortgage Company Inc.
    Infinity Information Solutions LLC, wos of First American RE
    Infinity Mortgage Co. Inc
    Infinity Mortgage Corporation
    Infinity Mortgage Corporation.
    Information Engineering Services, Inc.
    Ingle & Associates Mortgage Services, Inc dba Ingle Mortgage
    Ingomar Limited Partnership
    Inland Northwest Bank
    Innergy Lending LLC
    Innovative Financial Services, Inc.
    Innovative Mortgage Capital, LLC
    Innovative Mortgage Concepts LLC
    Innovative Mortgage Solutions LLC
    Innovative Property Services, Inc.
    Insight Bank
    Insight Financial Corporation
    InSource Financial Services LLC
    InSouth Funding Inc
    Instant Capital Funding Group, Inc.
    Integrated Financial Group, Inc.
    Integrated Lending, Inc.
    Integrated Mortgage Corporation
    Integrated Mortgage Services Inc.
    Integrated Mortgage Strategies Ltd.
    Integrity Bancorp
    Integrity Financial LLC
    Integrity Financial Services of Tampa Bay Inc.
    Integrity Financial Services, Inc.
    Integrity First Financial, Inc.
    Integrity First Home Loans Inc
    Integrity Home Loan of Central Florida Inc
    Integrity Home Mortgage Corporation
    Integrity Lending LLC
    Integrity Mortgage & Financial Incorporated
    Integrity Mortgage LLC
    Integrus Mortgage LLC
    Intelli Mortgage Services, Inc.
    Inter Mountain Mortgage
    Inter National Bank
    Inter Savings Bank, FSB
    InterBay Funding, LLC
    InterContinental Capital Group, Inc.
    Intercontinental Mortgage Partners of Texas, LP
    Interlinc Mortgage, Inc.
    Intermountain Industries, Inc. dba Major Mortgage USA
    Intermountain Mortgage Company Inc
    International Bank of Commerce
    International Bankers Financial Group
    International Home Capital Corporation
    International Lending Solutions, Inc.
    International Mortgage Corporation
    Interra Credit Union
    Interstate Home Loan Center Ind dba
    Interthinx, Inc
    Intertrust Mortgage LLC
    Intervale Mortgage Company, Inc.
    InTouch Mortgage Inc.
    Intracoastal Mortgage Co. LLC
    Intrust Mortgage, Inc.
    Investaid Corporation
    Investors Mortgage Asset Recovery Company, LLC dba IMARC
    Investors Mortgage Company, Inc.
    Investors Trust Mortgage & Investment Co. Inc.
    Iowa Bankers Mortgage Corporation
    Iowa Mortgage Professionals, In.c
    iQ Credit Union
    Ireland Bank
    Ires Co.
    IronStone Bank
    Irwin Home Equity
    Irwin Mortgage Corporation
    Irwin Union Bank and Trust
    iServe Servicing Inc.
    Island Community Mortgage Services LLC dba Island Mortgage
    Ivanhoe Financial, Inc.
    iWayloan LP
    IZT Mortgage Inc. dba Ameritech Mortgage
    J and E Mortgage Services LLC
    J&M Mortgage Brokers, LTD dba Mortgages USA
    J&R Lending Inc.., dba First Security Lending
    J&S Holdings of Greenville Inc. dba First United Mortgage
    J. Allston Mortgage LLC
    J. Friedman Inc dba J. Friedman Mortgage & JRA Mortgage
    J. Philips Mortgage Inc.
    J. Powder Mortgage, Ltd.
    J. Virgil, Inc. dba The Lending Factory
    J.D. Martinez Investments, Inc. DBA AllBay Mortgage Services
    J.S. Shirk & Associates, Inc. dba Florida Community Mortgage
    J.S. Smith Mortgage, LLC
    Jabez Financial Services, LLC
    JAC Financial Inc. dba Plaza Loan Services
    Jam Consultants
    Jamsab Realty Corp
    Jason B. Jones dba Halo Capital
    Jayco Capital Group dba Loan Solutions
    JBJ, LLC dba Precision Mortgage
    JC Reed Mortgage LLC
    JCJ Mortgage Ventures, L.P.
    JDB Mortgage Corp.
    JDH Capital, LLC
    JDJ Financial Group Inc.
    Jefferson Bank
    Jefferson Bank & Trust co.
    Jefferson Mortgage Services, Inc
    Jennifer Farley dba South River Mortgage
    Jersey Mortgage Company
    JFK Financial Inc. dba Equity Direct Funding
    JJAM Corporation
    JJM Investments, Inc.
    JKS Mortgage, LLC
    JLB Corporation dba Golden Oak Lending
    JMAC Lending, Inc.
    JMJ Financial Group dba The Coastal Lending Group
    JMJ Mortgage Capital, LLC
    Joe Klein Enterprises LTD d/b/a The Mortgage Store
    John Adams Mortgage
    John H.D. Goemans, Inc. dba The Mountain Mortgage Centers
    Johnson Mortgage Company, LLC
    Jonah Bank of Wyoming
    Jones Mortgage Group
    Jordon Financial Group, LLC
    JP Morgan Chase Bank
    JP Morgan Chase Bank as Trustee
    JP Morgan Chase Bank NA
    JP Morgan Chase Bank, N.A. – Warehouse Lending
    JP Morgan Chase Bank, N.A. – Warehouse Lending Vendor
    JPMorgan Chase Document Custodian
    JT, Inc dba Nortex Mortgage
    JTM Financial Services, Inc.
    Judith O. Smith Mortgage Group, Inc.
    Just Mortgage, Inc.
    Just Write Funding LP dba CU JWF Associates, Inc.
    JZ Mortgage Inc. dba Equity Funding Co.
    K & G Capital Mortgage LP
    K Bank
    K Hovnanian American Mortgage LLC
    K&B Capital Corp
    K&G Financial, LLC
    K.P. Riley Mortgage Corporation
    Kaiser & Associates Mortgage Services, Inc
    Kaiser Federal Bank
    Kansas City Mortgage Group LLC
    Kastle Mortgage Corporation
    Kaw Valley Home Loans, Inc.
    Kay-Co Investments, Inc. dba Pro30 Funding
    Kaye Financial Corporation
    KCB Bank
    KE Enterprises LLC
    Kellner Mortgage Investments I, LTD
    Kelly Stephens Mortgage Inc. dba KS Mortgage Inc.
    Kelstar Financial Services LLC
    Kemp Mortgage LLC
    Kenilworth Financial Inc.
    Kennedy Mortgage Corp
    Kenney Bank and Trust dba America’s Home Loan
    Kentucky Housing Corporation
    Kentucky Neighborhood Bank, Inc.
    Kentucky Telco Federal Credit Union
    Key Financial Corporation
    Key Mortgage Company, Inc.
    Key Mortgage Lenders, L.L.C.
    Key Mortgage Link, Inc.
    Key Mortgage Services
    Key Mortgage Services Inc dba Baird & Warner Financial Serv.
    Keynote Equity Group, LLC
    KeyPoint Credit Union
    KeySource Commercial Bank
    Keystone Home Mortgage, LLC
    Keystone Mortgage
    Keystone Mortgage Company, Inc.
    KH Financial, LP
    Kiertec Inc. dba US Mortgage Source
    Kinetic Mortgage Group
    King Financial Group, Inc.
    Kings Mortgage Services, Inc.
    Kingswood Mortgage Inc.
    Kirkland Investors LLC
    Kirkwood Bank & Trust Co.
    Kirkwood Financial Corporation
    Kirsten Estes dba Mountain Home Lending
    Kitsap Credit Union
    KleinBank, dba KleinMortgage
    KLW, Inc dba Northside Mortgage
    Knightbridge Mortgage Bankers
    Kohler Credit Union
    Kondaur Capital Corporation
    Kroboth & Helm Mortgage Company, Inc.
    KSC Investment Group, LLC
    Kubrick Financial
    L & G Mortgagebanc Inc
    LA Financial Federal Credit Union
    La Rue Residential Lenders LLC
    Lafayette Bank & Trust Company
    Lafayette Community Bank
    Lake Area Mortgage, A Division of Lake Area Bank
    Lake Community Bank
    Lake Creek Financial LLC
    Lake Dillon Mortgage Services, Inc.
    Lake Michigan Credit Union
    Lake Mortgage Company, Inc.
    Lake Mortgage Group, LLC dba Lake Mortgage
    Lake State Federal Credit Union
    Lakeland Mortgage Corporation
    Lakes Area Mortgage, LLC
    Lakeshore Mortgage Group Inc.
    Lakeside Bank
    Lakeside Lending LTD
    Lakeside Mortgage Company
    Lakeview Bank
    Lakeview Mortgage, Inc.
    Lancaster Mortgage Bankers LLC
    Land Home Financial Services, Inc.
    Landmark Mortgage & Associates Inc
    Landmark Mortgage Corporation
    Landmark Mortgage Lending
    Landmark Mortgage LLC
    Landmark Mortgage of Tampa Bay, Inc.
    Landover Mortgage, LLC
    Langdon Motrgage Company, Inc.
    Laraby Financial Group Inc.
    LaSalle Bank NA Trustee for BancOne Series 2000-2
    LaSalle Bank NA, Trustee for BancOne Series 2000-1
    Lawrence Bank
    Lawrence Residential Funding Corp.
    Lawrence Winslow dba All Texas Mortgage
    Layton State Bank
    LBA Financial Group
    Leader Bank, N.A.
    Leader Financial Services, a div of American National Bank
    Leader Mortgage Company, Inc.
    Leader Mortgage Corp
    LeaderOne Financial Corporation
    Leahy & Walker Financial Services
    Leavitt Inc.
    Lee Financial Corporation
    Legacy Bank
    Legacy Financial Corporation
    Legacy Funding Corp.
    Legacy Group Lending, Inc.
    Legacy Lending, Inc.
    Legacy Mortgage Group LLC
    Legacy Mortgage Inc.
    Legacy Texas Mortgage, LP
    Legend Lending Corporation
    Legendary Home Loans, Inc.
    Lehman Brothers Bank
    Lehman Brothers Holdings Inc.
    Lehman Commercial Paper, Inc.
    Lehman/FNMA Non-Laser
    Leitchfield Deposit Bank and Trust Company
    Lend America
    Lend America, Inc.
    Lend Smart Mortgage LLC
    LendAmerica Home Loans, Inc.
    Lender Ltd.
    Lender Processing Services, Inc. (aka LPS)
    Lenders Association, Inc.
    Lenders Depot Inc.
    Lenders Direct Capital Corporation
    Lenders Rate, Corp.
    Lendia, Inc.
    Lending 1st Mortgage, LLC
    Lending Bankers Mortgage LLC
    Lending Capital Group, LLC
    Lending Solutions Inc. dba LSI Mortgage Plus
    Lending Street, L.L.C.
    LendingSpace, Inc.
    Lend-Mor Mortgage Bankers Corp
    Lendmor, LLC
    LendSource, Inc.
    LendSouth Mortgage, Inc.
    Lenox Financial Mortgage Corporation
    Level One Bank
    Lewis Hunt Enterprises dba Interactive Financial Corporation
    Lexim Mortgage
    Lexingtonton Capital Corp dba Lexington Mortgage
    LFM Group Inc. DBA LIRA Financial Mortgage
    LG & MG Corporation dba Precise Mortgage Lending
    LHI Mortgage
    LHM Financial dba CNN Mortgage Inc.
    Libertad Bank SSB
    Liberty 2000 Enterprises, Inc.
    Liberty Alliance Federal Credit Union
    Liberty Bank
    Liberty Bank and Trust Company
    Liberty Bank of Arkansas
    Liberty Federal Mortgage LLC, dba First United Inc LLC
    Liberty First Credit Union
    Liberty Home Lending, Inc.
    Liberty Home Loan Corporation
    Liberty Home Loans
    Liberty Mortgage Corp.
    Liberty Mortgage Corporation
    Liberty Mortgage Corporation dba Liberty Home Mortgage
    Liberty Mortgage Funding Inc.
    Liberty Mortgage Group, LLC
    Liberty Mortgage Services, LLC
    Liberty Mortgage, Inc.
    Liberty Savings Bank FSB
    Liberty Savings Bank, F.S.B.
    Liberty State Finance, LLC
    LibertyQuest Financial Inc dba LibertyQuest
    Lifeline Christian Mortgage Inc
    Lifestyle Mortgage Holdings, Inc.
    Lifestyle Mortgage II, LLC
    Lifetime Financial Partners Inc.
    Lifetime Financial Services LP dba Town and Country Mortgage
    Lifeway Lending Group Inc.
    Lighthouse Mortgage Company, Ltd.
    Lighthouse Mortgage Service Co Inc.
    Lighthouse Mortgage USA, Inc.
    Lime Financial Services, LTD.
    Limes Financial Funding, LTD
    Linc Capital LLC
    Linco Capital LLC dba Kirkwood Mortgage
    Lincoln Bank
    Lincoln Capital Advisors, LLC
    Lincoln County Credit Union
    Lincoln Federal Savings Bank
    Lincoln Mortgage Co.
    Lincoln Mortgage Corporation
    Lincoln Park Savings Bank
    Lincolnway Community Bank
    Lindstrom Financial Group, Inc.
    Link One Mortgage Bankers LLC
    Linn Area Credit Union
    Liquid Financial Group Inc
    Litton Loan Servicing LP
    LJL Mortgage Pool, LLC
    Lo, Inc. dba Reliance Mortgage Inc.
    Loan Across America dba Loan America, Inc.
    Loan America Home Mortgage Inc.
    Loan Center of California, Inc.
    Loan Correspondents, Inc. dba Capital Funding Group
    Loan Lines, Inc.
    Loan Link Financial Services
    Loan Management Services, Inc.
    Loan Network, LLC
    Loan Resource Center, Inc. DBA Optima Home Mortgage
    Loan Services, Inc.
    Loan Servicing Solutions, LLC
    LoanCare Servicing Center, Inc
    Loancorp Financial Inc.
    Loanfinders of SC., Inc.
    Loangistics Mortgage Solutions, LLC
    LoanPlex Mortgage
    LoanStar Mtg, LLC dba LoanStar Mortgage
    Logan Finance Corporation
    Lombard Financial Corp., LLC
    Lone Star Mortgage of DFW
    Lord and Silva, LLC
    Lovell, Hubbard & Associates, Inc. dba LHA Mortgage Services
    LownHome Financial Holdings LLC
    LP Direct LLC
    LPS Field Services, Inc.
    Lubbock Housing Finance Corporation
    Lubbock National Bank Mortgage
    Lucey Mortgage Corp.
    Lumina Mortgage Company
    Luminent Mortgage Capital Inc.
    Lundin & Associates Inc.
    Luxury Mortgage Corp.
    Lydian Data Services, LLC
    Lydian Private Bank
    Lydian Technology Group
    Lyndsey Home Mortgage Express, Inc.
    Lynx Mortgage Bank, LLC
    Lyons Enterprises dba LEI Financial
    Lyons Mortgage Services, Inc.
    M & T Bank
    M&I Bank
    M&I Bank FSB
    M&I Mortgage
    M.I.F. Services Inc.
    M.Point Mortgage Services, LLC
    M/I Financial Corp.
    Mac and Waters Mortgage Group Inc.
    Macarthur & Baker International Inc d/b/a MBI Mortgage Fndg
    Macatawa Bank
    Mac-Clair Mortgage Corporation
    Mackinac Savings Bank
    Macon Mortgage, Inc.
    Madera Financial, Inc.
    Madison Financial LLC
    Madison Home Equities, Inc.
    Madison Mortgage Corporation
    Magellan Harbor Lending, LLC
    Magellan Mortgage Corp
    Magnolia Mortgage Company LLC
    Magnolia Mortgage Inc.
    MAI Mortgage Inc.
    MAIA Mortgage Finance Statutory Trust
    Main Stream Financial, Inc.
    Main Street Financial Group, Inc.
    Main Street Financial, Inc.
    Maine Home Mortgage Corp.
    Mainland Mortgage Corp
    Mainline Mortgage Corporation
    Mainsource Bank
    Mainstreet Mortgage, Inc.
    Maitland Mortgage Lending Company
    Majestic Home Mortgage Corp.
    Majestic Mortgage Services, Inc.
    Majesty Mortgage, Inc.
    Major Mortgage
    Mak Mortgage Consultants Inc
    Malcap Mortgage LLC
    Mandalay Mortgage LLC
    Mandalay Mortgage LLC(CA) dba Capital Six Funding
    Manhattan Financial Group, Inc.
    Manhattan Mortgage Corporation
    Mann Financial, LLC
    MAR Group LLC
    Marathon Asset Investment Trust 2007-1
    Marathon Asset Investment Trust 2007-2
    Marathon Asset Management
    Marathon Mortgage
    Marathon REO Management LLC
    Marathon Structured Asset Solutions Trust
    Mardy L Dallas dba Great Western Mortgage
    Maribella Mortgage, LLC
    Marimark Mortgage, LLC
    Mariner’s Bank
    Marion State Bank
    Maritime Mortgage Corp
    Marix Servicing
    Mark James Haselhorst dba Arbor Mortgage
    Market Mortage Co., Ltd.
    Market Street Mortgage Corporation
    Marketline Mortgage
    Marketplace Home Mortgage, LLC
    Marlin Mortgage Company LLC
    Marquis Financial Group
    Marquis Money Inc.
    Marshall BankFirst Mortgage Group
    Marshland Community Federal Credit Union
    Martin Funding Corp
    Marty Cancila Mortgage LLC dba Capital Funding Group
    Maryland Residential Lending LLC dba Nationwide Mortgage Ser
    MAS Associates LLC dba Equity Mortgage Lending
    Mason Dixon Funding, Inc.
    Mason-McDuffie Mortgage Corporation
    Massachusetts Housing Finance Agency
    Massachusetts Mutual Life Insurance Company c/o Babson Cap.
    Master Financial, Inc.
    Matrix Financial Services Corporation
    Mattamy Home Funding, LLC
    Mattocks Mortgage, Inc.
    Maverick Funding Corp
    Maverick Residential Mortgage
    Maxim Capital Inc.
    Maxim Investment Group, LLC
    Maxim Mortgage Corporation
    Maxwell Funding Inc. dba Maxwell Funding Group
    Mayer Home Mortgage Co. LLC
    MBA Financial Solutions, Inc. dba Bay Wholesale Lending
    MBI Mortgage, Inc.
    MBJ Mortgage Services America, LTD. dba Merchants Home Loan
    MBS Mortgage Comapny, LLC
    MBT Credit Company, Inc.
    MC Harbor Investment Co
    McCabe Mortgage Group, Inc.
    McCaughan Mortage Co., Inc.
    McJab Inc. dba First California Funding
    McLean Mortgage Corporation
    MCM Companies LLC
    McMillin Mortgage, Inc
    MCS Mortgage Bankers, Inc.
    MDKJR Inc.
    Meadowbrook Mortgage Corporation
    Mecco Financial, Inc.
    MECE Credit Union
    Meetinghouse Cooperative Bank
    MEG Co., LLC
    Mega capital Funding, Inc.
    MegaStar Financial Corp.
    Member First Mortgage LLC dba Michigan First Mortgage LLC
    Member Options LLC
    Members Cooperative Credit Union
    Members Loan Services, Inc.
    Members Mortgage
    Members Mortgage Company, Inc.
    Members Preferred Mtg. Services Inc.
    Members1st Community Credit Union
    MembersAlliance Credit Union
    Menna Company dba Independent Mortgage Associates
    Mennonite Financial Federal Credit Union
    Mercantile Bank d/b/a Florida Wholesale Mortgage
    Mercantile Bank Mortgage Company LLC
    Merchants & Farmers Bank
    Merchants & Southern Bank
    Merchants and Manufacturers Bank
    Merck Sharp and Dohme Federal Credit Union
    Mercury Inc.
    Meridian Lending Corporation
    Meridian Lending Inc. dba All Source mortgage
    Meridian Residential Capital LLC dba First Meridian Mortgage
    Meridias Capital
    Merit Financial Inc.
    Merit Financial Services LLC
    Merit Mortgage Services
    Meritage Home Funding, LLC
    Meritas Mortgage LLC
    Meriwest Credit Union
    Meriwest Mortgage Company LLC
    Merrill Lynch (surf)
    Merrill Lynch Bank USA
    Merrill Lynch Credit Corporation
    Merrill Lynch Mortgage Lending, Inc. (Subprime)
    Merrimack Mortgage Company, Inc.
    Merrlin Mortgage Corporation
    MERS Link Subscriber
    MetAmerica Mortgage Bankers, Inc.
    Metlife Bank, N.A.
    MetLife Home Loans, a Division MetLife Bank, N.A.
