Friday, May 6, 2016

FYI: CFPB's Proposed Arbitration Rule Designed to Protect Consumer Financial Services Class Actions

The Consumer Financial Protection Bureau released a notice of proposed rule with request for public comment to prohibit creditors from using arbitration clauses to block class action litigation.

 

The CFPB's proposed ban is not surprising.  However, it will only impact arbitration agreements concerning covered consumer financial products or services entered into after its effective date.

 

A copy of the NPRM is available at:  Proposed rule with request for public comment

 

 

Arbitration Clauses and Class Action Waivers

 

Arbitration is an effective means for consumers to vindicate their claims in an informal setting. Through the informal setting of arbitration, consumers are not restricted by court rules of evidence and procedure that could otherwise limit or even prevent the assertion of particular claims or the use of certain evidence in a court proceeding.  This provides consumer litigants with a significant advantage over their creditors.

But creditors ask a concession for giving up the protections they receive in civil courts. Arbitration agreements prohibit a consumer from asserting class action claims.

 

Favoring Class Actions Over Innovation

 

The Bureau's rationale for the proposed ban is largely based on its finding that class actions "better enable consumers to enforce their rights under Federal and State consumer protection laws and the common law and obtain redress when their rights are violated." The Bureau also notes it believes the threat of class action litigation increases a company's costs for compliance and causes companies to forgo potentially profitable initiatives because they may increase the risk of class action liability. At the same time, this may also reduce innovation in financial products and services, but the loss of these new and useful products and services, the Bureau concludes, is outweighed by the benefits to consumers from class action litigation.

 

Who and What Would Be Covered

 

The proposed rule would cover a multitude of entities that provide consumer financial products or services. Among the covered parties are entities that provide extensions of consumer credit, act as consumer creditors or participate in a consumer credit decision. It would encompass debt collectors under the federal Fair Debt Collection Practices Act (FDCPA) as well as others collecting consumer debt who are not debt collectors under the FDCPA. And it covers persons who purchase or acquire consumer debt. This list is not exhaustive and the proposed rule does cover other persons not listed here. In addition, it also provides limited exemptions for certain persons, products and services. Most notable, the rule exempts the federal government and "any affiliate of the Federal government" when providing a consumer financial product or service directly to consumers.

 

What It Would Prohibit

 

The proposed rule would not ban arbitration of disputes over consumer financial products and services. It would prohibit the use of arbitration agreements to dismiss or stay a class action concerning a covered product or service. However, it does permit disputes to head to arbitration once a court has ruled that a claim may not proceed as a class action and any right to appeal the court's ruling has expired.

 

Proposed Required Disclosures and Arbitration Agreement Terms

 

If a covered person uses an arbitration agreement in a covered transaction, the agreement must contain one of two mandatory disclosures.

 

When the arbitration agreement covers only particular consumer credit products or services that are covered by the proposed rule, it must state:  "We agree that neither we nor anyone else will use this agreement to stop you from being part of a class action case in court. You may file a class action in court or you may be a member of a class action even if you do not file it."

 

As noted above, a few products and services are not covered, like business loans. When the arbitration agreement concerns both covered and not covered products or services, the following disclosure may be used: "We are providing you with more than one product or service, only some of which are covered by the Arbitration Agreements Rule issued by the Consumer Financial Protection Bureau. We agree that neither we nor anyone else will use this agreement to stop you from being part of a class action case in court. You may file a class action in court or you may be a member of a class action even if you do not file it. This provision applies only to class action claims concerning the products or services covered by that Rule."

 

If a consumer credit product or service was subject to an arbitration agreement "between other parties" and did not contain one of the previously outlined proposed mandatory disclosures, the proposed rule would require either an amendment of the arbitration agreement using language mandated by the proposed rule or that a mandatory notice be given to the consumer.

 

Record Keeping and Provision of Information to the Bureau

 

Covered providers who submit claims to arbitration or have claims against them submitted to arbitration will be required to provide the Bureau with particular documents and information concerning those claims. If the claim was filed by the covered person, then the information and documents must be provided to the Bureau within 60 days of the filing of the arbitration or of any "record" filed by the covered person. Otherwise, for claims filed against the covered person, the documents and information must be provided within 60 days of the covered person's receipt of the record.

