US TRUSTEES ATTACKING PRETENDER LENDER STANDING IN MLS

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

In his experience, Mr. Shaev said: “The attorneys who represent the banks invariably state that they will get the collateral file for us and prove that the banks had possession of the documents at the appropriate time. But then when we review the file it doesn’t show that at all.”

“The Central Question rising to the surface and now unavoidable is whether a party claiming to be a secured creditor would prevail if there was a normal adversary hearing on the merits where the normal rules of evidence apply” — Neil F Garfield

EDITOR’S NOTE:  In bankruptcy courts across the country, pretender lenders have been able to rely upon an unwritten code wherein a motion to lift stay (MLS) filed by a secured creditor would be unopposed by the trustee. The pretender lender would not only be free to continue with judicial or nonjudicial foreclosure and sale, they would also have the appearance of a court order  apparently confirming their right to foreclose.

When I first broached the subject with various US trustees around the country in 2007 and 2008 they were extremely skeptical. I proposed a business model to them which would provide the protection to the debtor that was intended by the Constitution and the statutes governing the substance of bankruptcy petitions.  I showed them that the US trustee, the attorney for the US trustee, the creditors, and the attorney for the debtor would all be able to share in a larger estate and thus earned more fees than was currently the case where a home was in foreclosure.

It was my opinion then and it is my opinion now that not only do the pretender lenders lack standing to pursue a foreclosure, but that there does not appear to be any credible party in the securitization chain who would possess such standing. It was my opinion that the participants in the securitization scheme had hopelessly obscured the obligation and split the obligation from the note and mortgage as well as splitting the note from the mortgage.

Thus while the obligation clearly exists, subject to offsets and counterclaims, there is no law or legal theory under which the obligation was in fact secured. The US trustees in bankruptcy were not only skeptical, they were actually opposed to my plan because they did not want to be part of any procedure by which a borrower abused the judicial process in order to gain a windfall or undue advantage.

In a major change of policy, US trustees in bankruptcy court are now challenging the standing and viability of the claims made by the pretender lenders. The premise was that if a lawyer came to bankruptcy court claiming to represent a lender that was secured by a mortgage on the property it was presumed that the representation to the court was true. As we have seen in various news reports there are good reasons to question whether the attorney represents anyone, whether any of the parties to whom the attorney refers is an actual creditor, and whether the claim is secured by a mortgage on the home.

The wrongful foreclosure damage actions are giving pause to everyone involved in the closing of these deals and in the processing of the “foreclosures.” Invariably, the old trustee on a deed of trust is substituted with one with whom the pretender lender has an ‘arrangement” concerning going forward, regardless of the obstacles.

The employment of  intermediaries used to obscure the fraud in the sale of the bogus mortgage bonds and the bogus mortgage loans are the business model for the employment of intermediaries used to obscure the fraud on the court in foreclosures.

These intermediaries — originators, brokers, title agents, escrow agents, appraisers, trustees, and foreclosure companies are all in the cross hairs of lawyers across the country who are suing for individual or class action relief. Any party moving forward at this point can be held to the “knew or should have known” status required for a fraudulent foreclosure or slander of title action. If it is negligence, there might be insurance coverage. If it is viewed as an intentional act of fraud, the insurer for errors and omissions might decline coverage for even the defense of the action.

The megabanks have intentionally and in so many words set up various “bankruptcy remote” vehicles that are intended to insulate them from liability in case this thing explodes in their faces. They wish to protect their claim of plausible deniability and point the finger at the actual people who got the hands dirty — as the recent closing of  David Stern’s office in Florida demonstrates. These remote vehicles are submitting credit bids at auction which are by all accounts not only illegal, but void.

Any issuance of a title document reflecting a “credit bid” is essentially a “wild deed,” — i.e., one that can and would be ignored by a title examiner. This leads to the inevitable conclusion that nearly all REO property is still legally owned by the homeowners who believe their home was foreclosed and sold.

The central question that is gradually rising to the surface is simply whether or not a party claiming to be a creditor could sustain its burden of proof in a normal evidentiary hearing. The presumptions that were used before the securitization of residential mortgage loans made sense when the transaction lacked the complexity and duplicity inherent in the scheme of securitization as it was practiced by Wall Street. It is now apparent to many judges, many lawyers, many people in the media, many homeowners, and now US trustees in bankruptcy, that the old presumptions do not apply.

In plain language, the parties claiming to be creditors are not creditors, because the bankruptcy estate does not owe them any money. The same is true in federal and state civil court. The mega banks took advantage of their appearance of propriety and the old presumptions and made the judicial system of vehicle for fraudulent conveyances. The resulting chaos in the chain of title, claims under title insurance, and the inability to obtain a satisfaction of mortgage from a party that is authorized to execute it is the major challenge confronting the legal system.