    Metro Atlanta Mortgage Company, Inc.
    Metro Finance
    Metro Funding Corporation
    Metro Health Services FCU dba Metro First Mortgage
    Metro Mortgage Corporation
    Metro One Mortgage LLC
    MetroBoston Mortgage Co., Inc.
    Metrocities Mortgage LLC
    Metropolitan Bank Group
    Metropolitan Financial Services Inc
    Metropolitan Home Mortgage, Inc.
    Metropolitan Mortgage Bankers Inc.
    Metropolitan Mortgage Group, Inc. dba Metropolitan Mortgage
    Metropolitan National Bank
    Metropolitan National Bank (MO)
    Metropolitan National Bank Mortgage Company
    Metrostate Financial and Real Estate Corp
    Metuchen Savings Bank
    MFC Mortgage Inc
    MFG Funding
    MGM Funding, LLC
    MGN Funding Corp.
    MHC I, Inc.
    MHL Funding Corp
    Michael David Financial Inc dba Cornerstone Lending
    Michigan Fidelity Acceptance Corporation
    Michigan Heritage Bank
    Michigan Mutual, Inc.
    Michigan United Mortgage LLC
    Mid America Bank & Trust Company
    Mid America Mortgage Services of IL Inc. Carterville Branch
    Mid America Mortgage Services of Illinois, Inc.
    Mid America Mortgage Services of Kansas City, Inc.
    Mid Atlantic Capital, LLC
    Mid Valley Services, Inc.
    Midamerica Mortgage Corporation
    Mid-Atlantic Federal Credit Union
    Mid-Atlantic Financial Services, Inc.
    MidCarolina Bank
    Midcontinent Fin Ctr Inc d.b.a. American Mutual Mortgage Co.
    MidCountry Bank
    Middlekauff Mortgage Co.
    MidFirst Bank
    Mid-Island Mortgage Corp.
    Midland Federal Savings & Loan
    Midland Mortgage Corporation
    Midtown Bank
    Midtown Financial Services
    Midtown Mortgage Inc
    Midtowne Mortgage
    Midwest Community Bank
    Midwest Equity Mortgage LLC
    Midwest Financial Mortgage
    Midwest Funding Bancorp
    Midwest Heritage Bank, FSB
    Midwest Home Loans LLC
    Midwest Loan Services, Inc.
    Midwest Mortgage Capital
    Midwest Mortgage Investments, LTD
    Midwest Mortgage Planners, Inc.
    Midwest National Mortgage Corporation dba Midwest Natl Mort
    Midwest Residential Lending, LLC
    Mid-Wisconsin Bank
    Miguel A, Baylon, Jr. dba Baylon Mortgage Services
    Mila, Inc.
    Milestone Mortgage Inc
    Milestone Mortgage Solutions, Inc.
    Milford Federal Savings and Loan Association
    Millenium Home Mortgage LLC
    Millennia Mortgage Corporation
    Millennium Bank N.A./Millennium Capital
    Millennium Financial Group, Inc. dba MLend, Inc.
    Millennium Marketing Co. Inc.
    Millennium Mortgage Corporation
    Millennium Mortgage Services Corporation
    Miller Home Mortgage, LLC
    Miner Kennedy Chmura Associates, Inc.
    Minnesota Lending Co. LLC dba Optimum Mortgage Services
    Minnesota Lending Company, LLc
    Minnesota Valley Federal Credit Union
    Minster Bank
    Mirad Financial Group
    Mission Federal Credit Union
    Missouri Bank & Trust Company of Kansas City
    MIT Federal Credit Union
    MJ Mortgage Services Inc
    MJS Lending, Inc.
    MLD Mortgage Inc.
    MLS Mortgage Group Inc.
    MLS Mortgage Lending Solutions, LLC
    MLSG Inc.
    MMG Inc
    MMW Holdings LLC dba Trident Home Loans
    Mohave State Bank
    Molton, Allen & Williams LLC
    Monarch Bank
    Moncor, Inc.
    Money Forest Mortgage LLC
    Money Warehouse
    Moneylink Mortgage Inc
    MoneyOne Corporation
    Monster Mortgage LLC
    Montana Board of Housing
    Montana First Credit Union
    Montana Mortgage Company
    Montgomery Bank, National Association
    Montgomery Mortgage Capital Corporation
    Montgomery Mortgage, Inc
    Monticello Banking Company
    Monument Bank
    Monument Capital LLC dba Moneytree Mortgage Services LLC
    Monument Mortgage Company, Inc.
    Monument Mortgage, Inc.
    Moore Financial Enterprises, Inc. dba Lenders Diversified
    Moore Mortgage Inc.
    Moran Industries dba Pacific Financial
    More House Mortgage Inc.
    More2Lend Financial
    Moreland Financial Corporation
    MorEquity Inc.
    Morgan Stanley Credit Corp
    Morgan Stanley Mortgage Capital Holdings, Inc
    Morrison Home Funding, LLC
    Mortgage & Investment Consultants
    Mortgage 1 Incorporated
    Mortgage 2000 Inc
    Mortgage Acceptance LLC
    Mortgage America Bankers LLC
    Mortgage America Inc.
    Mortgage and Equity Funding Corp.
    Mortgage Architects Inc. dba Mortgage Architects
    Mortgage Associates Inc
    Mortgage Avenues LLC
    Mortgage Bank of California
    Mortgage Bankers Financial Group, Inc.
    Mortgage Bankers of Wisconsin Inc.
    Mortgage Banking Systems, Inc.
    Mortgage Broker Network Group, LLC
    Mortgage Brokers Service, Inc.
    Mortgage Capital Associates, Inc. A California Corporation
    Mortgage Capital Corporation of America (MCCA)
    Mortgage Capital Group
    Mortgage Center LLC
    Mortgage Central, Inc.
    Mortgage Clearing Corporation
    Mortgage Company of America, LLC
    Mortgage Consultants Group, Inc
    Mortgage Consultants Inc.
    Mortgage Consultants Incorporated
    Mortgage Contracting Services
    Mortgage Corp of Ohio
    Mortgage Corp of the East III
    Mortgage Corporation of America
    Mortgage Corporation of America, Inc.
    Mortgage Counseling Services
    Mortgage Data Management Corp. (MDMC)
    Mortgage Department Services, LLC
    Mortgage Depot, LLC
    Mortgage Direct Inc.
    Mortgage Dynamics Inc (FL)
    Mortgage Edge Corporation
    Mortgage Elite Inc.
    Mortgage Enterprise, Ltd.
    Mortgage Essentials, Inc.
    Mortgage Experts Inc.
    Mortgage Express LLC
    Mortgage Express, Inc.
    Mortgage Factory Inc dba Mortgages Direct
    Mortgage Financial Services
    Mortgage Financial, Inc.
    Mortgage First LLC
    Mortgage Funding Corp
    Mortgage Funding Direct LLC
    Mortgage Group of Wisconsin Inc.
    Mortgage Group Services LLC
    Mortgage Haus Inc.
    Mortgage Headquarters of Missouri, Inc
    Mortgage Horizons LLC dba Mortgage Horizons
    Mortgage Innovations Inc
    Mortgage Investment Services Corporation
    Mortgage Investors Corporation
    Mortgage Investors Group
    Mortgage Lenders Network USA, Inc.
    Mortgage Lenders Network USA.
    Mortgage Lenders of America, LLC
    Mortgage Lenders of Americas and Company Inc.
    Mortgage Lending Consultants, Inc.
    Mortgage Lending Group, Inc. (AZ)
    Mortgage Line Financial Corp.
    Mortgage Loan Solutions LLC
    Mortgage Management Consultants, Inc.
    Mortgage Managers, Inc.
    Mortgage Master Service Corporation
    Mortgage Master, Inc.
    Mortgage Masters of Indiana, Inc
    Mortgage Mentor Inc.
    Mortgage Mobility LLC
    Mortgage Movers, Inc.
    Mortgage Network Inc (KY)
    Mortgage Network Solutions
    Mortgage Network, Inc.
    Mortgage Now Inc.
    Mortgage Now, Inc.
    Mortgage One Group, Inc.
    Mortgage One of North Louisiana LLC
    Mortgage One of the South, Inc.
    Mortgage One Solutions, Inc.
    Mortgage Options of America, Inc.
    Mortgage Outfitters, LLC
    Mortgage Partners
    Mortgage Plan Financial Services, Inc.
    Mortgage Planners LLC
    Mortgage Planners, Inc.
    Mortgage Planners, LLC
    Mortgage Planning & Lending Specialists LTD
    Mortgage Process Center
    Mortgage Professionals, Inc.
    Mortgage Pros LTD
    Mortgage Pros, Inc.
    Mortgage Real Estate Services, Inc. dba Macro Financial Grou
    Mortgage Recovery 1
    Mortgage Research Center LLC dba VAMORTGAGECENTER.COM
    Mortgage Resource Group, Inc.
    Mortgage Resources In The Midwest, Inc.
    Mortgage Resources, Inc.
    Mortgage Revolution, Inc.
    Mortgage Sense, Inc.
    Mortgage Services III, LLC
    Mortgage Servicing Center
    Mortgage Servicing, Inc
    Mortgage Shop LL
    Mortgage Solutions Network Inc DBA Mortgage Solutions Mgmt
    Mortgage Solutions of Central Fl, Inc.
    Mortgage Solutions of Colorado LLC.
    Mortgage Solutions of St. Louis LLC
    Mortgage Solutions Services, LLC
    Mortgage Source LLC
    Mortgage Source, Inc.
    Mortgage Sources Corp
    Mortgage South Financial Services, Inc.
    Mortgage Specialists of Illinois, Inc
    Mortgage Specialists, LLC (NE)
    Mortgage Specialits, LLC
    Mortgage Strategists Incorporated
    Mortgage Superstore, Inc.
    Mortgage Systems, Inc.
    Mortgage Team 1, Inc.
    Mortgage Tree
    Mortgage Trust Group, Inc.
    Mortgage Trust, Inc.
    Mortgage Works Unlimited, Inc. DBA The Mortgage Works
    Mortgage World Bankers, Inc.
    Mortgage Xpress
    MortgageAmerica Associates, Inc.
    MortgageAmerica, Inc.
    MortgageIT, Inc.
    MortgageOne Financial Services Corp
    Mortgages & More, Inc.
    MortgageStream Financial Services, LLC
    MortgageTree Lending
    Motivity Solutions, Inc.
    Mountain 1st Bank & Trust
    Mountain America Credit Union
    Mountain America Fin. Svcs, The Mortgage Co-op & Q Mortgage
    Mountain Crest Mortgage, Inc.
    Mountain Express Mortgage
    Mountain High Federal Credit Union
    Mountain Pacific Mortgage Company
    Mountain Peaks Financial Services
    Mountain Range Funding LLC
    Mountain States Mortgage Centers, Inc.
    Mountain View Mortgage Company, Inc
    Mountain West Bank
    Mountain West Bank, NA
    Mountain West Financial, Inc.
    MountainView Capital Group
    MRG Document Technologies.
    MSA Mortgage, LLC
    MSG-The Mortgage Specialist Group LP
    MSMC Venture, LLC
    Mtg America Corpus ChristiTX dba Mtg Assoc Corpus Christi
    MTG Finance, LLC
    MTH Lending Group, LP
    Multi-State Home Lending, Inc.
    Mutual Mortgage Corporation
    Mutual Mortgage Corporation MI
    Mutual Savings Bank
    Mutual Security Mortgage Ltd
    MV Holdings, LLC dba Global Lending Group
    MVB Mortgage Corp
    My Mortgage Company
    My Mortgage Pro, LLC dba Mortgage Management Group
    My Neighborhood Mortgage Co. LLC dba Neighborhood Mortgage
    My South Lending Group, Inc.
    Myers Park Mortgage, Inc.
    Mylor Financial Group, Inc.
    MyTown Mortgage Corp
    NAD Acquisition 3, LLC
    Nation One Mortgage Co. Inc.
    National Americas Investment Inc.
    National Asset Direct Acquisition LLC
    National Asset Direct, Inc.
    National Bank
    National Bank of Arizona
    National Bank of Arkansas
    National City Bank (KY)
    National City Bank of Indiana
    National City Mortgage, a Division of National City Bank
    National City Mtg Svcs Inc. A Subsidiary of Nat’l City Bank
    National Fidelity Mortgage Corporation
    National Future Mortgage
    National Guaranty Mortgage Corporation
    National Lenders Services Inc
    National Mortgage Network, Inc.
    National Mortgage Network, Inc. DBA Interstate Mortgage Netw
    National Mortgage Options LLC
    National Penn Bank
    Nations Direct Mortgage, LLC
    Nations First Financial, LLC.
    Nations Funding Source, Inc.
    Nations Home Corporation dba First American Lending Corp
    Nations Home Funding
    Nations Home Lending Center
    Nations Home Mortgage Corporation
    Nations Lending Corp
    Nations Mortgage & Investment
    NationsFirst Lending, Inc.
    Nationstar Mortgage LLC
    Nationwide Advantage Mortgage Company
    Nationwide Bank
    Nationwide Equities Corporation
    Nationwide Home Loans Inc
    Nationwide Home Loans.
    Nationwide Home Mortgage Inc. dba Allstate Mortgage Lending
    Nationwide Lending Corporation
    Nationwide Lending Services Inc
    Nationwide Mortgage & Associates Inc
    Nationwide Mortgage Concepts
    Nationwide Mortgage, Inc.
    Nationwide Residential Capital, Inc
    Nationwide Title Clearing, Inc.
    Natixis Real Estate Capital, Inc.
    Nattymac Capital LLC
    Navy Federal Credit Union
    nBank, N.A.
    NBD Bank (Florida) – Non-Member
    NBD Bank (Michigan) NON-MEMBER
    NBD Bank N.A. – NON-MEMBER
    NBGI, Inc.
    NBRS Financial Bank
    NDFC Capital Corp
    NE Moves Mortgage Corporation
    Nebraska Mortgage Co LLC
    Nebraska National Bank
    Neighborhood Funding Inc.
    Neighborhood Housing Services of America
    Neighborhood Housing Services Silicon Valley
    Neighbor’s Financial Corporaton
    Net Rate Mortgage Inc.
    NetCap Financial LLC
    NetCentral Mortgage LLL
    NetMore America, Inc dba Hm Ln Ctr of WA, of OR, of MT, of I
    Network Capital Group, Inc.
    Network Funding, L.P.
    Network Mortgage Services
    Network Mortgage, LLC
    Nevada Federal Credit Union
    Nevada Mortgage Inc.
    Nevis Funding Corp.
    New Age Mortgage Company
    New America Capital, Inc.
    New American Funding
    New American Mortgage LLC
    New Century Financial
    New Century Mortgage Corp, Irvine
    New Day Financial LLC
    New Day Trust Mortgage dba New Day Mortgage
    New England Regional Mortgage Corporation
    New Equity Financial Corp
    New Fed Mortgage Corp
    New Granite Mortgage Corporation dba Granite Mortgage Corp
    New Home Finance LLC
    New Homes Mortgage Inc.
    New Horizon Financial, LTD
    New Horizon Mortgage
    New Horizon Mortgage, Inc
    New Horizon Real Estate Financial Services Inc.
    New Liberty Home Loans
    New Mexico Educators Federal Credit Union
    New Millennium Bank
    New Millennium Mortgage Corporation
    New Penn Financial, LLC
    New Perspective Mortgage, LLC
    New South Federal Savings Bank
    New Vision Residential Lending
    New West Lending, Inc.
    New World Mortgage Inc
    New York Mortgage Funding, LLC
    NewAlliance Bank
    Newcastle Home Loans, LLC
    NewCastle Mortgage Corp
    Newmarket Financial Mortgage Corporation
    Newport Funding Corp.
    NewPrime Home Loans, LLC
    Newwest Funding, A Nevada Corporation
    NexBank SSB
    NextHome Mortgage Corp
    Nexus Financial LLC
    NFS Loans Inc
    NHEL – Citibank as Trustee
    NHSA – JPS
    NJ Lenders Corp.
    NL, Inc. dba RPM Wholesale
    NLMC, Inc.
    Noble Bank & Trust, N.A.
    Nola Lending Group LLC dba Nola Funding Group
    Nomura Credit Capital Inc.
    Norhill Financial Corporation
    Normandy Mortgage Inc.
    Norstar Mortgage LLC
    North Alabama Mortgage Inc.
    North American Banking Company
    North American Savings Bank, fsb
    North Atlantic Mortgage Corporation
    North County Real Estate Inc. dba HMC Funding
    North Dallas Bank & Trust Co.
    North Florida Funding, Inc.
    North Fork Bank
    North Georgia Bank
    North Middlesex Savings Bank
    North Shore Bank
    North Shore Bank of Commerce
    North Shore Bank, FSB
    North Shore Community Bank and Trust
    North Shore Trust &Savings
    North Star Home Lending, LLC
    NorthCountry Federal Credit Union
    Northeast Financial Corporation
    Northeast Mortgage Corporation
    Northern Federal Credit Union
    Northern Mortgage Inc.
    Northern New Mexico Mortgage Co.
    Northern Pacific Mortgage Inc
    Northern Star Bank
    Northern States Funding Group, Inc.
    Northfield Trust Mortgage Company, LLC
    NorthPoint Financial Services, Inc.
    Northpoint Lending Group Inc.
    NorthPoint Mortgage
    Northpoint Mortgage LTD
    Northsight Mortgage Group, LLC
    NorthStar Alliance, Inc.
    Northstar Bank of Texas-Mortgage Division
    NorthStar Mortgage Corp.
    Northstar Mortgage Group LLC
    Northwest Bank
    Northwest Funding Group Inc
    Northwest Lending Group, Inc.
    Northwest Mortgage Group, Inc.
    Northwestern Financial Corporation
    Norwich Commerical Group dba Norcom Mortgage
    Nothnagle Home Securities Corp.
    Nova Home Loans
    NovaStar Certificates Financing Corporation
    Novastar Home Mortgage Inc
    Novastar Mortgage, Inc.
    Novelle Financial Services, Inc.
    Novellus Capital Funding, Inc.
    NP Inc dba US Mortgage of Florida
    NPB Mortgage LLC dba Northpointe Mortgage
    NTFN Inc. dba Premier Nationwide Lending
    Numerica Mortgage LLC
    NVR Mortgage Finance, Inc.
    NW Lending, Inc.
    Oak Bank
    Oak Creek Mortgage, Inc.
    Oak Mortgage Company, L.L.C.
    Oak Mountain Mortgage, LLC
    Oak Street Mortgage LLC
    OakStar Bank, NA
    Oaktree Funding Corporation
    Oakville Capital Inc.
    O’Brien Mortgage Services, Inc.
    Ocala Funding, LLC
    Ocean West Enterprises, Inc.
    OceanFirst Bank
    Oceans Funding Company, Inc.
    Oceanside Mortgage Company
    OCM Mortgage, Inc.
    OCM, Inc. dba
    Ocwen Loan Servicing, LLC
    O’Dowd & Associates Mortgage Co. Inc.
    Odyssey Funding LLC
    OGrady Mortgage, Inc.
    Ohio Capital Alliance Corp
    Ohio Legacy Bank, NA
    Ohio Lending Group
    Old Colonial Mortgage
    Old Oaks Mortgage Inc.
    Old Point Mortgage LLC
    Old Republic Insurance Company
    Old Republic Title Ins. Group
    Old Second National Bank
    Old Town Mortgage, LLC
    Old Towne Financial, Inc.
    Old Virginia Mortgage Inc.
    Olympia Funding Inc.
    Olympia Mortgage Corp.
    Olympia West Mortgage Group, LLC
    Omaha Police Federal Credit Union
    Omega Financial Services Inc.
    Omega Financial Services, Inc.
    Omega Mortgage Company
    Omni Bank
    Omni National Bank
    OmniAmerican Bank
    On Point Mortgage, LLC.
    On Q Financial, Inc.
    On Time Capital
    One Bank and Trust, NA
    One Choice Mortgage, LLC.
    One Community F.C.U.
    One Mortgage LLC dba One Mortgage
    One Mortgage Network, LLC
    One on One Funding
    One Source Mortgage, LLC
    Onestop Financial Services LLC
    Online Financial Group