 

The information and documents proposed by the rule are:  (1) the initial claim and any counterclaim; (2) the arbitration agreement filed with the arbitrator or arbitration administrator; (3) the judgment or award, if any, issued by the arbitrator or arbitration administrator; and (4) if an arbitrator or arbitration administrator declines to administer the arbitration or dismisses it because of the covered person's failure to pay arbitration filing or administration fees, then covered persons will be required to provide the Bureau with "any communication the provider receives from the arbitrator or an arbitration administrator related to such a refusal."

 

Finally, it would require covered persons to provide the Bureau with "any communication the provider receives from an arbitrator or an arbitration administrator related to a determination that a pre-dispute arbitration agreement for a consumer financial product or service . . . does not comply with the administrator's fairness principles, rules, or similar requirements, if such a determination occurs."

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Tuesday, May 3, 2016

FYI: Fla App Ct (5th DCA) Reverses Dismissal of Foreclosure on "Substantial Compliance of Notice of Default" and "Admissibility of Prior Servicer Records" Issues

The District Court of Appeal of Florida, Fifth District, recently held that the trial court erred in ruling that a mortgagee failed to comply with the pre-foreclosure notice requirements of the mortgage, as the mortgagee's default notice substantially complied with the mortgage and did not prejudice the borrower.

 

The Court also held that testimony by the current loan servicer's employee with regard to a prior loan servicer's business records established sufficient foundation for the prior servicer's records to be admitted into evidence as business records under Florida law.

 

A copy of the opinion is available at:  Link to Opinion

 

In July 2006, the borrower executed a promissory note and accompanying mortgage for $187,000.  She defaulted on the mortgage beginning in August 2009.  In May 2010, the mortgagee filed a complaint to foreclose, and the case proceeded to a non-jury trial in September 2014.

 

At trial, an employee of the loan servicer testified for the mortgagee regarding various records it obtained from the prior loan servicer, including a foreclosure referral document and loan payment history.  Despite the employee's testimony, the trial court sustained the borrower's objections, finding that the employee failed to establish a proper foundation for the records' admissibility under the business records exception to the hearsay rule.  See § 90.803(6), Fla. Stat.  The trial court explained that the business records exception "was based upon a party's own records, not someone else's records."

 

Although the trial court excluded these records, it admitted a notice of default and intent to accelerate sent by the prior servicer in November 2009. The default letter provided, in relevant part:

 

You may, if required by law or your loan documents, have the right to cure the default after the acceleration of the mortgage payments and prior to the foreclosure sale of your property if all amounts past due are paid within the time permitted by law. However, BAC Home Loans Servicing, LP and the Noteholder shall be entitled to collect all fees and costs incurred by BAC Home Loans Servicing, LP and the Noteholder in pursuing any of their remedies, including but not limited to reasonable attorney's fees, to full extent permitted by law. Further, you may have the right to bring a court action to assert the non-existence of a default or any other defense you may have to acceleration and foreclosure.

 

After the mortgagee rested its case, the borrower moved for an involuntary dismissal, arguing the default letter failed to comply with paragraph 22 of the mortgage.

 

As you may recall, Paragraph 22 of the Fannie Mae/Freddie Mac Uniform Security Instrument provides, in pertinent part, that the default letter shall specify:

 

(a) the default, (b) the action required to cure the default, (c) a date, not less than 30 days from the date the notice is given to Borrower, by which the default must be cured, and (d) that failure to cure the default on or before the date specified in the notice may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. The notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non existence of a default or any other defense of Borrower to acceleration and foreclosure.

 

The borrower argued that, because the default letter stated the borrower would have to file an action to stop foreclosure, rather than raising any defenses in the mortgagee's foreclosure case, it supposedly did not properly inform the borrower of her rights with respect to foreclosure. The trial court agreed and granted the borrower's request for involuntary dismissal.

 

The Fifth District reversed on appeal.  The Appellate Court ruled that the prior servicer's default letter substantially complied paragraph 22 of the mortgage and caused no prejudice to the borrower.

 

Additionally, the Fifth District agreed with the mortgagee that the trial court erred by excluding various records obtained from the prior servicer. 

 

In a prior ruling, the Appellate Court held that a current servicer can establish a proper foundation for admission of a prior servicer's records "so long as all the requirements of the business records exception are satisfied, the witness can testify that the successor business relies upon those records, and the circumstances indicate the records are trustworthy." Berdecia, 169 So. 3d at 216 (citing Le v. U.S. Bank, 165 So. 3d 776 (Fla. 5th DCA 2015); Calloway, 157 So. 3d at 1074)).  Following this prior ruling, the Fifth District here held that the trial court abused its discretion by excluding business records obtained from the prior servicer.