This has thrust an enormous burden on the offices of the  property appraiser and County recorder across the country. 66 million transactions involving “wild deeds” are now in the chains of title in tens of millions of homes.

The resolution to this crisis is obvious even if it is odious. It has happened in the past that title records have been corrupted beyond repair. It becomes necessary to push a figurative “reset” button with a window of opportunity for those affected to present their claims in a manner required by the court and the legislature of each state. It is in this process that the homeowners will receive an opportunity to obtain some relief while the investors who advanced the funds for the loans recover as much as possible.

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November 27, 2010

Don’t Just Tell Us. Show Us That You Can Foreclose.

SYSTEMIC CHANGE NEEDED

By GRETCHEN MORGENSON

NY TIMES

AFTER examining their foreclosure practices for flaws in mortgage documentation and other procedures, many of the nation’s largest banks have resumed — or will soon resume — trying to evict defaulted borrowers.

JPMorgan Chase, for example, told investors this month that it had extensively reviewed its foreclosure controls, trained personnel in the unit and started new procedures to ensure that all legal requirements would be met when it moves to seize a property in default.

“If we find any foreclosures in error, we will fix them,” JPMorgan Chase said.

But while banks may have booted a few robo-signers and tightened up some lax procedures, one question at the heart of the foreclosure mess refuses to go away: whether institutions trying to take back a property can prove they even have the right to foreclose at all.

Some in the industry believe that questions about this issue — known as “legal standing” — are trivial. They say it’s just a gambit by borrowers’ lawyers to throw sand in the foreclosure machine. Nine times out of 10, bankers say, the right institutions are foreclosing on the right borrowers.

Maybe so. But the United States Trustee Program, the unit of the Justice Department charged with overseeing the integrity of the nation’s bankruptcy courts, is taking a different view. The unit is stepping up its scrutiny of the veracity of banks’ claims against borrowers, and its approach is evident in two cases in federal bankruptcy court in Atlanta.

In both cases, Donald F. Walton, the United States trustee for the region, has intervened, filing motions contending that the banks trying to foreclose have not shown they have the right to do so.

The matters involve borrowers operating under Chapter 13 bankruptcy plans overseen by the court in the Northern District of Georgia. In both cases, the banks have filed motions with the bankruptcy court to remove the automatic foreclosure stay that results when a court confirms a debtor’s Chapter 13 repayment plan. If the stay is removed, the banks can foreclose.

In one case, the borrower had her Chapter 13 plan confirmed by the court early last month. About two weeks later, Wells Fargo asked the court for relief from the stay so that it could foreclose.

Responding on Nov. 16, Mr. Walton asked the court to deny the bank’s request because it had failed to produce any facts showing that it was entitled to foreclose — either as the holder of the underlying note or as the agent for the holder.

The other case involves a couple who had their Chapter 13 plan confirmed by the court in March 2009. A month ago, Chase Home Finance, a unit of JPMorgan Chase, asked the court for relief from the automatic stay so that it could start foreclosure proceedings.

Again, Mr. Walton objected, asking the court to deny the request on the same grounds as argued in the Wells Fargo matter — in this case, that Chase hadn’t proved that it controlled the note on the property.

Jane Limprecht, a spokeswoman for the trustee program, confirmed that it was ratcheting up its scrutiny on banks’ foreclosure practices.

“The United States Trustee Program is engaged in an enhanced review of mortgage servicer filings in bankruptcy cases to help ensure the accuracy of the claim to repayment,” she said. She declined to comment on specific filings.

A Chase spokesman said the bank is the holder of the note in the Georgia case, giving it standing to file the motion.

A spokeswoman for Wells Fargo said that in its case, it is the trustee of a mortgage security that contains the loan, not the servicer. In its capacity as the trustee for mortgage loans serviced by others, it says it expects those servicers to abide by all required laws, processes and procedures.

Howard D. Rothbloom, a lawyer in Atlanta who represents borrowers in bankruptcy, welcomed the actions by Mr. Walton and said he believes they show a sea change in the United States trustee’s thinking on the foreclosure mess.

“Until now, what we had was homeowners complaining about a lack of due process,” Mr. Rothbloom said. “Now you have the federal government complaining about the abuse of the judicial process. That’s really what was missing before.”

The judges overseeing these matters have not yet ruled on the banks’ or the trustee’s requests. And Wells Fargo and Chase may indeed be able to persuade the trustee that their filings were proper.