    Onyx Capital LLC
    Open Mortgage, LLC
    Opes Advisors Inc.
    Opteum Financial Services LLC
    Opteum Financial Services, LLC (Optemac T/F Opteum Mortgage)
    Optima Mortgage Corporation
    Optimax Mortgage Co.
    Optimum Financial Services, Inc.
    Optimum Mortgage Group, LLC
    Optimum Mortgage LLC
    Option Financial LLC
    Option One Mortgage Corporation
    Oregon Coast Bank
    Originate Home Loans, Inc.
    Orion Bank
    Orion Mortgage Corporation
    Orlando Mortgage Company, Inc.
    Ouachita Independent Bank
    Outlook Mortgage, LLC
    Outsource Solutions, Inc.
    Overland Mortgage, LP
    Owen Community Bank, S.B.
    Owl Tree Mortgage Company
    Owner’s Choice Mortgage Services Inc. dba Owner’s Choice Mtg
    Ownit Mortgage Solutions Inc
    OWS I Acquisitions, LLC
    Oxford Capital, LLC
    Oxford Funding Corporation
    Oxford Lending Group, LLC
    Oxford Mortgage, Inc.
    P.T. K. Consulting, Inc. DBA Preferred Mortgage Lenders
    PA Mortgage Service, Inc.
    PA Preferred Mortgage Co.
    Pacesetter Mortgage Company
    Pacific America Group Inc. dba Pacific America Mortgage
    Pacific Coast Lending
    Pacific Coast Mortgage Inc.
    Pacific Community Mortgage, Inc.
    Pacific Continental Mortgage
    Pacific Crest Funding, LLC dba Pacific Crest Home Loans
    Pacific First Financial Services LP
    Pacific Gold Mortgage Group, LLC
    Pacific Horizon Bancorp, Inc.
    Pacific Mercantile Bank
    Pacific Mutual Funding dba Pacific Residential Financing
    Pacific Northwest Mortgage Corporation
    Pacific Northwest Mortgage LLC
    Pacific Residential Mortgage, LLC
    Pacific Reverse Mortgage, Inc.dba Financial Heritage
    Pacific Service Credit Union
    Pacific Union Financial, LLC
    Pacor Mortgage Corp
    PacWest Funding dba PacWest Funding Incorporated
    Pacwest Services, Inc.
    Palladium Mortgage Corporation
    Palm Beach Atlantic Lending LLC
    Palm Beach Mortgage Group Inc.
    Palmetto South Mortgage Corp.
    Palos Bank & Trust Company
    Panhandle State Bank
    Paradigm Mortgage Corporation
    Paradise Financial Group, Inc.
    Paragon Home Lending, LLC
    Paragon Mortgage Bankers Corp.
    Paragon Mortgage Consultants, Inc.
    Paragon Mortgage Services Inc.
    Paragon National Bank
    Paramount Bond & Mortgage Company
    Paramount Equity Mortgage, Inc.
    Paramount Home Loans, Inc
    Paramount Lending, LLC
    Paramount Mortgage Professionals on NC, Inc
    Paramount Mortgage, Inc.
    Paramount Residential Mortgage Group, Inc.
    Park National Bank
    Park Place Finance, LLC
    Park Place Mortgage, LLC
    Park Shore Mortgage Corp
    Park West Corporation
    Parkside Lending, LLC
    Parkway Bank
    Partners for Payment Relief, LLC
    Partners Mortgage dba Partners Capital Mortgage
    Partners Mortgage, Inc.
    Pathfinder Mortgage Group, Inc.
    Pathway Financial, LLC
    Patriot Bank
    Patriot Bank FL
    Patriot Bank Mortgage Inc. a Division of Patriot Bank
    Patriot Federal Credit Union
    Patriot Funding LLC
    Patriot Lending Group, Inc
    Patriot Lending Services, Inc.
    Patriot Mortgage Bankers of North America LTD
    Patriot Mortgage Company Inc
    Patriot Mortgage Services Inc.
    Patriots Bank
    Patroit One Mortgage Bankers LLC
    Patuxent Funding LLC
    Paul E Smith dba Main Street Mortgage Company
    PB Reit, Inc.
    PCFS Financial Services, Inc.
    Pellow Mortgage Company LLC
    Pemm. Tek Mortgage Services, LLC
    Penn 1st Financial Services Inc
    Penn Liberty Bank
    Pennie L. Carey dba Worldwide Home Lending
    Pennwest Home Equity Services Corp
    PennyMac Loan Services, LLC
    Pentagon Mortgage LLC
    People Bank – WA
    Peoples Bank
    Peoples Bank of Commerce
    People’s Bank of Commerce
    Peoples Bank of KY, Inc
    Peoples Bank, N.A.
    People’s Choice Funding, Inc
    Peoples Choice Home Loan Inc
    People’s Choice Mortgage Company
    Peoples Choice Mortgage LLC
    Peoples Exchange Bank
    Peoples Independent Bank
    Peoples Mortgage Company
    People’s Mortgage Corporation
    Peoples Mortgage, Inc.
    Peoples National Bank, N.A.
    Peoples Savings Bank dba Peoples Mortgage Company
    Peoples State Bank of Comm dba RHR Mortgage of America, LLC
    People’s State Bank of Wyalusing, PA
    People’s United Bank
    PeoplesBank, A Codorus Valley Company
    Performance Financial Inc dba Pacific Funding & Mort Advisor
    Performance Lending, Inc
    Perimeter Mortgage Funding Corporation
    Perl Mortgage, Inc.
    Personal Home Mortgage Services, Inc.
    PFagan Mortgage, Inc.
    PFG Mortgage Trust I
    PFG Mortgage Trust II
    PFL, Inc.
    PGNF Home Lending Corporation
    PHH Mortgage Corporation
    Philadelphia Mortgage Advisors Inc.
    Philip R. Marsh
    Phoenix Funding Corporation
    Phoenix Mortgage Corporation
    Phoenix Rising Brokers Conduit dba
    Pierce Commercial Bank
    Pike Creek Mortgage Services Inc
    Pillar Financial LLC
    Pillar Mortgage Services Corporation
    Pine River Valley Bank
    Pine State Mortgage Corp.
    Pinellas Mortgage Services, Inc.
    Pinnacle Bank
    Pinnacle Capital Mortgage Corporation
    Pinnacle Financial Corporation
    Pinnacle Financial Corporation of Michigan
    Pinnacle Financial Services, Inc.
    Pinnacle Financial Solutions
    Pinnacle Home Mortgage Co.
    Pinnacle Lending Group
    Pinnacle Mortgage Funding LLC
    Pinnacle Mortgage Group, Inc.
    Pinnacle Mortgage, Inc
    Pinnacle National Bank
    Pinta, LLC
    Pintola Inc. dba Town and Country Mortgages
    Pioneer Financial Services, Inc.
    Pioneer Mortgage, Inc. #40319
    Pirimar Industries Inc. dba Pirimar Home Loans
    Plains Commerce Bank
    Planters Bank Inc
    Planters First
    Platinum 1 Mortgage Services, LLC
    Platinum Capital Group
    Platinum Community Bank
    Platinum Community Bank dba Platinum Direct Funding
    Platinum HomeMortgage Corporation
    Platinum Mortgage Group, LLC
    Platinum Mortgage Inc.
    Platte River Mortgate and Investments Inc
    Platte Valley Bank of Missouri
    Plaza Home Mortgage, Inc.
    Plaza Mortgage Group Inc.
    PLB Lending, LLC
    PLN Associates Inc
    PMAC Lending Services Inc
    PMC BanCorp.
    PMI Mortgage Insurance Company
    PNC Bank N.A.
    PNC Consumer Services
    PNC Mortgage, LLC
    PNCMT Trust Series 2000-1, Bank One as Trustee
    PNMAC Mortgage Co., LLC
    PNMAC Mortgage Opportunity Fund Investors, LLC
    Point Independent Mortgage
    Point Mortgage Corp.
    Point Plus Credit Union
    Polaris Home Funding Corporation
    Poli Mortgage Group Inc.
    Pope Mortgage & Associates
    Popular Mortgage
    Popular Mortgage Servicing, Inc
    Positive Mortgage, Inc
    Potelco United Credit Union
    Potomac Mortgage Capital Inc.
    Poulsen Mortgage Corporation
    Powder House Mortgage Company, Inc.
    Power Financial Corporation
    PPI Equities, Inc. dba Pacific Mortgage
    Prairie Community Bank
    Prajna Group Inc. dba Liberty Mortgage Funding
    Precision Financial, Inc.
    Precision Funding
    Precision Funding Group LLC
    Preferred Financial Funding, Inc.
    Preferred Financial Grp Inc dba Preferred Mortgage Services
    Preferred Financial Services Inc.
    Preferred Home Lending LLC
    Preferred Home Loan LTD
    Preferred Home Mortgage Company
    Preferred Mortgage, Inc
    Prem Mortgage, Inc. DBA First United Mortgage
    Premier Atlanta Mortgage Company
    Premier Bank
    Premier Bank – Dubuque
    Premier Bank (MO)
    Premier Bank Minnesota
    Premier Bank Rochester
    Premier Banks
    Premier Community Bank of the Emerald Coast
    Premier Financial Correspondent Inc.
    Premier Financial Services, Inc.
    Premier Holdings LC dba Premier Mortgage
    Premier Home Lending Inc.
    Premier Home Lending, Inc. (FL)
    Premier Home Mortgage LLC dba PHM, LLC (Nebraska only)
    Premier Lending Solutions LLC
    Premier Mortgage Capital Inc.
    Premier Mortgage Funding, Inc.
    Premier Mortgage Group of South Florida
    Premier Mortgage Group, Inc.
    Premier Mortgage Inc
    Premier Mortgage Resources LLC dba Premier Mortgage Resource
    Premier Mortgage Services Inc.
    Premier Mortgage Services, Inc.
    Premier Mortgage Services, LLC
    Premiere Mortgage, Inc.
    Premium Capital Funding LLC
    Premium Mortgage
    Premium Trust Mortgage Corp
    Presidential Bank, FSB
    Prestige Funding Solutions LLC dba Distinct Funding Solution
    Prestige Mortgage, LLC
    Prestige Mtg.
    Prestonwood Mortgage L.P
    Priceline Mortgage Company LOC
    Pride Mortgage LLP
    Primary Capital Advisors LC
    Primary Funding Group, a dba of Pro-Buy Equities Corp
    Primary Mortgage Corporation
    Primary Residential Mortgage
    Primary Residential Mortgage (2)
    Prime Axia Financial, Inc.
    Prime Capital Group, LLC
    Prime Capital, Inc.
    Prime Equity Access Corporation
    Prime Financial Corporation
    Prime Max Mortage, LLC
    Prime Mortgage Financial, Inc.
    Prime Mortgage, a division of the Business Bank
    Prime Residential Funding, LLC
    Prime Shop, Inc.
    Prime Source Funding Inc.
    PrimeLending, a Plains Capital Company
    Primequity LLC
    PrimeWest Mortgage Corporation
    Primrose Mortgage Co. Inc., dba First PrimSouth Mortgage
    Primus Lending Corp.
    Princeton Financial, LLC
    Princeton Mortgage Corporation
    Principal Bank
    Principal Mortgage, LLC
    Priority Bank
    Priority Financial, Inc. dba Priority Funding
    Priority Mortgage Corp
    Private Capital Group LLC
    PRMI 011
    PRMI 018
    Pro Mortgages LLC
    Proctor Properties dba 1st Southwest Security Mortgage
    Prodigy, Inc
    Prodovis Mortgage
    Production Mortgage, Inc.
    Professional Advantage Financial Group., Inc.
    Professional Consolidated Financial Goup, Inc.
    Professional Lending, LLC
    Professional Mortgage Bankers Corp.
    Professional Mortgage Centers
    Professional Mortgage Group, Inc.
    Professional Mortgage Partners, Inc.
    Professional Mortgage Service, Inc.
    Professional Mortgage Services of WNC, Inc.
    Professional Mortgage Solutions Inc
    Professional Mortgage, Inc.
    Proficio Mortgage Ventures, LLC
    Profolio Home Mortgage Corp
    Progress Bank & Trust
    Progressive Lending LLC
    Progressive Mortgage Group, Inc
    Progressive Mortgage Inc. dba Key Mortgage
    Progressive Mortgage Services LLC dba A&M Mortgage Group Inc
    ProLender Solutions, Inc.
    ProLending Mortgage, LLC
    Properties, Etc., Inc dba Rescomm Financial
    Property Network, Inc. dba Property & Mortgage Network, Inc.
    Prospect Financial Services, LLC
    Prosperan Bank
    Prosperity Bank
    Prosperity Bank (TX)
    Prosperity Mortgage Company
    ProtoFund Mortgage Corporation
    Providence Mortgage Company
    Providence Postal Federal Credit Union
    Provident Asset Management, L.P.
    Provident Credit Union
    Provident Funding Associates, LP
    Provident Mortgage Corporation
    Provident Mortgage Corporation, A Calif. Corp.
    Provident Savings Bank, F.S.B.
    Providential Bancorp LTD dba Providential Mortgage Co.
    Province Bank, FSB
    Provincial Bank
    ProviNet Mortgage Corporation, Inc.
    PRS, LLC DBA The Mortgage Link
    Prudential Lending Inc. DBA PLI Capital
    Prudential Mortgage Services, LLC
    Prysma Lending Group, LLC
    PTF Financial Corp
    Public Savings Bank
    Public Trust Mortgage Corp.
    Pulaski Bank (Pulaski Service Corp)
    Pulaski Mortgage Company
    Pulse Funding, Inc.
    Pulte Mortgage LLC
    Q Financial Direct Inc
    QLending, Inc.
    QMC Holdings Inc.
    QR Lending, Inc.
    Quad City Bank and Trust Company
    Qualita Financial Group, Inc
    Quality Home Loans
    Quality One Mortgage, Inc.
    Quantum Leap Mortgage Corp dba Supreme Lending Services
    Quantum Servicing Corporation
    Queensborough National Bank and Trust Company
    Quick Loan Funding Inc.
    Quick Mortgage Services, LLC
    Quick Mortgage, LLC
    Quickdraw Real Estate Service dba Homestar Lending
    Quicken Loans, Inc.
    R.O.C. Financial, Inc.
    R.W. Allen Financial
    Rabobank N A
    Radian Guaranty Inc.
    Radius Financial Group Inc.
    Rancho Financial Inc.
    Randall Mortgage Services, Inc.
    Rapid Mortgage Co., Inc.
    Rasmussen Mortgage Inc. dba Rasmussen Mortgage Specialists
    Rate One Inc The Mortgage People
    Raven Financial Services LLC
    Raymond James Bank FSB
    RBC Bank (USA)
    RBC Mortgage Company
    RBS Citizens, N.A.
    Real Estate Financial Services, Inc
    Real Estate Lending Group
    Real Estate Mortgage Corp.
    Real Estate Mortgage Network LLC
    Real Estate Mortgage Network, Inc
    Real Estate Mortgage Network, Inc.
    Real Mortgage Partners, Inc.
    Real Time Resolutions, Inc.
    RealPros, LLC dba RealPros Mortgage LLC
    Realty Funding Corporation
    Realty Home Mortgage Associates, LLC
    Realty Home Mortgage Co., LLC
    Realty Mortgage – Home Office
    Realty Plus Mortgage
    Recorder of Deeds of Lancaster County
    Red Mountain Bank, N.A.
    Red River Bank
    Red Rocks Federal Credit Union
    Redmond Mortgage Company Inc
    Redwood Trust, Inc.
    Reed & Associates Mortgage Corp.
    Referral Marketing Inc. dba Referral Mortgage
    Refund Realty & Mortgage LLC
    Regency Lending Services
    Regency Mortgage Corporation
    Regent Bank
    Regent Mortgage Funding LLC
    Regions Mortgage
    Reliance Bank
    Reliance First Capital, LLC
    Reliance Plus Mortgage Co. L.P. dba Reliance Mortgage Co.
    Reliance Preferred Funding Corp
    Reliant Mortgage Company, LLC.
    Renaissance Mortgage Corporation
    Renaissance Mortgage Group, Inc.
    Renasant Bank
    Renew Investment Co dba Columbine Mortgage
    Republic Bank
    Republic Bank & Trust
    Republic Mortgage Home Loans, LLC
    Republic Northwest, LLC
    Republic State Mortgage Co.
    Rescomm Holdings No. 2 LLC
    Rescue Mortgage Inc
    Reserve Mortgage Investments, LLC
    ResFund LLC
    Residence Lending, LLC
    Residential Acceptance Corporation
    Residential Acceptance Network, Inc.
    Residential Bancorp
    Residential Capital Mortgage Corporation
    Residential Credit Solutions
    Residential Finance Corp.
    Residential Funding Company, LLC
    Residential Home Funding Corp.
    Residential Home Funding Corporation
    Residential Home Loan Center LLC
    Residential Home Mortgage Corporation
    Residential Lending Corporation
    Residential Lending Network Inc
    Residential Lending Services, Inc
    Residential Lending, LLC
    Residential Loan Centers of America, Inc.
    Residential Mortgage Advisors LLC
    Residential Mortgage Associates, Inc. dba RMA Lending
    Residential Mortgage Capital
    Residential Mortgage Center Inc.
    Residential Mortgage Corp.
    Residential Mortgage Corporation
    Residential Mortgage Funding, Inc.
    Residential Mortgage Group, a division of Inter Savings Bank
    Residential Mortgage Network, Inc
    Residential Mortgage Services Inc
    Residential Mortgage Solution LLC
    Residential Mortgage Solutions
    Residential Mortgage, LLC
    Residential Mtg. Group, Inc.
    Residential Wholesale Mortgage, Inc.
    ResMAE Mortgage Corporation
    Resolutions Capital, LP
    Resource Financial Services, Inc
    Resource Lenders, Inc.
    Resource Mortgage Corporation
    Resource One Credit Union
    Resource One, Inc.
    Response Mortgage Services Inc.
    Resurgent Capital Services
    Reunion Mortgage, Inc.
    Reverse Mortgage Solutions, Inc.
    Revolutionary Mortgage Company
    RFC Trustee 01
    RFC Trustee 02
    RFC Trustee 03
    RFC Trustee 04
    RFC Trustee 05
    RH Lending, Inc. d/b/a Residential Home Lending
    Rhodes Financial Services Mortgage LLC dba Rhodes Fin’l Mtg
    Rhome Asset Management Corporation
    Ribble Real Estate LLC
    Richland Federal Credit Union
    Richland Mortgage Company, LLC
    Ridge Mortgage Services Inc.
    Ridgeview Mortgage Associates, Inc.
    Riggs Real Estate Investment Corporation
    Right-Away Mortgage, Inc
    Rimrock Credit Union
    Risk Management Group, LLC dba RMG
    River Bank & Trust
    River City Mortgage & Financial, LLC
    River Funding Corporation dba River Home Lending
    River Mortgage, LLC
    River Region Credit Union
    Riverbend Bank dba Riverbend Mortgage
    Riverbend Mortgage Inc
    Riverside Bank of the Gulf Coast
    Riverside Mortgage Company LLC
    Riverside Mortgage Company, Inc.
    Riverside Mortgage Corp.
    Riverside National Bank of Florida
    Riverview Community Bank
    Rivoli Mortgage
    RJ Commercial Funding, Inc. dba Gateway Mortgage
    RKS Financial Services, Inc
    RMA Lending, LLC
    RMC Vanguard Mortgage Corp.
    RMK Financial Corp dba Majestic Home Loan
    RMR Financial LLC d/b/a Princeton Capital
    RMS & Associates
    RNB Inc. dba Cornerstone Mortgage Company
    Robertson & Anschultz
    Rochester Home Equity, Inc
    Rockaway Beach Financial
    Rockwood Bank
    Rocky Mountain Bank
    Rocky Mountain Bank (MT)
    Rocky Mountain Credit Union
    Rocky Mountain Mortgage Group, LLC
    Rocky Mountain Mortgage Specialist, Inc.
    Rocky Mountian Mortgage Co.
    Rogue Federal Credit Union
    Rolwes Mortgage Co. LLC