 

Thus, the Fifth District reversed the trial court's entry of involuntary dismissal and remanded for a new trial.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email:
rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Monday, May 2, 2016

FYI: 4th Cir Confirms Sale Orders in Prior Bankruptcy Precluded Debtors Later Claims

The U.S. Court of Appeals for the Fourth Circuit recently affirmed the dismissal of a borrower's lawsuit against a bank, holding that the district court correctly found that sale orders entered in a prior bankruptcy case were res judicata and precluded the borrower's new claims.

 

A copy of the opinion is available at:  Link to Opinion

 

A Virginia-based limited partnership owned real property in several states, and entered into a line of credit and loan secured by deeds of trust or mortgages. The borrower defaulted and filed for bankruptcy protection under Chapter 11 of the U.S. Bankruptcy Code.

 

The bank filed a proof of claim, to which the debtor objected and filed an adversary complaint, which was later amended. The amended complaint alleged that the bank misrepresented that it would forego suing on the credit line, which caused the debtor to default and file bankruptcy.

 

The U.S. Trustee moved to convert the case to Chapter 7 or to dismiss based on the debtor's failure to file monthly financial reports. The bank joined the motion, arguing that the debtor had also improperly used the bank's cash collateral to pay "distributions" to its principals.

 

The bankruptcy judge appointed a Chapter 11 trustee instead of converting the case to a Chapter 7 proceeding or dismissing the case.

 

The Chapter 11 trustee obtained the bankruptcy court's approval to sell two of the debtor's properties to satisfy the debt owed to the bank. He also consented to the dismissal of the debtor's adversary complaint without prejudice.

 

More than one year later, the debtor sued in Virginia state court and the bank removed the case to federal court. The complaint repeated the claims raised in the prior adversary complaint and alleged the bank was liable because the interest rate swap transaction was a "sham" because the LIBOR rate was illegally manipulated or "rigged."

 

The bank moved to dismiss and the district court granted the motion, reasoning that the bankruptcy court's two sale orders were preclusive on the basis of res judicata. The debtor appealed.

 

On appeal, the Fourth Circuit explained that "[u]nder the doctrine of res judicata, or claim preclusion, '[a] final judgment on the merits of an action precludes the parties or their privies from relitigating issues that were or could have been raised in that action.' … Three elements must be satisfied for res judicata to apply. '[T]here must be: (1) a final judgment on the merits in a prior suit; (2) an identity of the cause of action in both the earlier and the later suit; and (3) an identity of the parties or their privies in the two suits.'"

 

In addition, the Court explained, there are two practical considerations: first "whether the party or its privy knew or should have known of its claims at the time of the first action"; and second, "whether the court that ruled in the first suit was an effective forum to litigate the relevant claims."

 

As to the first res judicata prong — whether the sale orders were final orders — the Fourth Circuit relied on decisions from the Fifth, Sixth and Seventh Circuits to find that the bankruptcy sale orders were orders or judgments on the merits.

 

The Court rejected the debtor's argument that the cases relied upon by the district court were distinguishable because the debtors never objected to the sale orders or the creditor's claim in the bankruptcy court, unlike [the debtor in the case at bar] which objected to [the bank's] proof of claim" because, as the Fifth Circuit held in the Baudoin case, "sale orders 'are final judgments on the merits for res judicata purposes, even though the order neither closes the bankruptcy case nor disposes of any claim.'… It is irrelevant whether an objection was made."

 

The Fourth Circuit also rejected the debtor's argument that its claims were unrelated to the sale proceedings, while in the Seventh Circuit's Met-L-Wood case, the trustee alleged fraud surrounding the sale, reasoning that the distinction was "not a meaningful one."

 

"To sell  bankruptcy estate assets outside the ordinary course of business, the trustee of the estate or the debtor-in-possession must initiate the sale proceeding. … Here, the trustee moved to sell property in satisfaction of specifically identified obligations arising out of [the debtor's] transactions with [the bank]. The bankruptcy court approved these sales, finding them to be 'in the best interests of the Estate.' … It would make little sense after the sales were made, the debt settled, and the bankruptcy proceeding closed, to then allow [the debtor] to challenge in a new judicial proceeding the propriety of the transactions giving rise to its now-extinguished debt. To allow such a challenge would achieve little more than upending the purpose of res judicata: promoting finality and judicial economy."