But the trustee’s intervention in these matters indicates that it wants banks to show the courts that they have the right to foreclose, rather than simply telling them they do. That had been the custom, after all. Now, Mr. Walton’s motions may serve as a warning to banks that they need to be better prepared if they want to foreclose on a borrower.

“For years, the trustee would always take the creditors’ side,” Mr. Rothbloom said. “My strong opinion is the U.S. trustee’s perspective is that they exist to stop borrowers from cheating banks. Perhaps they are coming to the realization that banks can also cheat borrowers.”

FEDERAL trustees in other parts of the country have also intervened in borrower cases, but many of these actions have been related to questionable foreclosure fees or to dubious legal or documentation practices. The shift to a broader focus on the issue of standing suggests that the courts may no longer accept at face value the banks’ arguments that they have the right to foreclose or represent the institution that does.

David Shaev, a lawyer in New York who works with troubled borrowers, says the United States trustee there has also intervened in one of his cases, taking up the issue of a bank’s right to foreclose.

In his experience, Mr. Shaev said: “The attorneys who represent the banks invariably state that they will get the collateral file for us and prove that the banks had possession of the documents at the appropriate time. But then when we review the file it doesn’t show that at all.”

As many large banks renew their foreclosure efforts, Mr. Rothbloom says he hopes that the United States trustee will bring about a comprehensive change in bank practices.

“I’ve gotten resolutions for clients in individual cases, but I’m just a flea on the tail of an elephant,” he said. “Resolutions of individual cases don’t bring about systemic change.”

And systemic change is precisely what’s needed.

Jury Demand: Should You or Shouldn’t You

Since this question keeps popping up I figured I would take a shot at it.

The theory is that by asking for a jury verdict you are taking the matter out of the hands of a politicized judge and putting it in the hands of what is likely to be a very angry jury pool itching to whack the Wall Street players. I think that’s right, theoretically.

My problem with the theory is that in practice I don’t see much mileage in it. These cases don’t seem to EVER get to trial which is the only place a jury will hear anything. In the meantime you still have the the same politicized judge making all the preliminary rulings about whether your case will survive, much less get to trial.

The other problem I have with the Jury Demand is that you only have a right to trial by jury on money damages, not equitable relief, like an injunction or some mandate against the players. So the jury demand won’t have much effect on the main issue: whether the foreclosure is right or wrong and whether the money is owed and if so to whom, and whether the party seeking to foreclose has any right to do so.

And the last problem I have with it is the issue of bifurcation. If you ask for a jury trial the Judge might split the case into two cases — first the case involving the legality of the foreclosure and second, the damage case that will go to the jury. This creates the appearance that the Judge is “protecting” your right to be heard on your claims while “protecting” a secured creditor (who is neither a creditor nor secured) from further losses on a “legitimate” obligation.

So obviously I think that a jury demand takes the focus off whether the party you are fighting is a creditor, has standing or is just trying to steal the property. But I could be wrong. This isn’t a legal opinion, it is just a knee-jerk reaction.

Foreclosure Defense: SEC Rules on Lost Documents

Based upon the following, and assuming that the the entire single transaction from sale of the ABS to “sale” of the loan to the borrower consists of a basket of securities, some of which should have been registered, had a prospectus, right to rescind, etc., and based upon the disclosure requirements of public companies who have interests in SPVs and SIVs that supposedly have documents that now appear to be lost, destroyed or otherwise unavailable, this would be another persuasive argument to any judge that something is fishy and that the party seeking to foreclose, or who is seeking relief from automatic stay in bankruptcy, might not have the standing or authority to represent anyone with standing.

I REMAIN CONVINCED THAT MORTGAGES AND NOTES THAT WERE EXECUTED BETWEEN 2001 AND 2008 SHOULD NOT BE LISTED AS SECURED CREDITORS WITH LIQUIDATED AMOUNTS OWED AND THAT “JOHN DOE” SHOULD BE NAMED AS THE PARTY OR GROUP THAT HAS AN INTEREST IN THE NOTE AND MORTGAGE, SUBJECT TO THE RESCISSION BY THE BORROWER WHICH ELIMINATES THE SECURITY IF RESPA RULES ARE FOLLOWED.

(2) Missing or lost securities. Every reporting institution shall report to the 
Commission or its designee, and to a registered transfer agent for the issue, the 
discovery of the loss of any securities certificate where criminal actions are not 
suspected when the securities certificate has been missing or lost for a period of 
two business days. Such report shall be made within one business day of the end of 
such period except that:
(i) Securities certificates lost in transit to customers, transfer agents, banks, 
brokers or dealers shall be reported by the delivering institution by the later of 
two business days after notice of non-receipt or as soon after such notice as the 
certificate numbers of the securities can be ascertained. 

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