    Rose Rock Bank, a Division of Union Bank
    Ross Mortgage Company, Inc.
    Ross Mortgage Corporation
    RoundPoint Mortgage Servicing Corp.
    Royal Credit Industries, Inc.
    Royal Mortgage Company, Inc.
    Royal Pacific Funding Corp dba Pacific Banc
    RP Funding, Inc
    RPM Mortgage, Inc
    RSR Home Loan Corporation
    RTR Capital LP
    Rubiola Mortgage Company, Inc.
    Ryan Mortgage Co
    Ryland Mortgage Company
    S&L Investment Lending dba JC Mortgage
    S&T Bank
    S.M. Neider Mortgage Consultants, Inc.
    S.W.I Financial Services, Inc. dba Integrity 1st Mortgage
    S/C Financial LLC dba Quest Mortgage Consultants
    Saab Financial Corporation dba Saab Mortgage
    Sabal Palm Bank
    Sacramento Credit Union
    Sacramento Valley Mortgage Corp. dba Greater Valley Mortgage
    Saddlebred Capital Mortgage, LLC
    Safeguard Properties
    Safeguard Properties Inc.
    Sagamore Home Mortgage, LLC
    Sahara Mortgage Corporation
    Sajomi Holdings Corporation DBA Lenders Residential Mortgage
    Sallie Mae Home Loans
    Sam Houston Mortgage Co., Inc.
    San Angelo National Bank
    San Antonio Mortgage Company, LLC
    San Diego Funding
    San Jacinto Mortgage Inc dba Mtg. Spec. of Greater Houston
    San Luis Capital, Inc.
    Sanborn Mortgage Corp.
    Sandhills Bank
    Sandy Spring Bank
    Santa Cruz Home Finance
    Santa Cruz Mortgage Company
    SASCO 1999 AL2/US Bank NA
    SASCO 1999 SP1/FNB Chicago
    SASCO 2000 ARC-BC3
    SASCO 2000-3
    SASCO 2000-4
    SASCO 2000-RF1
    SASCO 2001-1
    SASCO ARC 2001-BC2
    SASCO1999ALS-1/Chase Manhattan Bank
    Saugus Federal Credit Union
    Savage Mortgage Services LLC
    Savi Ranch Financial Inc. dba Western Pacific Financial Inc.
    Savings First Mortgage LLC
    Sawgrass Funding LLC
    Saxon Equity Mortgage Bankers, Ltd.
    Saxon MortgageServices, Inc.
    SBMC Mortgage
    SBW Management, LLC dba Capital Home Loans
    SCBT, N.A.
    SCD Recovery, LLC
    Schaefer Mortgage Corp.
    Schmidt Mortgage Company
    Schmitt Mortgage, LLC
    Scholastic Mortgage LLC
    Schyndel Investments, Inc.
    SCME Mortgage Bankers, Inc.
    Scott Financial LLC dba Des Peres Mortgage LLC
    SDK Real Estate Funding LLC dba Allied Banc Mtg/Allied Mtg L
    Sea Financial Group, Inc.
    Seabreeze Financial Services, Inc.
    Seacoast National Bank
    Seattle Bank
    Seattle Pacific Mortgage, Inc.
    Sebring Capital Partners, Limited Partnership
    Sebring Capital Partners, LP (Subprime Div.)
    Secure Lending Solutions, Inc.
    Secured Funding Corp
    Security Atlantic Mortgage Co., Inc.
    Security Bank of Kansas City
    Security Federal Bank
    Security Federal Mortgage Corp.
    Security First Bank
    Security First Mortgage, Inc.
    Security Home Mortgage LLC
    Security Lending Wholesale
    Security Mortgage Corporation
    Security Mortgage Corporation (MI)
    Security Mortgage Funding Corporation
    Security Mortgage, Inc.
    Security National Life Insurance Company
    Security National Mortgage Company
    Security National Partners Limited Partnership
    Security One Mortgage
    Security Real Estate Services, Inc.
    Security Savings Bank, FSB
    Security Service Federal Credit Union
    Security State Bank
    Security State Savings Bank
    Select Fnancial Services Inc dba McColly Mortgage
    Select Mortgage
    Select Mortgage Corporation
    Select Mortgage Group Ltd.
    Select Portfolio Servicing Inc
    Selene Finance LP
    Selene RMOF BOA 063008 LLC
    Selene RMOF Loan Acquisition LLC
    Self Help Ventures Fund
    Selleck Mortgage Group, Inc.
    Sellers Financial Group, Inc. dba Sellers Mortgage Corp
    Seminole Moneytree Inc.
    Senderra Funding
    Sente Mortgage Corporation
    Sentinel Home Mortgage LLLP
    Sentinel Mortgage Co.
    Serramonte Mortgage Company, Inc. dba SMC Bancorp
    Service First Mortgage Corp.
    Service First Mortgage dba Trans-Act Mortgage
    Service Mortgage Underwriters, Inc.
    Servis First Bank
    Seven Seventeen Credit Union
    Severn Mortgage Corporation
    Severn Savings Bank, FSB
    SFF Mortgage, Inc. DBA Security First Financial
    SFG Bancorp
    SFJV 2005, LLC
    Shamrock Bank of Florida
    Shamrock Financial Corporation
    Shamrock Mortgage Inc.
    Share Plus Federal Bank
    Sharp Mortgages, Inc.
    Shasta Financial Services, Inc. dba First Capital
    Shea Mortgage – Corporate Office
    Shearson Home Loans
    Shelby State Bank
    Shelly K Hulse dba Shell Mortgage
    Shelter Mortgage Inc.
    Shelton Mortgage Group, LLC
    Sher Financial Group, Inc. dba Citizens Lending Group, Inc.
    Sherwood Mortgage Group, Inc.
    Shore Mortgage
    SI Mortgage Company
    Sibcy Cline Mortgage
    Sids Mortgage Inc dba Alliance Financial Mtg.
    Sidus Financial Corporation (NC)
    Sidus Financial Corporation (VA)
    Sidus Financial LLC (SC)
    Sidus Financial, LLC – New England Regional Office
    Sierra Financial Mortgage, LLC
    Sierra Home Loans, LLC
    Sierra Pacific Home Loans, Inc.
    Sierra Pacific Mortgage Company, Inc.
    Sierra Star Financial, LLC
    Sigmund Financial Group Inc.
    Signature Bank
    Signature Bank of Arkansas
    Signature Lending Group, Inc.
    Signature Mortgage Corporation
    Signature Mortgage, L.L.C.
    Signia Docs, Inc.
    Silver Mortgage Bancorp, Inc.
    Silver Oak Mortgage, LP
    Silver State Bank
    Silver State Financial Services, Inc. dba Silver State
    Silvergate Bank
    Silverstone Mortgage Group, LLC
    Silverton Mortgage Specialists, Inc.
    Simmons First National Bank
    Simonich Corporation dba BWC Mortgage Services, Inc.
    Sioux Falls Federal Credit Union
    SIRVA Mortgage
    Sisters Contract Mortgage Solutions Inc
    SIU Credit Union
    SK & Associates LLC dba Desert Sun Mortgage
    Skofed Mortgage Funding Corporation
    Sky Capital Mortgage, LLC
    Sky Federal Credit Union
    Sky Investments Inc. dba North Star Lending
    Skyline Funding
    Skyline Mortgage Company
    Skyline Mortgage LLC
    Slavie Federal Savings Bank
    SLM Financial Corporation
    Smart Choice Loan Center, Inc
    Smart Wholesale Lending, Inc
    SMI Lending, Inc
    SMI Residential Mortgage, Inc.
    SN Servicing Corp.
    SNMLT 2001-2
    Sno-King Mortgage Inc.
    Societe Generale dba SG Mortgage Finance Corp
    Sofin, Inc
    Solace Financial LLC
    Solstice Capital Group, Inc. dba Loanbus
    SoluBanc Funding, Inc.
    Solution One Mortgage
    Solutions Bank
    Solutions Funding, Inc.
    Solutions Lending LLC
    SolVerus Banc Incorporated
    SOMA Financial
    Somerset Investors Corp dba Somerset Mortgage Bankers
    Sonterra Mortgage Capital, LLC
    Sophia Ventures, Inc dba Elite Lending
    Sotheby’s/Lehman Mortgage Services, LLC
    Sound Mortgage, Inc.
    Source Mortgage Corporation
    Source Mortgage, LLC
    Source One Mortgage Corporation
    South Central Bank of Barren County, Inc.
    South Chase Mortgage Corporation
    South County Bank
    South Lakes Mortgage Bankers, Inc.
    South Pacific Financial d/b/a Funding Solutions Bancorp
    South Shore Financial Services, Inc.
    South Valley Bank & Trust
    South Wind Tours & Excursions
    Southcoast Community Bank
    Southeast Bankers Mortgage Corp
    Southeast Funding Alliance Inc.
    Southeast Mortgage of Georgia
    Southeast TX Equity Mgmt Inc dba Acq Funding or Home 1st Mtg
    Southeastern Mortgage Corp.
    Southern Equity Mortgage Services, LLC
    Southern Fidelity Mortgage LLC
    Southern Highlands Mortgage LLC
    Southern Home Lending Corp
    Southern Horizon Financial Group LLC
    Southern Missouri Bank of Marshfield
    Southern Mortgage Associates
    Southern Mortgage Brokers Inc.
    Southern Mortgage Co. of Central LA
    Southern Mortgage Source, Inc
    Southern Star Mortgage Corp
    Southern Trust Mortgage, LLC
    SouthFirst Bank
    SouthPoint Bank
    Southpoint Financial Services, Inc.
    Southside Bank
    SouthStar Funding, LLC
    SouthTrust Mortgage Corporation
    Southwest Funding, L.P.
    SouthWest Missouri Bank
    Southwest Mortgage Corp.
    Southwest Mortgage Partners
    Southwest Securities FSB (warehouse)
    Southwest Securities, FSB
    Southwest Stage Funding, LLC dba Cascade Financial Services
    Southwood Mortgage Co.
    Sovereign Bank
    Sovereign Bank (PA)
    Sovereign Bank (TX)
    Sovereign Bank/NATCO
    Sovereign Bank-Capital Markets (Newton)
    Special Project RFC
    Specialized Loan Servicing, LLC
    Specialty Mortgage Corporation
    Spectra Financial Inc.
    Spectra Funding, Inc.
    Spectrum Financial Group
    Spectrum Funding Corp
    Spectrum-Hale Partners, LLC dba Hale Financial Partners
    Spire Federal Credit Union
    Spirit Bank
    Spurr Mortgage Corporation
    SRI dba SRI Mortgage, SRI Wholesale, SRI Lending
    ST Fin Corp dba Star Financial
    St George Mortgage Inc
    St Louis Federal Mortgage Co.
    St. Francisville, LLC
    St. Louis Bank
    St. Louis Mortgage Connections Inc.
    Stagecoach Mortgage, LLC
    Standard Bank and Trust
    Standard Equity Funding
    Standard Mortgage Corp
    Standard Pacific Mortgage, Inc.
    Stanford Federal Credit Union
    Stanley Capital Mortgage Company, Inc.
    Star Funding, Inc
    Starwood Vacation Ownership Inc.
    Starwood Vacation Ownership Portfolio Services, Inc.
    State Bank
    State Bank of Delano
    State Bank of Southwest Missouri
    State Central Credit Union
    State Farm Bank FSB
    State Highway Patrol Federal Credit Union
    State Lending Corporation
    State Mortgage LLC
    State of New York Mortgage Agency (SONYMA)
    Statewide Bank
    Statewide Bank (Correspondent
    Statewide Financial Group, Inc.
    Statewide Lending, Inc.
    Stearns Bank N.A.
    Stearns Lending Inc., A California Corporation
    Steel Mountain Capital, Inc and Its Wholly Owned Purchasing
    Stellarone Bank
    Steller Mortgage Corporation dba Freedom Financial
    Stenton Mortgage Inc
    Stephen H. Robin dba HMC Enterprises
    Stephen W. Head dba Texas Premier Mortgage
    Stepstone Mortgage Company, Inc.
    Sterling Asset & Equity Corp
    Sterling Bank
    Sterling Bank & Trust, FSB
    Sterling Capital Mortgage
    Sterling Coast to Coast Financial Group, Inc.
    Sterling Eagle Mortgage Investment Company, LLC
    Sterling Empire Funding Association, LTD
    Sterling Home Mortgage Corporation
    Sterling Home Mortgage, LLC
    Sterling Mortgage and Financial Services, Inc.
    Sterling Mortgage Corporation
    Sterling Mortgage Services of the Treasure Coast, Inc
    Sterling National Mortgage Company, Inc.
    Sterling State Bank
    Stewart Financial Enterprises Inc dba City Fund Mort Lending
    Stewart Mortgage Information Services
    Stewart Mortgage Services, Inc.
    Stewart Title of Northern New England, Inc.
    Stifel Bank & Trust
    Stillwater Mortgage, LLC dba Turnbury Mortgage
    Stirling II Corporation dba Stirling Mortgage
    Stock Financial, LLC
    Stock Yards Bank & Trust Company
    Stockman Bank of Montana
    Stockton Mortgage Corporation
    Stockton Turner LLC
    Stoffer Mortgage Inc.
    Stone Creek Capital Mortgage
    Stone Mortgage Corporation
    Stonebrook Mortgage Corporation
    Stonebrook Mortgage Services, Inc.
    Stonecreek Funding Corporation
    Stonegate Mortgage Corporation
    StonehamBank-A Cooperative Bank
    Stonetrust MortgageLending LLC
    StoneWater Mortgage Corporation
    Straight Line Mortgage, Inc.
    Strait Financial Corporation
    Strata Bank
    Strategic Capital Mortgage, Inc.
    Strategic Lending, Inc.
    Strategic Mortgage Company
    Stratus Mortgage, LLC
    Streeter Brothers Mortgage Corp.
    Stronghold Funding LLC dba Stronghold
    Structure Mortgage Inc.
    Suburban Federal Savings Bank
    Suburban Mortgage Company of New Mexico
    Suburban Mortgage Inc.
    Success Investments, Inc.
    Success Mortgage Partners, Inc
    Sullivan Financial Services, Inc.
    Summatyme LLC
    Summit Bank
    Summit Bank, Tulsa
    Summit Credit Union
    Summit Credit Union (WI)
    Summit Financial LLC
    Summit Funding Inc
    Summit Investments Loan Corp dba Loanisland
    Summit Lending Group, Inc.
    Summit Lending Solutions Inc
    Summit Mortgage Bankers, Inc.
    Summit Mortgage Corp. IL
    Summit Mortgage Corporation
    Summit Mortgage Corporation LLC
    Summit Mortgage Corporation TX
    Summit Mortgage Inc
    Sun American Mortgage Company
    Sun Capital Inc
    Sun Home Loans, Inc.
    Sun Quest Funding LLC
    Sun Valley Mortgage Services LLC
    Sun Vista Mortgage Services Ltd Co
    Sun West Mortgage Company, Inc.
    Sunbelt Lending Services
    Sunbelt Mortgage, LLC
    Suncoast Financial, Inc.
    Suncoast Mortgage Bankers Inc
    Suncoast Mortgage Corporation
    Suncoast Mortgage Group, LLC
    SunFirst Bank
    Sunflower Bank N.A.
    Sunlending Mortgage Corporation
    Sunmark Federal Credit Union
    Sunrise Financial Services, Inc.
    Sunset Bank & Savings
    Sunset Direct Lending
    Sunset Financial Resource Inc.
    Sunset Mortgage & Investment Corp.
    Sunset Mortgage Co.
    Sunset Mortgage Company, LP
    Sunset Portfolio Servicing Company, LLC.
    Sunset West Mortgage, Inc.
    Sunshine Financial Group, Inc.
    Sunshine Mortgage
    Sunstreet Mortgage, LLC
    SunTrust Mortgage, Inc.
    Sunwest Bank
    SunWest Mortgage, LLC
    Superior Bank
    Superior Lending Corp.
    Superior Lending Mortgage Inc
    Superior Mortgage and Equity Corp.
    Superior Mortgage Corporation
    Superior Mortgage LLC
    Superior Mortgage Services LLC
    Supreme Funding Corporation
    Surecredit USA Home Loans, Inc.
    Susquehanna Bank
    Susquehanna Mortgage Corporation
    Sussex Group, Inc.
    Sutton Bank
    SVO 2008-A VOI Mortgage Corp.
    Swan Investments Intl., Inc. dba International Mortgage
    SWBC Mortgage Corporation
    Sweetwater Home Fin. of Houston, Inc. dba Sweetwater Mtg Co
    Swinford Capital Corp.
    Sycamore Funding Inc.
    Sydion Financial LLC
    Symmetry Mortgage Corp
    Synergy Capital Mortgage Corporation
    Synergy Home Loans, LLC
    Synergy Mortgage Group, Inc.
    Synergy One Financial Services, LLC
    Synovus Mortgage Corp.
    Syracuse Securities Inc
    Syringa Bank
    T.D. Service Company
    T.J. Financial, Inc.
    T.R. Hughes Home Mortgage Co. LLC
    Tahoe Executive Enterprises, Inc dba Paragon Mortgage Serv
    Tamayo Financial Services, Inc.
    Tartak Mortgage LLC
    Tarzana Capital
    Taylor Morgan Inc dba Community Lending Services
    Taylor, Bean & Whitaker Mortgage Corp.
    TBI Mortgage Company
    TBS Financial Services Inc. dba Lenders Mortgage Services
    TC Preferred Funding Inc.
    TCD Mortgage Corporation
    TD Bank, N.A. – Commerce Bank
    TD Banknorth NA
    TDA Capital Group, LLC DBA Atlas Capital Mortgage
    Team Lending Concepts, LLC
    Team Mortgage, LLC
    Team USA Mortgage, LLC
    TeamBank N.A.
    Technology Credit Union
    Telemetry Mortgage Opportunities Fund, L.P.
    Telesis Community Credit Union
    Telhio Credit Union
    Tenacity Mortgage
    Tennessee Bank and Trust, A Div. of Farmers Bank & Trust Co.
    Tennessee State Bank
    Tennessee Valley Mortgage of Florence LLC
    Terrace Mortgage Company
    Terwin Advisors, LLC dba The Winter Group
    Texas Bank and Trust Company
    Texas BRV, Inc. dba Blue Apple Mortgage
    Texas Capital Bank, N.A.
    Texas Commercial Funding Group LLC
    Texas First Family Mortgage Inc.
    Texas Heritage Mortgage, LTD.
    Texas Loan Star, Inc.
    Texas Mortgage Professionals, LLC
    Texas Mortgage Team LLC
    Texas Security Bank
    Texas Western Mortgage, LLC
    The Addison Mortgage Group, Inc.
    The Advantage Mortgage Group,Inc
    The American Eagle Mortgage Corp.
    The American National Bank of Dekalb County’s Mortgage Div.
    The Anderson Financial Group, Inc.
    The Andover State Bank
    The Arlington Bank
    The Bancorp Bank
    The Bank of Canton
    The Bank of Charlotte County
    The Bank of Commerce
    The Bank of Fayette County
    The Bank of Georgia
    The Bank of Holland
    The Bank of Missouri
    The Bank of New York
    The Bank of New York as Trustee
    The Bank of Northern Michigan
    The Bank of San Antonio
    The Bank of South Carolina
    The Bank of the Pacific
    The Bollin Mortgage Group, Inc.
    The Broadstone Mortgage Company
    The Bryn Mawr Trust Company
    The Business Bank of St. Louis
    The Carroll Mortgage Group, Inc.
    The Citizens National Bank of Meridian
    The Clinton Mortgage Network
    The Coastal Bank dba Coastal Mortgage Company of SC
    The Columbia Bank
    The CU Mortgage Center, Inc. dba The Mortgage Center, Inc
    The Delaware County Bank & Trust Company
    The El Paso Mortgage Company
    The Equity Group Financial, Inc.
    The F & M Bank and Trust Company
    The Family Credit Union
    The First Mortgage Corporation
    The First National Bank
    The First National Bank Of Chicago – Non-Member
    The First National Bank of Deerwood
    The First National Bank of Granbury
    The First National Bank of Jackboro dba The Highlands Bank
    The First National Bank of Ogden
    The First, A National Banking Association
    The Freedom Bank of Virginia