 

The Court also found that "the preclusive effect of the bankruptcy court's sale orders is consistent with the 'fundamental purpose' of Chapter 11 bankruptcy: 'rehabilitation of the debtor.' … To fulfill this objective, '[c]entralizaiton of disputes concerning a debtors legal obligations is especially critical' because it allows 'reorganization [to] proceed efficiently, unimpeded by uncoordinated proceedings in other arenas.'"

 

Rejecting as unpersuasive the debtor's arguments that it should "break ranks with our sister circuits and hold that the sale orders fail to satisfy the first prong of res judicata", the Fourth Circuit found: (a) the fact that the adversary proceeding was dismissed without prejudice was irrelevant because "the sale orders are what preclude the claims now before the court"; (b) res judicata bars personal lender liability claims even though the bankruptcy sale order is an in rem proceeding; (c) because the bankruptcy trustee "could have litigated the extent of [the debtor's] obligations to [the bank] rather than move to sell estate property in satisfaction of those obligations, and … [the debtor's] present claims are transactionally related to the facts underlying the sale orders … [t]his gives rise to the preclusion of [the debtor's] present claims."

 

Turning to the second prong of res judicata—"an identity of claims between the first and second suit"—the Court explained that it follows the "transactional approach" which means "that 'res judicata will bar a newly articulated claim' if it is based on the same underlying transaction [involved in the first suit] and could have been brought in the earlier action.'"

 

The Fourth Circuit found the second prong was satisfied because the sale orders arose out of the same facts as the debtor's claims in the case at bar, i.e., the loan agreements between the debtor and the bank; the sale orders provided for the satisfaction of the debtor's obligations arising from the loan agreements; and, in the case at bar, the debtor was challenging the propriety of the sale transactions.

 

The Court also found that the third res judicata prong—identity of the parties or their privies—was satisfied because the trustee is in privity with the debtor in his capacity as representative of the bankruptcy estate.

 

Finally, the Fourth Circuit concluded that the two "additional considerations"—"whether the party or its privity knew of should have known of its claims at the time of the first action and whether the court that ruled in the first suit was an effective forum to litigate the relevant claims"—were met because the debtor offered no argument that the trustee could not effectively litigate in the bankruptcy court.

 

Accordingly, the district court's judgment was affirmed.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email:
rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Sunday, May 1, 2016

FYI: Ill App Ct (1st Dist) Rejects Challenge to Foreclosure Based on Alleged HAMP Non-Compliance

The Illinois Appellate Court, First District, recently affirmed a trial court's denial of a borrower's motion to vacate a default judgment of foreclosure and sale, rejecting the borrower's argument that the mortgagee failed to comply with certain Home Affordable Modification Program (HAMP) guidelines.

 

A copy of the opinion is available at:  Link to Opinion

 

In January, 2007, the borrower executed a mortgage in the amount of $360,000, which was later assigned to the mortgagee.  In December, 2008, the mortgage filed a complaint seeking to foreclose due to default beginning in August 2008. 

 

The mortgagee amended the complaint in February 2009, and the trial court allowed service by publication after several personal service attempts failed.  In May 2009, the mortgagee moved for default judgment as the borrower neither answered the complaint nor appeared.  The mortgagee provided an affidavit stating that $398,386 was due and owing as of September 2009, and the trial court granted the motion and entered a judgment of foreclosure and sale of the property.

 

In June 2012, the mortgagee moved to vacate the judgement of foreclosure "due to an [undisclosed] error."  However, in July 2012, the mortgagee withdrew its motion without prejudice.  Two days later, the borrower entered an appearance through counsel.

 

No further action was taken until April 2013, when the mortgagee again moved for entry of an order of default and judgment of foreclosure and sale.  The April 2013 affidavit in support stated that the amount due and owing was now $487,094.  After the borrower failed to file an answer, the trial court granted the motion and entered judgment of foreclosure and sale in favor of the mortgagee.

 

In August 2013, the trial court granted the mortgagee's motion to set aside the default judgment of foreclosure and sale entered in September 2009 nunc pro tunc to April 2013, the date the court granted default judgment for the second time. 