    The Funding Source LLC
    The Gordon Group, Inc.
    The Grange Bank
    The Guernsey Bank
    The H55 Group, Inc.
    The Herring National Bank
    The Hinks Company, Inc.
    The Home Equity Network, LLC
    The Home Loan Pros, Inc.
    The Huntington National Bank
    The Hurricane Mortgage Company, Inc.
    The Joshua Group Co. LLC dba U.S. Lending
    The Kent Group Ltd
    The Klein Group, LLC
    The LaPorte Savings Bank
    The Lenders Group LLC
    The Lending Company Inc
    The Lending Connection, Inc.
    The Lending Group
    The Lending Partners, LLC
    The Loan Experts Corporation dba All Amrican Finance
    The Louisville Mortgage Group
    The McCue Mortgage Company
    The Milan Group Inc dba Milan Mortgage Bankers
    The Money Source Inc.
    The Money Source, Inc.
    The Mortgage Advantage, Inc
    The Mortgage Bankers Corp.
    The Mortgage Broker, LLC
    The Mortgage Center, Inc.
    The Mortgage Center, LLC
    The Mortgage Company
    The Mortgage Company LLC
    The Mortgage Connection
    The Mortgage Depot Inc
    The Mortgage Firm, Inc
    The Mortgage Funding Group, Inc.
    The Mortgage Group, Inc.
    The Mortgage Group, LLC
    The Mortgage House, Inc.
    The Mortgage Lending Group, Inc.
    The Mortgage Makers, Inc.
    The Mortgage Network Wholesale Lender
    The Mortgage Network, Inc., dba Mortgage Network North Ameri
    The Mortgage Network, LLC
    The Mortgage Outlet, Inc.
    The Mortgage Place
    The Mortgage Shoppe Inc
    The Mortgage Source Inc
    The Mortgage Specialist LP
    The Mortgage Store Financial, Inc.
    The National Bank
    The New York Mortgage Company, LLC
    The Northwestern Mutual Life Ins. Co. dba Northwestern Mutua
    The Pappadakis Corporation dba Plaza Mortgage Group of FL
    The Park Bank
    The Peoples Bank Co.
    The Petkewich Corp dba The Mortgage Outlet
    The Ping Mortgage Company
    The Poca Valley Bank
    The Premiere Mortgage Corporation
    The Private Bank
    The PrivateBank Mortgage Company dba The PrivateBank
    The PrivateBank Mortgage Company, LLC
    The Situs Companies
    The Stone Hill Group
    The Vault Mortgage Co.
    The Warren Group
    The Washington Savings Bank
    The Washington Trust Company
    The Watermark Group Inc. dba Watermark Financial
    Thomas Louis Mortgage Inc
    Thomas Mortgage & Financial Services
    Thornburg Mortgage Home Loans, Inc.
    Thoroughbred Lending Company LLC
    Three Rivers Financial Services, Inc.
    Three Rivers Mortgage
    TIB Bank of the Keys
    TIB-The Independent Bankers Bank
    Tidewater Home Funding, LLC
    Tidewater Mortgage Services, Inc.
    TierOne Bank
    Tim Simko dba First United Lending
    Timberland Mortgage Services, Inc.
    Tippecanoe Mortgage, Inc.
    Titan Funding
    Titan Lenders Corp.
    TLP Funding Corporation
    TM Capital, Inc.
    TMBG Inc
    TNBank dba TNBank of Oak Ridge
    Token Mortgage Corporation
    Tomahawk Community Bank, SSB
    Top Mortgage Corporation
    Top Performers Financial Services, Inc.
    Total Funding Corporation
    Total Home Source, Inc
    Total Mortgage Services, L.L.C.
    Tower Mortgage and Financial Services Corp
    Tower Mortgage Capital Inc., dba National Home Lenders
    Tower Mortgage Corporation
    Town & Country Bank
    Town North Bank N.A.
    Towne Mortgage Company
    Townebank Mortgage
    Townstone Financial, Inc.
    TPI Mortgage, Inc.
    Trade Street Mortgage Inc.
    Trademark Mortgage LLC
    Tradition Mortgage LLC
    Tranex Financial, Inc.
    Transcontinental Lending Group, Inc
    TransLand Financial Services, Inc.
    Transnational Financial Network, Inc.
    Travis Mortgage, LLC
    Treeside Financial, LLC
    Tremont Credit Union
    Triad Bank, N.A.
    Tribeca Lending Corp.
    Tri-County Bank
    TriCounty Mortgage Corporation
    Trident Mortgage Company
    Triduanum Financial Inc
    Trinity Mortgage Capital, Inc.
    Trinity Mortgage Company of Central Florida, LLC dba Trinity
    Trinity Mortgage Corporation
    Tristate Capital Bank
    Tristone Community Bank
    Triton Commercial Capital Incorporated
    Triumph Funding, Inc.
    True Lending Company, LLC
    Truemark Lending, Inc
    Truliant Federal Credit Union
    Trust USA Mortgage Group
    Trustmark National Bank
    TrustMor Mortgage Company, LLC
    Tucker Mortgage, LLC
    Turner Mortgage Company
    Turtle Creek Mortgage Inc.
    TWA Corporation
    Twin Capital Mortgage
    Twin City Bank
    Twin Star Credit Union
    TXL Mortgage Corporation
    U S Capital Home Loans Inc
    U. S. Lending Group, Inc.
    U.P. Catholic Credit Union
    U.S. Bank as Trustee
    U.S. Bank N.A.
    U.S. Bank National Associaton
    U.S. Capital Funding, LLC
    U.S. Financial LTD
    U.S. Mortgage Corporation
    U.S. Recordings, Inc.
    UBS Home Finance
    UBS Real Estate Investments Inc.
    UBS Real Estate Securities Inc.
    UBS Special Servicing Group
    UBS Warburg Real Estate Securities Inc. (Warehouse)
    Ulster Savings Bank
    UM Acquisitions LLC
    UMG Mortgage LLC
    Unified Capital Group
    Unifirst Mortgage Corp
    Unifirst Mortgage Corp.
    Unilenders, Inc.
    UniMortgage LLC
    Union Bank
    Union Bank and Trust Company
    Union Capital Mortgage
    Union Capital Mortgage Business Trust
    Union Federal Bank of Indianapolis.
    Union Federal Bank of Indianapolis..
    Union Federal Mortgage Corp.
    Union Federal Mortgage Corporation
    Union Federal Savings Bank
    Union Fidelity Mortgage Inc
    Union Home Mortgage LLC
    Union Mortgage Group, Inc
    Union Mortgage Group, Inc.
    Union Mortgage Omaha Inc
    Union National Mortgage Company
    Union River Mortgage LLC
    Union Savings Bank
    Union State Bank of Everest dba Bank of Atchison
    Union Trust Mortgage Corporation
    United Bank
    United Bank & Trust – Washtenaw
    United Bank (VA)
    United Bank Inc.
    United Capital Financial of Atlanta, LLC
    United Capital Mortgage Corporation
    United Capital, Inc.
    United Commercial Bank
    United Community Bank
    United Community Mortgage Corp.
    United Community Mortgage Services Inc.
    United Equity LLC
    United Federal Credit Union
    United Federal Mortgage a div. of United Medical Bank, FSB
    United Fidelity Bank
    United Fidelity Funding Corp.
    United Financial Mortgage Corporation
    United Funding Mortgage Corp.
    United General Mtg Corp dba CLS Mtg a subsidary of UGMC
    United Group Acquisition, LLC
    United Guaranty Residential Insurance Company of N.C.
    United Heritage Credit Union
    United Home Mortgage
    United Home Mortgage Corporation
    United Lending Solutions LLC dba Home Lending Solutions
    United Liberty Mortgage Corp.
    United Mortgage Bankers, Inc.
    United Mortgage Company – Washtenaw
    United Mortgage Finance Group, Inc
    United Mortgage Funding
    United Mortgage Investors, Inc.
    United Mutual Funding Corp
    United Northern Mortgage Bankers
    United Pacific Mortgage
    United Pacific Mortgage as Vendor
    United Pacific Mortgage DBA Mandalay Mortgage
    United Prairie Bank
    United Residential Lending LLC
    United Security Financial
    United Western Bank
    UnitedOne Credit Union
    Unitrust Mortgage, Inc.
    Unity Mortgage Corp.
    Universal American Mortgage Company, LLC
    Universal Financial Group, Inc.
    Universal Lending Corporation
    Universal Lending Services, Inc.
    Universal Mortgage & Finance, Inc.
    Universal Mortgage Company, LLC
    Universal Mortgage Corporation
    University Bank
    University Mortgage Inc.
    University of Wisconsin Credit Union
    Uniwest Mortgage Corporation
    Unprime Securities Company LLC
    Unversity Federal Credit Union
    Uptown Mortgage
    Urban Financial, Inc.
    Urban Trust Bank
    US Bank as Custodian/Trustee
    US Bank National Association (Warehouse)
    US Capital Financial Services, Inc dba Primestreet Lending,
    US Employees O.C. Federal Credit Union
    US Equity Mortgage, LLC
    US Financial Funding Inc. dba US Financial
    US Lending & Finance LTD
    US Money Source, Inc. d/b/a Soluna First
    US Mortgage Bankers Inc. dba USMB Inc
    US Mortgage Capital Inc.
    US Mortgage Corp.
    US Mortgage Corporation dba Mortgage Concepts
    US Mortgage Finance Corp
    US Mortgage Group, LLC
    US Mortgage Network
    US New Mexico FCU
    USA Bank
    USA Funding Corp
    USA Home Loans, Inc.
    USA Mortgage Business Inc.
    USA Mortgage Corporation
    USAA Federal Savings Bank
    USB Home Lending
    USU Community Federal Credit Union
    Utah Community Federal Credit Union
    Utah Financial, Inc dba Federal Mortgage Funding
    Utah Housing Corporation
    Uvantage Home Lending Services, Inc.
    V.I.P. Mortgage Inc.
    Valley Bank
    Valley Bank of Helena
    Valley Mortgage Solutions LLC
    Valley National Bank
    Valley National Bank (OK)
    Valley View State Bank
    Valley Vista Mortgage Corporation
    Valley West Corporation DBA Valley West Mortgage
    Valley Wide Home Loans
    Vanderbilt Mortgage & Finance, Inc
    VanDyk Mortgage Corporation
    Vanguard Funding LLC
    Vanguard M & T, Inc.
    Vanguard Mortgage Corporation
    VantageSouth Bank
    Vantium Capital Markets, L.P.
    Vantium Capital, Inc., d/b/a Acqura Loan Services
    Vaughan Financial Mortgage Group, Inc.
    VCH – 1998-A (Wells Fargo as Trustee)
    VCH – 1999-A (Wells Fargo as Trustee)
    VCH – 2003-A (Wells Fargo Bank of Minnesota, N.A as Trustee)
    VCH – Beethoven (Dresdner as Lender)
    VCH -Alpine (Credit Suisse First Boston as Lender)
    Vectra Bank Colorado
    Venta Financial Group, Inc.
    Venture Bank
    Venture Financial Services
    Venture One Mortgage Corporation
    Veridian Credit Union
    Veritas Funding LLC
    Veritas In Commercium LLC
    Verity Credit Union
    Vertical Financial Group
    Vertical Lend dba Mortgage Warehouse
    Verus Bank, NA
    Veterans Home Mortgage Inc.
    Victoria Capital Inc dba Victoria Funding Services
    Victorian Finance LLC
    Vieux Carre Mortgage
    Viewpoint Bank
    ViewPoint Bank (Warehouse)
    Viewpoint Bankers Mortgage
    Vigilant Federal Savings Bank
    Vigio Lending Corp.
    Viking Capital
    Village Bank Mortgage Corporation
    Village Capital & Investment, LLC DBA Village Home Mortgage
    Village Mortgage Company
    Vinson Mortgage Services, Inc. dba Vinson Mortgage Group
    Vintage Hills Mortgage Corporation
    Vintage Mortgage Corporation
    Vintage Mortgage Group
    VIP Mortgage Corporation
    VIP Mortgage Inc.
    VIP Mortgage Solutions, LLC
    Virgin Money USA, Inc.
    Virginia Credit Union Inc.
    Virginia Heritage Bank
    VirtualBank Seniors Lending Group
    Visalia Community Bank
    Vision Bank
    Vision Mortgage Company, Ltd. dba Vision Mortgage Company
    Vision Mortgage LLC
    Vision Mortgage Professionals Inc.
    Vision Mortgage Resources, Inc.
    Vision One Mortgage, Inc.
    Vision, Inc.
    VIST Bank
    Vista Mortgage Corp.
    Vista Mortgage Corporation
    Vista Mortgage Services, Inc.
    Vitek Mortgage Group
    Volunteer Mortgage Lenders Inc
    Volunteer Trust Mortgage Corporation
    Voorhees Ventures, Inc.
    W J Capital Corporation
    W. R. Clouse & Associates Mortgage Company
    W.J. Bradley Mortgage Capital Corp.
    W.M. Howard Inc.
    W.R. Starkey Mortgage LLC
    W/E Mortgage Services Inc.
    Wachovia Bank National Association
    Wachovia Bank, NA as Trustee
    Wachovia Correspondent Warehouse Lending
    Wachovia Mortgage Corporation
    Wachovia Mortgage Corporation – Winston-Salem
    Wachovia Mortgage, FSB
    Wachovia Mortgage, FSB (CP)
    Wachovia Securities
    Wachusett Mortgage Corporation
    Wahlstrom Financial Group
    Walker Jackson Mortgage Corp.
    Wall Street Financial Corporation
    Wall Street Mortgage Bankers, Ltd.
    Wallick and Volk
    Walter Mortgage Company
    Walton Mortgage
    Wantland Realty Corporation DBA WRC Mortgage
    Ward Lending Group, LLC
    Warehouse Lender #1005308
    Warehouse USA Capital, Inc.
    Warren Bank Mortgage Company, LLC
    Wasatch Capital Mortgage, Inc
    Washington Financial Group, Inc.
    Washington Mutual Bank (Interim Funder)
    Washington Mutual Bank (vendor)
    Washington Mutual Bank, F.A.
    Washington Mutual Mortgage Securites Corp.
    WashingtonFirst Bank
    Washtenaw Mortgage Company
    Waterfall Victoria Master Fund 2008 – 1 Grantor Trust Servic
    Waterfall Victoria Master Fund Ltd
    Waterfall Victoria REO, LLC
    Watermark Credit Union
    Watermark Financial Partners, Inc.
    WaterStone Bank SSB
    Waterstone Mortgage Corp.
    Watson Group Financial Corporation
    Watson Mortgage Corp.
    Waukesha State Bank
    Waukesha State Bank (WI)
    Wausau Mortgage Corporation dba Broadstreet Mortgage
    WCRSI 2007-3 LLC
    WCS Funding Group Inc.
    WCS Lending LLC
    Weatherford National Bank
    Webster Bank, Inc.
    Weger Mortgage Corporation
    WEI Mortgage Corp
    Weichert Financial Services
    Welcome Home Finance, LP
    Welcome Home Loans, Inc.
    Welcome Home Mortgage Inc
    Wells Bank of Platte City
    Wells Fargo – Acquisition
    Wells Fargo as Trustee
    Wells Fargo Bank, NA dba Wells Fargo Home Equity
    Wells Fargo Foothill, LLC dba Lender Finance Division
    Wells Fargo Home Mortgage a Division of Wells Fargo Bank NA
    Wells Fargo Mortgage Document Custody
    Wendover as SubServicer for Chase
    Wendover Financial Services
    WesBanco Bank, Inc.
    West Alabama Bank & Trust
    West Coast 2007-1 LLC
    West Coast 2008-1, LLC
    West Coast 2008-3, LLC
    West Coast 2008-4, LLC
    West Coast Bank
    West Coast Realty Services, Inc.
    West Coast Servicing, Inc.
    West Community Credit Union
    West Gate Bank
    West Michigan Bank & Trust
    West Penn Financial Service Center, Inc.
    West Suburban Bank
    West Town Savings Bank
    WestAmerica Mortgage Company
    Westbridge Bank and Trust dba Westbridge Mortgage
    Westbury Bank
    Western Estates, Inc.
    Western Fidelity Mortgage Company
    Western Financial LLC dba American Guaranty Mortgge
    Western Horizon Mortgage
    Western Mortgage Brokers Inc dba Western Mtg Bankers Inc.
    Western Mortgage Corporation
    Western Ohio Mortgage Corporation
    Western Reliance Funding Group
    Western Reserve Bank
    Western Residential Mortgage Inc
    Western Security Bank
    Western State Bank
    Western States Mortgage Corporation
    Western Thrift & Loan
    Western Vista FCU
    Western World Financial
    Westfield Bank FSB
    Westlend Financing Inc dba American Capital Funding Inc
    Westminster Mortgage Co. a Division of Shapell Industries
    Westsound Bank dba Westsound Mortgage
    Weststar Mortgage Corporation
    WestStar Mortgage, Inc.
    WFS Mortgage Services Inc.
    Whidbey Island Bank
    Whitney National Bank
    Whitney National Bank (fka Access Mortgage)
    Whitney National Bank (fka Parish National Bank)
    Wholesale America Mortgage, Inc.
    Wholesale Capital Corporation
    Wiedman Mortgage, Inc.
    Wieland Financial Services, Inc.
    Wilber National Bank
    William M. Perlmotter dba Executive Mortgage Lenders
    William Raveis Mortgage, LLC
    Willow Bend Mortgage
    Willow Financial Bank
    Wilmington Finance, Inc.
    Wilmington Mortgage Services Inc
    Wilshire Credit Corp.
    Wilson & Muir Bank and Trust Company
    Wilson Mortgage Services, Inc.
    Wilson Resources, Inc.
    Windermere Mortgage Services Series LLC a DE Series LLC
    Windom Capital Inc. dba Windom Mortgage
    Windsor Capital Mortgage
    WinStar Mortgage Partners Inc. sub of Partner Loan Services
    Wisconsin Mortgage Corporation
    WM Specialty Mortgage LLC
    WMC Mortgage Corp. Minnesota
    WMC Mortgage Corporation
    WMD Realty, Inc.
    Wolfe Financial, Inc. dba Integrity Mortgage Group
    Wolters Kluwer Financial Services
    Wood & Huston Bank dba Wood & Huston Bancorporation Inc
    Woodfield Planning Corporation
    Woodforest National Bank dba Woodforest Mortgage Company
    Woodland Mortgage Partners, Inc
    Woodlands Bank
    World Alliance Financial Corp
    World Capital Mortgage, LP
    World Group Mortgage, LLC
    World Mortgage Corporation of Miami
    World Mortgage Group, Inc.
    World Wide Credit Corporation
    World Wide Financial Services, Inc.
    World Wide Mortgage Group, Inc.
    Worldwide Financial Resources, Inc.
    Worthington Federal Bank
    Worthington Mortgage Group, Inc.
    Wow Financial Inc
    Wow Financial LLC dba Advanced Mortgage Concepts
    Wright Financial Inc
    Wright-Patt Credit Union, Inc.
    Wyman Funding Group Inc.
    Wyndham Capital Mortgage, Inc.
    Wyoming Bank & Trust
    Wyoming State Bank
    Xenia Financial LLC
    Xetus Corp.
    Xtra Mile Financial Services, LLC
    Yale Financial Group, Inc.
    York Financial Inc.
    Your Best Rate Financial, LLC
    Your Community Bank
    Your Mortgage Company, LLC
    Your Mortgage Source LLC
    Your Mortgage Source, Inc.
    Yvonne K Yung Kwan Chau DBA YKC Mortgage
    Z.T.F. LLC dba At Home Mortgage Group
    Zeus Mortgage Ltd
    Zino Financial, Inc.
    Zions First National Bank
    Z-Mortgage Company, L.L.C.




    Red Flags

    Critical loan processing activities, such as  verification of

    income, employment, or deposit, is delegated to brokers.

    Delegated underwriting allowed for correspondents that are new or

    lack an established track record with the FI.

    A growing number of loans is being repurchased due to

    misrepresentations by the FI under purchase and sale agreements

    with secondary market investors.  The originating FI may suffer

    significant financial losses in the event of a large and

    unforeseen fraud.

    Third party mortgage loan fraud is not covered in standard

    fidelity bond insurance.

    Tax returns show RE taxes paid but no property is identified as


    Alimony is paid but not disclosed.

    Evidence of white out or other document alterations is observed.

    Type or handwriting varies from other loan file documents or

    handwriting is the same on documents that should have been

    prepared by different people or entities.

    Internal Controls/Best Practices

    Review purchase and sales agreements with brokers, correspondents,
    and secondary market investors to determine if general
    representations and warranties contain appropriate fraud and
    misrepresentation provisions.

    Determine the FI’s responsibility for repurchasing and putting
    back loans that were funded based on misrepresentations.

    Check whether an endorsement or rider exists to the fidelity bond
    that provides coverage of third party mortgage fraud.

    Regularly document the FI’s review of insurance coverage.

    Establish procedures to ensure the bonding company is notified of
    a possible claim within the policy’s specified period.

    Adopt detailed policies and procedures to ensure effective
    controls are in place to set, validate, and clear conditions prior
    to final approval processes.

    Base underwriter compensation on loans reviewed and not loans

    Establish effective pre-funding and post QC programs that include
    sampling, portfolio analysis, appraisal, and income/down payment
    verification practices.

    As a part of the pre-funding QC process, use AVMs to corroborate
    appraised values.

    Employ internally developed or vendor-provided fraud detection

    Institute corporate wide fraud awareness training.

    Perform due diligence of brokers and correspondents.  Understand
    the risks in their policies, procedures, and practices before
    transacting business.

    Determine how and when the FI reserves for fraud and ensure
    compliance with FAS 5.

    Review the FI’s litigation roster for existing and potential class
    actions, and threatened litigation that may highlight a problem
    with a particular broker, correspondent, or internal practices.

    Review whistleblower and hot line reports, which may indicate
    fraudulent activities.

    Mortgage Brokers

    A mortgage broker is an individual who, for a fee, originates and

    places loans with an FI or an investor but does not service the


    o Review the broker’s financial information as stringently
    as for other RE borrowers.
    o Ensure the FI’s broker agreements require brokers to act
    as the FI’s representative/agent.
    o Independently verify the broker’s background information
    by checking business history outside of given references.
    o Obtain a new credit report for the broker and check for
    recent debt at other FIs.
    o Obtain resumes of principal officers, primary loan
    processors, and key employees.
    o Conduct state license verification.
    o Conduct criminal background checks and adverse data base
    searches, i.e., MARI (fraud repository).

    Conduct an annual re-certification of brokers.

    Conduct pre-funding reviews on all new production utilizing a pre-
    funding checklist.

    Conduct QC underwriting reviews.

    Base broker compensation incentives on something other than loan
    volume, i.e., credit quality, documentation completeness,
    prepayments, fraud, and compliance.

    Establish measurable criteria that trigger recourse to the broker,
    such as misrepresentation, fraud, early payment defaults, failure
    to promptly deliver documents, and prepayments (loan churning).

    Hold brokers and third party contract underwriters responsible for
    gross negligence, willful misconduct, and errors/omissions that
    materially restrict salability or reduce loan value.

    Establish a broker scorecard to monitor volume, prepayments,
    credit quality, fallout, FICO scores, LTVs, DTIs, delinquencies,
    early payment defaults, foreclosures, fraud, documentation
    deficiencies, repurchases, uninsured government loans, timely loan
    package delivery, concentrations, and QC findings.

    Perform detailed vintage analysis, and track delinquencies and
    prepayments by number and dollar volume.

    Closely monitor the total number of loans and products from a
    single broker.

    Establish an employee training program that provides instruction
    on understanding common mortgage fraud schemes and the roles of a
    mortgage broker, as well as recognizing red flags.

    Establish a periodic audit of the brokered mortgage loan
    operations with specific focus on the approval process.

    Perform social security number validation procedures to validate
    borrower identity.

    Red Flags

    No attempt is made to determine the financial condition of the

    broker or obtain references and background information.

    A close relationship exists between the broker, appraiser, and

    lender, raising independence questions.

    The broker acts as an advocate for the borrower instead of serving

    as the FI’s representative/agent.

    High “yield spread premiums” are paid by the FI.

    Original documents are not provided to the funding FI within a

    reasonable time.

    An unusually high volume of loans with maximum loan to value

    limits have been originated by one broker.

    An uncommonly large number of foreclosures, delinquencies, early

    payment defaults, prepayments, missing documents, fraud, high-risk

    characteristics, QC findings, or compliance problems exist on

    loans purchased from any broker.

    A large volume of loans from one broker arrives using the same


    High repurchase volume exists for a specific broker.