 

In September 2013, the borrower moved to vacate the order of default and filed an amended motion in October 2013, alleging: 1) the borrower qualified for a HAMP loan modification in 2010 and other loss mitigation programs; 2) the mortgagee informed him that his loan was still active as of 2013; 3) the judgment amount was wrongly inflated; 4) the mortgagee lacked standing; and (5) judgment was erroneously entered on the mortgagee's original complaint when an amended complaint had been filed.  Finally, the borrower argued that the mortgagee's motion for the nunc pro tunc order did not comply with the requirements for notice under Illinois Supreme Court Rules 12, 131 (eff. Jan. 4, 2013), and Rule 105 (eff. Jan. 1, 1989).

 

In December, 2013, after briefing, the trial court denied the borrower's motion to vacate the default judgment.

 

After several months of back and forth of scheduling judicial sales and stays of the sale, the sale was held in June, 2014.  In November, 2014, the trial court granted the mortgagee's motion to confirm sale, holding that the mortgagee did not "establish that this property was sold in material violation of any of the HAMP regulations."  The borrower then appealed.

 

On appeal, the borrower challenged the trial court's denial of his motion to vacate the April 2013 default judgment brought pursuant to 2-1301(e) of the Illinois Code of Civil Procedure, 735 ILCS 5/2-1301(e) (West 2012)). 

 

In evaluating a section 2-1301(e) motion, the trial court considers the moving party's due diligence and the existence of a meritorious defense. Wells Fargo Bank, N.A. v. McCluskey, 2013 IL 115469, ¶ 27.

 

The Appellate Court noted that it was the borrower's burden, as appellant, to provide a sufficiently complete record to support a claim of error, and in the absence of that record, the Appellate Court must presume that the trial court's order conformed to the law and had a sufficient factual basis. Foutch v. O'Bryant, 99 Ill. 2d 389, 391-92 (1984). 

 

The First District found that the borrower did not provide a report of proceedings of the hearing on the motion to vacate nor a sufficient substitute.  Because the record did not reflect the reasons the trial court denied the motion to vacate, the Appellate Court held the borrower could only prevail if he demonstrated that he was entitled to have the default judgment vacated as a matter of law. 

 

The First District held that the borrower failed to meet that burden because a number of the debtor's contentions of error were patently frivolous, such as omission of attorney's phone number on motion for default.  The First District additionally held that none of the alleged errors mandated the conclusion that the trial court abused its discretion or otherwise erred in denying the borrower's motion to vacate.

 

The last basis of the borrower's appeal was his challenging the order confirming the sale.  Section 15-1508(d-5) of the Illinois Mortgage Foreclosure Law provides that a sale shall be set aside if the mortgagor proves "by a preponderance of the evidence that (i) the mortgagor has applied for assistance under the Making Home Affordable Program * * * and (ii) the mortgaged real estate was sold in material violation of the program's requirements for proceeding to a judicial sale." 735 ILCS 5/15-1508(d-5) (West 2012). 

 

The borrower alleged that the mortgagee "illegally revoked" a loan modification under HAMP in 2010.  Under HAMP guidelines, "[b]orrowers who make all trial period payments timely and who satisfy all other trial period requirements will be offered a permanent modification."  Making Home Affordable Program, Handbook for Servicers of Non-GSE Mortgages 46 (Aug. 19, 2010).  Despite allegedly making timely payments during his trial period, the borrower claimed he was denied a permanent modification.

 

The Appellate Court initially noted that the borrower failed to demonstrate that the decision to deny a permanent loan modification prevented the judicial sale of a foreclosed property, as HAMP guidelines require the suspension of a sale only where a HAMP application is pending.  But here, the borrower abandoned his argument that a HAMP application was pending at the time of the judicial sale.

 

But, more importantly, the First District held that the borrower did not meet his burden to show that the mortgagee's denial of a permanent modification was contrary to HAMP guidelines. 

 

In the borrower's motions to stay the sale, he never alleged that he had satisfied HAMP's trial period requirements.  The Appellate Court noted that the borrower never provided the trial court with a copy of his HAMP application or any documents from the mortgagee establishing the terms on which his loan had been approved.  Therefore, the Court held that pursuant to the HAMP guidelines, the mortgagee was not required to make the modification permanent. 

 

Accordingly, the Appellate Court affirmed the trial court's orders entering the default judgment of foreclosure and confirming the sale because the borrower failed to sustain his burden to demonstrate any HAMP violations that would have precluded confirmation of the judicial sale.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email:
rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Illinois   |   Indiana   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

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Insurance Recovery Services