    Numerous applications from a particular broker are provided

    possessing unique similarities.

    A high volume of loans exist in the name of trustees, holding

    companies, or offshore companies.

    An unusually large increase is noted in overall volume of loans

    during a short time period.

    Internal Controls/Best Practices5

    Conduct an initial acceptance review and obtain documentation to

    support broker approval.  Examples of actions to be taken include:


    The mortgage application is the initial document completed by the
    borrower that provides the FI with comprehensive information
    concerning the borrower’s identity, financial position and
    employment history.

    Red Flags

    The application is unsigned or undated.

    Power of attorney is used.  Investigate why the borrower cannot
    execute documents and if formal supporting documentation exists.

    Signatures on credit documents are illegible and no supporting
    identification exists.

    Price and date of purchase is not indicated.

    Borrower is selling his current residence, but does not provide
    documents to support a sale.

    Down payment is not in cash, i.e., source of deposit is a
    promissory note or repayment of a personal loan.

    Borrower has high income with little or no personal property.

    Borrower’s age is not consistent with the number of years of

    Borrower has an unreasonable accumulation of assets compared to
    income or has a large amount of unsubstantiated assets.

    Borrower claims to have no debt.

    Borrower owns an excessive amount of RE.

    New housing expense exceeds 150% of current housing expense.

    A post office box is the only indicated address for the borrower’s

    The same telephone number is used for the borrower’s home and

    Application date and verification form dates are not consistent.

    Patterns or similarities are apparent from applications received
    from a specific seller or broker.

    Certain brokers are unusually active in a soft RE market.

    Concentration of loans to individuals related to a specific
    project is noted.

    Borrower does not guarantee the loan or will not sign in an
    individual capacity.

    Borrower’s income is not consistent with job type.

    Employer is an unrealistic commuting distance from property.

    Years of education is not consistent with borrower’s profession.

    Borrower is buying investment properties with no primary

    Transaction resulted in a large cash-out refi as a percent of the
    loan amount.

    Internal Controls/Best Practices

    Establish an employee training program that provides instruction
    on understanding common mortgage fraud schemes and recognizing red

    Conduct pre-funding reviews on new production.

    Closely monitor new brokers, correspondents, and products.
    Scorecard criteria can be used to track performance.  Typical
    tracking data includes:  default rates, pre-purchase cycle times,
    loan quality indicators such as underwriting exceptions, and key
    data changes prior to approval.

    Verify the source of down payment funds by directly contacting the
    FI where funds are shown deposited.

    Closely analyze the borrower’s financial information for unusual
    items or trends.

    Independently verify employment by researching the location and
    phone number of the business.

    Employ pre-funding and post-closing reviews to detect any
    inconsistencies within the transaction.

    Conduct risk based QC audits prior to funding.

    Ensure that prior liens are immediately paid from new loan

    Assess the volume of critical post-closing missing documents,
    determine the potential for repurchase recourse, and evaluate
    reserve adequacy.

    Monitor RE markets from the locale in which the FI’s mortgage
    loans originated.

    Establish a periodic independent audit of mortgage loan

    Provide fraud updates/alerts to employees.

    Review patterns on declined loans, i.e., individual social
    security number, appraiser, RE agent, loan officer, broker, etc.

    Establish a fraud hotline for anonymous fraud tips.

    Increase the use of original supporting documentation on third
    party transactions, i.e., wholesale and correspondent


    An appraisal is a written report, independently and impartially
    prepared by a qualified individual, stating an opinion of market
    value of a property as of a specific date.

    Red Flags

    The appraiser is a frequent or large volume borrower at the FI.

    The appraiser owns property in the project being appraised.  This
    is a violation of the appraisal regulation and raises concerns
    about appraiser independence and bias.

    The most recent assessed tax value does not correlate with the
    appraisal’s market value.

    An appraiser is used who is not on the institution’s designated
    list of approved appraisers.

    The appraiser is from outside the area and may not be familiar
    with local property values.  Understanding of local market nuances
    is critical to an accurate property valuation.

    An appraisal is ordered by a party to the transaction other than
    the FI, such as the buyer, seller, or broker.

    An appraisal is ordered before the sales contract is written.

    Certain information is left blank such as the borrower, client, or

    The appraised value is contingent upon curing some property
    defects, i.e., drainage problems or a zoning change.

    Comparables are not verified as recorded or are submitted by a
    potentially biased party, such as the seller or broker.

    Old comparables (9-12 months old) are used in a “hot” market.

    Comparables are an excessive distance from the subject property or
    are not in the subject property’s general area.

    Comparables all contain similar value adjustments or are all
    adjusted in the same direction.

    All comparables are on properties appraised by the same appraiser.

    Unusual or too few comparables are used.

    Similar comparables are used across multiple transactions.

    Comparables and valuations are stretched to attain desired loan-
    to-value parameters.

    Excessive adjustments are made in an urban or suburban area when
    the marketing time is less than six months.

    Appreciation is noted in a stable or declining areas.

    Large unjustified valuation adjustments are shown.

    The land constitutes a large percentage of the value.

    The market approach greatly exceeds the replacement cost approach.

    Overall adjustments are in excess of 25%.

    Photos do not match the description of the property.

    Photos of comparables look familiar.

    Photos reveal items not disclosed in the appraisal, such as a
    commercial property next door, railroad tracks, etc.

    Items with the potential for negative valuation adjustments, i.e.,
    power lines, railroad tracks, landfill, etc., are avoided in
    appraisal photos.

    Loan amounts are disclosed to the appraiser.

    File documentation is inadequate to determine whether appraisals
    were properly scrutinized or supported by additional appraisal

    The appraisal fee is based on a percentage of the appraised value.

    Independent reviews of external fee appraisals are never

    One or more sales of the same property has occurred within a
    specified period (6-12 months) and exceeds certain value increases
    (10% or more value increase).

    A fax of the appraisal is used in lieu of the original containing
    signature and certification of appraiser.

    Internal Controls/Best Practices

    Establish an employee training program that provides a good
    overview of common mortgage fraud schemes, the appraisal
    regulation, the RE lending standards regulation, appraisal
    techniques, and red flag recognition.

    Implement a strong appraisal and evaluation compliance review
    process that is incorporated into the pre-funding quality
    assurance program.

    Ensure reviewers identify violations of regulations and
    noncompliance with RE lending standards and other interagency

    Establish an approved appraiser list for use by retail, broker,
    and correspondent origination channels.  This list should be
    generated and controlled by a unit independent of production.

    Obtain a current copy of each appraiser’s license or certificate.

    Implement “watch” list and monitoring systems for appraisers who
    exhibit suspect practices, issues, and values.  Include a post-
    closing review to detect any transaction inconsistencies.

    Establish a “suspended” or “terminated” list of appraisers who
    have provided unreliable valuations or improper practices.

    Implement controls to ensure that “terminated” appraisers are
    prohibited from engaging in future transactions with the FI, and
    its brokers and correspondents.

    Implement third party appraisal controls to ensure compliance with
    regulatory guidance, specifically as it applies to appraisals and
    evaluations ordered by loan brokers, correspondents, or other FIs.

    Develop appraisal requirements based on transaction risks.

    Statistically test the appropriateness of appraisals obtained by
    brokers and correspondents by obtaining independent AVMs and

    Establish an independent appraisal review/collateral valuation
    unit to research valuation discrepancies and provide technical

    Review the appraisal’s three-year sales history to determine if
    land flips are occurring.

    Perform detailed research on each appraiser’s business history and
    financial condition.

    Physically verify the location and condition of selected subject
    properties and comparables.

    Monitor RE market values in areas that generate a high volume of
    mortgage loans and where concentrations exist.

    Employ pre- and post-closing QC reviews to detect inconsistencies
    within the transaction and hold production units financially
    accountable for proper documentation and quality.

    Conduct periodic independent audits of mortgage loan operations.

    Credit Report

    A credit report is an evaluation of an individual’s debt repayment

    Red Flags

    The absence of a credit history can indicate the use of an alias
    and/or multiple social security numbers.

    A borrower recently paying all accounts in full can indicate an
    undisclosed consolidation loan.

    Indebtedness disclosed on the application differs from the credit

    The length of time items are on file is inconsistent with the
    buyer’s age.

    The borrower claims substantial income but only has credit
    experience with finance companies.

    All trade lines were opened at the same time with no explanation.

    A pattern of delinquencies exists that is inconsistent with the
    letter of explanation.

    Recent inquiries from other mortgage lenders are noted.

    AKA (also known as) or DBA (doing business as) are indicated.

    The borrower cannot be reached at his place of business.

    FI cannot confirm the borrower’s employment.

    DTI ratios are right at maximum approval limits.

    Employment information/history on the loan application is not
    consistent with the verification of employment form.

    Credit Bureau alerts exist for Social Security number
    discrepancies, address mismatches, or fraud victim alerts.

    Internal Controls/Best Practices

    Establish an employee training program that provides instruction
    on understanding common mortgage fraud schemes, analyzing credit
    reports, and recognizing red flags.

    Include an analysis of the credit report in the pre-funding
    quality assurance program.

    Make direct inquiries to the borrower and creditors to get an
    explanation of unusual or inconsistent information.

    Obtain an updated credit report if the one received is older than
    six months.

    Independently verify employment by researching the location and
    phone number of business.

    Implement a post-closing review to detect any inconsistencies
    within the transaction.

    Establish a periodic independent audit of mortgage loan

    Define DTI calculation criteria and conduct training to ensure
    consistency and data integrity.

    Clarify non-borrower spouse issues, such as community property
    issues and the impact of bankruptcy and debts on the borrower’s
    repayment capacity.

    Ensure lease obligations are reflected in borrower debts and
    repayment capacity.

    Conduct re-verification of credit to ensure accuracy of
    broker/correspondent provided credit reports.

    Obtain more than one report from multiple repositories available
    to corroborate the initial credit report if data appears


    A closing or settlement is the act of transferring ownership of a
    property from seller to buyer in accordance with the sales contract.

    Escrow is an agreement between two or more parties that requires
    certain instruments or property be placed with a third party for
    safekeeping, pending the fulfillment or performance of a specific
    act or condition.

    Red Flags

    Related parties are involved in the transaction.

    The business entity acting as the seller may be controlled by or
    is related to the borrower.

    Right of assignment is included which may hide the borrower’s
    actual identity.

    Power of attorney is used and there is no documented explanation
    about why the borrower cannot execute documents.

    The buyer is required to use a specific broker or lender.

    The sale is subject to the seller acquiring title.

    The sales price is changed to “fit” the appraisal.

    No amendments are made to escrow.

    A house is purchased that is not subject to inspection.

    Unusual amendments are made to the original transaction.

    Cash is paid to the seller outside of an escrow arrangement.

    Cash proceeds are paid to the borrower in a purchase transaction.

    Zero funds are due from the buyer.

    Funds are paid to undisclosed third parties indicating that there
    may be potential obligations by these parties.

    Odd amounts are paid as escrow deposits or down payment.

    Multiple mortgages are paid off.

    The terms of the closed mortgage differ from terms approved by the

    Unusual credits or disbursements are shown on settlement

    Discrepancies exist between the HUD-1 and escrow instructions.

    A difference exists between sales price on the HUD-1 and sales

    Internal Controls/Best Practices

    Establish an employee training program that provides an
    understanding of common mortgage fraud schemes, proper closing
    procedures, and recognizing red flags.

    Provide the closing agent with instructions specific to each
    mortgage transaction.

    Instruct the closing agent to accept certified funds only from the
    FI that is the verified depository.

    Require the closing agent to notify the FI if the agent has
    knowledge of a previous, concurrent, or subsequent transaction
    involving the borrower or the subject property.

    Obtain a specific transaction closing protection letter from the
    closing agent.

    Implement controls to ensure loan proceeds fully discharge all
    debts and prior liens as required.

    Employ pre- and post-closing reviews to detect any inconsistencies
    within the transaction.

    Conduct periodic independent audits of mortgage loan operations.

    Use IRS form 4506 on all loans to facilitate full investigation of
    future fraud allegations.

    Industry studies indicate that a significant portion of the loss
    associated with residential RE loans can be attributed to fraud.
    Industry experts estimate that up to 10% of all residential loan
    applications, representing several hundred billion dollars of the
    annual U.S. residential RE market, have some form of material
    misrepresentation, both inadvertent and malicious.  An in-depth
    review by The Prieston Group of Santa Rosa, California of early
    payment defaults, an indicator of problem loans, revealed that 45-
    50% of these loans have some form of misrepresentation.
    Additionally, this study showed that approximately 25% of all
    foreclosed loans have at least some element of misrepresentation,
    and losses on floan balance.

    The second motive, fraud for profit, is a major concern for the
    mortgage lending industry.  It often results in larger losses per
    transaction and usually involves multiple transactions.  The schemes
    are frequently well planned and organized.  There may also be intent
    to default on the loan when the profit from the scheme has been
    realized.  Multiple loans and people may be involved and
    participants, who are often paid for their involvement, do not
    necessarily have knowledge of the whole scheme.

    Fraud for profit can take many forms including, but not limited to:

    Receipt of an undisclosed or unusually high commission or fee,

    Representation of investment property as owner-occupied since
    FIs usually offer more favorable terms on owner-occupied RE, •
    Sale of an otherwise unsalable piece of property by concealing
    undesirable traits, such as environmental contamination,
    easements, building restrictions, etc.,

    Attainment of a new loan to redeem a property from foreclosure
    to relieve a burdensome debt,

    Rapid buildup of a RE portfolio with an inflated value to
    perpetrate a land flip scheme,

    Mortgage of rental RE with the intention of collecting rents
    and not making payments to the lender, retaining funds for
    personal use,

    The advance of loan approvals for customers to benefit from the
    commission payments, and/or

    Misrepresentation of personal identity, i.e., use of illegally
    acquired social security numbers, to illegally obtain a loan,
    or to sell/take cash out of equity on a property with no
    intention of repaying the debt.

    The third motive, which involves additional criminal purposes beyond
    fraud, is becoming more of a concern for law enforcement and FIs.
    This involves taking the profit motive one step further by applying
    the illegally obtained funds or assets to other crimes, such as:

    Money laundering through purchase of RE, most likely with cash,
    at inflated prices,

    Terrorist activities such as the purchase of terrorist safe
    houses and,

    Other illegal activities like prostitution, drug sales or use,
    counterfeiting, smuggling, false document production and
    resale, auto chop shops, etc.


    It is important to be aware of the different participants and
    transaction flows to understand the fraud schemes described in this
    paper.  This section provides background information on various
    participants and their roles in typical mortgage transactions.


    Common participants in a mortgage transaction include, but are not
    limited to:

    Buyer – a person acquiring the property,

    Seller – a person desiring to convert RE to cash or another
    type of asset,

    Real Estate Agent – an individual or firm that receives a
    commission for representing the buyer or seller, •
    Originator – a person or entity, such as a loan officer,
    broker, or correspondent, who assists a borrower with the loan

    Processor – an individual who orders and/or prepares items
    which will be included in the loan package,

    Appraiser – a person who prepares a written valuation of the

    Underwriter – an individual who reviews the loan package and
    makes the credit decision,

    Warehouse Lender – a short term lender for mortgage bankers
    that provides interim financing using the note as collateral
    until the mortgage is sold to a permanent investor, and

    Closing/Settlement Agent – a person who oversees the
    consummation of a mortgage transaction at which the note and
    other legal documents are signed and the loan proceeds are

    Refer to Appendix A – Glossary for additional and expanded
    definitions for participants and other terms used throughout this

    Mortgage Loan Purchased from a Correspondent – In this transaction,
    the borrower applies for and closes his loan with a correspondent of
    the FI, which can be a mortgage company, small depository
    institution, or finance company.  The correspondent closes the loan
    with internally generated funds in its own name or with funds
    borrowed from a warehouse lender.  Without the capacity or desire to
    hold the loan in its own portfolio, the correspondent sells the loan
    to an FI.  The purchasing FI is frequently not involved in the
    origination aspects of the transaction, and relies on the
    correspondent to perform these activities in compliance with the
    FI’s approved underwriting, documentation, and loan delivery
    standards.  The purchasing FI reviews the loan for quality prior to
    purchase.  The purchasing FI must also review the appraisal or AVM
    report and determine that it conforms to the appraisal regulation
    and is otherwise acceptable.  The loan can be booked in the FI’s own
    portfolio or sold.

    In “delegated underwriting” relationships, the FI grants approval to
    the correspondent to process, underwrite, and close loans according
    to the FI’s processing and underwriting requirements.  The FI is
    then committed to purchase those loans.  Obviously, proper due
    diligence, controls, approvals, QC audits, and ongoing monitoring
    are warranted for these higher risk relationships.

    Financial institutions that generate mortgage loans through
    correspondents should have adequate policies, procedures, and
    controls to address:  initial approval and annual re-certification,
    underwriting, pre-funding and QC reviews, repurchases, early
    prepayments, appraisals, quality and documentation monitoring,
    fraud, scorecards, timely delivery of loan packages, and utilization
    of contract underwriters.  In addition, FIs should have contractual
    agreements to demand and enforce repurchase proceedings and other
    disciplinary actions with correspondents delivering loans outside of
    product and other contractual agreements.

    There are a variety of mechanisms by which third party mortgage loan
    fraud can take place.  Various combinations of these mechanisms may be implemented in a single fraud.  Some of these mechanisms and
    their uses are described in this section.


    Collusion involves two or more individuals working in unison to
    implement a fraud.  Various third parties may conspire to perpetrate
    a fraud against an FI with each generally contributing to the plan.
    Each person performs his respective role and receives a portion of
    the illicit proceeds.  Often, but not always, third parties recruit
    or bribe FI employees to take part in the scheme.  The scheme may
    also include additional parties not involved in the planning or
    aware of all participants, but who are still part of the plan’s

    Documentation Misrepresentation

    Mortgage fraud is generally achieved using fictitious, forged, or
    altered documents needed to complete a transaction.  Pertinent
    information may also be omitted from documents.  The following
    describes some key documents and ways they can be altered to
    perpetrate fraud.

    Loan Application – The application captures information needed
    for an FI to make a credit decision based on the borrower’s
    qualifications such as financial capacity.  It may include
    false information regarding the identity of the buyer or
    seller, income, employment history, debts, or current occupancy
    of the property.  The information on the final application may
    have been altered and be materially different than that
    provided on the initial application.

    Appraisal – An appraisal is a written statement that should be
    independently and impartially prepared by a qualified
    practitioner setting forth an opinion of the market value of a
    specific property as of a certain date, supported by the
    presentation and analysis of relevant market information.  It
    is an integral component of the collateral evaluation portion
    of the credit underwriting process.

    An appraisal is fraudulent if the appraiser knowingly intends
    to defraud the lender and/or profits from the deception by
    receiving more than a normal appraisal fee.  This includes
    accepting a fee contingent on a foregone conclusion of value,
    or a guarantee for future business in response to the inflated
    value.  The appraiser may inflate comparable values or falsify
    the true condition of the property, which can allow the
    defrauder to obtain a larger loan than the property legitimately supports.  An appraisal that does not include
    negative factors affecting the property value can influence the
    FI to enter into a transaction that it normally would not
    approve.  The defrauder may use comparables that are outdated,
    fictitious, an unreasonable distance from the subject property,
    or materially different from the subject property.  Photos
    represented to be of the subject property may be of another
    property.  Inflated appraisal values create high loss potential
    and contribute to an FI’s losses at the time of foreclosure or

    Credit Report – This document contains an individual’s credit
    history which is used to analyze an individual’s repayment
    patterns and capacity.  Credit histories can be forged or
    altered through various methods to repair bad credit or create
    new credit histories.  Fraudsters can also use the credit
    report of an unknowing individual who has a good credit record.
    Perpetrators have been known to scan and alter illegally
    obtained legitimate credit reports that are then printed and
    used as originals.  Copiers can be similarly used to produce
    fictitious or altered credit reports.  Fraudsters have used
    computers to hack into credit bureau files and have purchased
    credit bureau computer access codes from persons who work for
    legitimate businesses.

    Alternate credit reference letters are often used for
    applicants with limited or no traditional credit history.  They
    are usually in the form of a letter directly from a business
    such as a utility, small appliance store, etc., to which the
    applicant is making regular payments.  These letters can be
    easily altered or completely fabricated using the business’s
    letterhead.  As lenders expand to provide loans to more diverse
    income levels, alternate credit references are becoming more

    Deed – A deed identifies the owner(s) of the property.  It can
    be altered to disguise the true property owner or the
    legitimate owner’s signature can be forged to execute a
    mortgage transaction.  Alteration or forgery of this document
    allows the fraudster to use a false identity to complete the

    Financial Information – This includes financial statements, tax
    returns, FI statements, and income information provided during
    the application process.  Any of this data can be falsified to
    enable the applicant to qualify for a mortgage loan.
    Inadequate income and employment verification procedures may
    allow mortgage loan fraudsters to deceive the FI regarding this information.  Some perpetrators have been known to set up phone
    banks to receive verification calls from FIs.

    HUD-1 Settlement Statement – The HUD-1 accompanies all
    residential RE transactions.  This is a statement of actual
    charges, adjustments, and cash due to the various parties in
    connection with the settlement.  Working alone or with
    accomplices this document can be altered to defraud the parties
    to the transaction.  Information on the original HUD-1 may show
    entities or persons not noted as lien holders but who still
    receive payoffs from seller’s funds.  These individuals may be
    deleted from the final HUD-1 that is available for review prior
    to loan closing.  This enables individuals involved in the
    fraudulent scheme to receive funds from the loan disbursement
    without the FI being aware of such payments.  The document may
    show a down payment when none was made.  The document may also
    include the borrower’s forged signature.

    Mortgage – A mortgage is a legal agreement that uses real
    property as collateral to secure payment of a debt.  In some
    locales a deed of trust is used instead.  A mortgage can be
    altered to disguise the true property owner, the legitimate
    lien holder, and/or the amount of the mortgage.  Alteration or
    forgery of this document allows the fraudster to obtain loan
    proceeds meant for another party or in an amount that exceeds
    the legitimate value of the property.

    Quitclaim Deed – This is a document used to transfer the named
    party’s interest in a property.  The transferring party does
    not guarantee that he has an ownership interest, only that he
    is conveying the interest to which he represents he is
    entitled.  Fraud perpetrators may use this document to quickly
    transfer property to straw or nominee borrowers without a
    proper title search.  Straw borrowers are discussed on page 17
    under Third Party Mortgage Fraud Schemes.  This technique can
    disguise the true property owner and allow the mortgage
    transaction to be completed quickly.

    Title Insurance/Opinion – Either of these documents confirms
    that the stated owner of the property has title to the property
    and has the right to transfer ownership of that property.  They
    identify gaps in the chain of title, liens, problems with the
    legal description of the property, judgments against the owner,
    etc.  Title insurance schedules or opinions can be altered to
    change the insured FI or omit prior liens.  This can be part of
    the falsification that occurs when a perpetrator attempts to
    obtain multiple loans from different FIs for one mortgage transaction.  Alteration of title insurance or opinions occurs
    in other fraud scenarios, as well.

    Identity Theft

    Identity theft means the theft of an individual’s personal
    identification and credit information, which is used to gain access
    to the victim’s credit facilities and FI accounts to take over the
    victim’s credit identity.  Perpetrators may commit identity theft to
    execute schemes using fake documents and false information to obtain
    mortgage loans.  These individuals obtain someone’s legitimate
    personal information through various means, i.e., obituaries, mail
    theft, pretext calling, employment or credit applications, computer
    hacking, and trash retrieval.  With this information, they are able
    to impersonate homebuyers and sellers using actual, verifiable
    identities that give the mortgage transactions the appearance of

    Mortgage Warehousing

    Mortgage warehousing lines of credit are used to temporarily
    “warehouse” individual mortgages until the mortgage banker, who may
    be acting as a broker, can sell a group of them to an FI.  If a
    dishonest mortgage banker has warehousing lines with two FIs, he can
    attempt to warehouse the same mortgage loan on each line.  The
    individual FIs may not be aware of the other’s line.  One FI may be
    presented with the original documents, while the delivery of the
    documents to the other FI is indefinitely delayed.  The second FI
    may fund the line without the documents if previous dealings with
    the mortgage banker have been satisfactory.  It is only after
    transferring funds that the second lender realizes it has been
    defrauded.  The Mortgage Electronic Registry System (MERS) can also
    be used as a valuable control tool.

    The mortgage warehouse lender often relies on the mortgage banker’s
    internal loan data regarding FICO, loan-to-value (LTV), debt-to-
    income (DTI), appraised value, credit grade and aging, making them
    vulnerable to fraud if the provided data is not accurate.  The
    mortgage warehouse lender should have proper procedures and controls
    to provide ongoing monitoring, verification, and audits of the loans
    under this line of credit.  It may also want to consider scorecards,
    due diligence, and customer identification policies and procedures.


    Negligence occurs when people who handle mortgage transactions are
    careless or inattentive to the accuracy and details of the documents
    or disregard established processing procedures.  This often happens
    when an FI is experiencing fast growth and uses temporary and part-time employees to process a large volume of mortgages without proper
    controls or oversight.  Inattention to detail provides perpetrators
    with the opportunity to submit documents containing fraudulent
    information with the probability that the fraud will not be
    detected.  Fraudsters may target FIs once they identify these


    The purpose of this section is to describe some of the most
    prevalent types of mortgage fraud that have resulted in significant
    losses to FIs.  Fraud schemes using one or more of the mechanisms
    described earlier are limited only by the imagination of the
    individuals who initiate them.  The following scenarios are not
    intended to be an all-inclusive list.  Specific examples for most of
    these schemes are detailed in Appendix C.

    Appraiser Fraud

    A person falsely represents himself as a State-licensed or State-
    certified appraiser.  Appraiser fraud also can occur when an
    appraiser falsifies information on an appraisal or falsely provides
    an inaccurate valuation on the appraisal with the intent to mislead
    a third party or FI.  Appraiser fraud is often an integral part of
    some fraud schemes.

    Double Selling

    Double selling is a scheme wherein a mortgage loan broker accepts a
    legitimate application, obtains legitimate documents from a buyer,
    and induces two FIs to each fully fund the loan.  In this scenario,
    the originator leads each FI to believe that the broker internally
    funded the loan for a short period.  Since there is only one set of
    documents, one of the funding FIs is led to believe that the proper
    documentation will arrive any day.  Double selling is self-
    perpetuating because different loans must be substituted for the
    ones on which documents cannot be provided to keep the scheme going.
    Essentially, the broker uses a lapping scheme to avoid detection.

    Another variation of double selling entails a mortgage loan broker
    accepting a legitimate application and proper documentation, who
    then copies the loan file, and presents both sets of documents to
    two investors for funding.  Under this scheme, the broker has to
    make payments to the investor who received the copied documents or
    first payment default occurs.

    False Down Payment

    Another third party mortgage fraud involves false down payments.  In
    this scenario, a borrower colludes with a third party, such as a
    broker, closing agent, etc., to reflect an artificial down payment.
    When this scheme is carried out with collusion by an appraiser, the
    true loan-to-value greatly exceeds 100% and has the potential to
    cause substantial loss to the FI.

    Fictitious Mortgage Loan

    A fictitious mortgage loan scheme is perpetrated primarily by
    mortgage brokers, closing agents, and/or appraisers.  In one version
    of this scheme, the identity of an unsuspecting person is assumed in order to acquire property from a legitimate seller.  The broker
    persuades a friend or relative to allow the broker to use the
    friend’s or relative’s personal credit information to obtain a loan.
    The FI is left with a property on which it must foreclose and the
    third parties pocket substantial fees from both the FI and buyer.
    Straw Borrower

    The straw borrower scheme involves the intentional disguising of the
    true beneficiary of the loan proceeds.  The “straw”, sometimes known
    as a nominee, may be used to:

    conceal a questionable transaction,

    replace a legitimate borrower who may not qualify for the
    mortgage or intend to occupy the property, or

    circumvent applicable lending limit regulations by applying for
    and receiving credit on behalf of a third party who may not
    qualify or want to be contractually obligated for the debt.

    The straw borrower scheme is accomplished by enticing an individual,
    sometimes a friend or relative, to apply for credit in his own name
    and immediately remit the proceeds to the true beneficiary.  The
    straw borrower may feel there is nothing wrong with this and fully
    believes that he is helping the third party.  He expects the
    recipient of the loan proceeds to make the loan payments, either
    directly or indirectly.  The recipient may be unable to or may never
    intend to make the payment.  Over time, default would occur with the
    FI initiating foreclosure proceedings.  This scheme can involve FI
    personnel, as well as other third party participants.  The straw
    borrower may or may not be paid a fee for his involvement or know
    the full extent of the scheme.

    In summary, millions of dollars have been lost because of the
    mortgage fraud schemes described above.  These schemes produce many
    indicators that are apparent to an educated observer.  The next
    section identifies these red flags and provides best practices that
    FIs can use to mitigate risk of loss.


    Prudent risk management practices for third-party originated loans
    are critical.  Strong detective and preventive controls are an
    integral part of a sound oversight framework, including adequate
    knowledge of the FI’s customers.  Knowledgeable, trained employees,
    coupled with disciplined underwriting and proactive prevention
    controls, are an FI’s best deterrent to fraud.  Implementation of
    strong controls does not prevent human errors or oversight failures,
    but documentary evidence of QC measures taken by the FI can be a
    useful defense against a repurchase request from an investor.

    As a part of the exam process, examiners should assess actions taken
    by the FI to document its controls over internal fraud, relative to
    safe and sound FI practices and individual agency regulatory requirements.  Examiners should also include Patriot Act and SAR
    requirements in their evaluations.

    The following list of red flags3, which is not intended to be all-
    inclusive, may be used to identify and deter misrepresentations or
    fraud.  Other automated systems for fraud detection, if used in
    conjunction with this list, are dependent on the quality of the
    input and analysis of the output.  The presence of any of these red
    flags DOES NOT necessarily indicate that a misrepresentation or
    fraud has occurred, only that further research may be necessary.


    Congress enacted Title XI of the Financial Institutions, Reform,
    Recovery and Enforcement Act of 1989 (FIRREA) requiring member
    agencies of Federal Financial Institutions Examination Council
    (FFIEC) to issue RE appraisal regulations to address problems
    involving faulty and fraudulent appraisals.  One of the cornerstones
    of the regulation was a requirement that a regulated financial
    institution or its representative select, order, and engage
    appraisers for federally related transactions to ensure
    independence.  The agencies’ expectations on this subject are stated
    in an interagency statement dated October 27, 2003 entitled
    Interagency Appraisal and Evaluation Functions.  This statement
    provides clarification of the various agencies’ appraisal and RE
    lending regulations and should be reviewed in conjunction with them.

    Specifically, the October 2003 statement primarily addresses the
    need for appraiser independence.  A regulated institution is
    expected to have board approved policies and procedures that provide
    for an effective, independent RE appraisal and evaluation program.
    Basic elements of independence are discussed such as separation of
    the function from loan production and engagement of the appraiser by
    the institution, not the borrower.  A written engagement letter is
    encouraged.  An effective internal control structure is also
    necessary to ensure compliance with the agencies’ regulations and
    guidelines.  This includes a review process provided by qualified,
    trained individuals not involved with loan production.  The depth of
    review should be based on the size, complexity, and other risk
    factors attributable to the transactions under review.  For the full
    text of the October 27, 2003 statement please refer to Appendix G.


    From the attached amended complaint.
    That Deed of Trust (“DOT”) contained a false representation on its face when it represented that Defendant MERS was a beneficiary under the DOT. Paragraph (E) States that “MERS is a separate corporation that is acting solely as a Nominee for Lender and Lender’s successors and assigns. MERS is the beneficiary under this Security Instrument.” As will be demonstrated below, MERS is NOT the beneficiary under the DOT, it never had ownership or possession of the Promissory Note which is the obligation which is secured by the DOT, and MERS has never been entitled to receive one cent of remuneration from Mr. Buse’s loan proceeds.The statement that MERS is the nominee is nonsensical language which means nothing in a real estate transaction and most certainly, MERS has never been nor is it now the beneficiary under the DOT.  The language is a sham.

    From MERS explained by Aurora Lawyers, Bold emphasis are my highlights.

    A. The Residential Mortgage Market and Function of MERS
    When a mortgage lender loans money to a home buyer, it obtains a promissory note in the form of a negotiable instrument from the borrower, as well as a mortgage instrument in the form of a deed of trust which is recorded in the county official records. The lender often does not continue to hold the note. Instead, the lender sells the note into the secondary mortgage market, most often to one of the government or government-sponsored entities created by statute to purchase residential mortgage loans from banks and other lenders. See 12 U.S.C. §§ 1451-59, 1716-23 et seq. (creating the Government National Mortgage Association (“Ginnie Mae”), Federal National Mortgage Association (“Fannie Mae”), and Federal Home Loan Mortgage Corporation (“Freddie Mac”)). In turn, these entities re-sell the notes into a tertiary mortgage backed securities market, usually as part of a bundle of notes held in trust for investors. As a result, the notes are held for the benefit of numerous people simultaneously, whose identities change as these negotiable instruments are sold and resold in these markets, and as the investors sell and re-sell their shares in the mortgage-backed securities.
    Because of the secondary and tertiary mortgage markets, the original lender is then able to make the funds from the first sale of the note available to additional home buyers. The availability of these funds is the specific and intended result of the statutes that created the government and government sponsored entities – to increase funds for home ownership in the
    United States. See 12 U.S.C. §§ 1451, 1716.
    MERSCORP, Inc. and MERS were companies formed to play an integral part in the federally established free-market system created to increase liquidity in the market for home loans. In 1993, the Mortgage Bankers Association, Ginnie Mae, Fannie Mae, Freddie Mac and others in the real estate finance industry created an electronic registration and tracking system that is similar to the process used with great success by the Depository Trust Company for the securities industry. MERSCORP, Inc. was formed to track both beneficial ownership interests
    in, and servicing rights to, mortgage loans as they change hands throughout the life of the loan.
    This tracking assists the mortgage banking industry by reducing questions regarding these contractual interests as they are bundled into mortgage-backed securities. In this manner, MERSCORP, Inc. facilitates liquidity in the secondary mortgage markets. MERS serves as the mortgagee or beneficiary for the MERS member lender.
    Upon the purchase of a home, the borrower signs a loan contract that names MERS as the beneficiary (as “nominee” for the lender and its successors and assigns as here). In the loan contract, the borrower assigns his or her right, title, and interest in the property to MERS. The borrower contractually agrees that, in the event of default, MERS is a proper party to foreclose on the home. The mortgage or deed of trust with MERS as a named beneficiary is recorded. When the note is sold by the original lender to others, the sales of the notes are tracked on the MERS® System. As long as the sale of the note involves a member of MERS, MERS remains a named mortgagee or beneficiary of record and continues to act as a nominee for the new holder.
    This relationship is memorialized in the original mortgage or deed of trust to which the borrower is a party. If a member is no longer involved upon sale, an assignment from MERS to the non MERS member is made, executed and recorded in the county where the real estate is located, and the loan is “de-activated” from the MERS® System.

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