FYI: 7th Cir Rules in Favor of Investor and Servicer in HOEPA/ECOA/FHA Case, Says Loan Mods Subject to ECOA

The United States Court of Appeals for the Seventh Circuit recently affirmed a lower court's judgment in favor of a mortgage loan investor and loan servicer under state law, the Home Ownership and Equity Protection Act ("HOEPA"), 15 U.S.C. § 1639, Equal Credit Opportunity Act ("ECOA"), 15 U.S.C. § 1691(a)), and Fair Housing Act ("FHA"), 42 U.S.C. § 3604(b).  A copy of the opinion is attached.

 

In so ruling, the Court held that loan modification offers are subject to ECOA.  "In light of the broad regulatory definitions, we find that [the Borrower], as the recipient of the defendants' offer to modify her loan, "received an extension of credit" and thus became an "applicant" under 12 C.F.R. § 202.2(e).

 

In 2001, the Plaintiff-Borrower ("Borrower") brought suit against the originating mortgage lender for, among other things, fraud.  The Borrower obtained a judgment against the lender in 2007 which the Borrower was unable to collect.  After 2001, the Borrower's mortgage loan was bought by Defendant Wells Fargo Bank ("Wells Fargo"), and Defendant Litton Loan Servicing ("Litton") took over the servicing of the loan.  However, Wells Fargo did not inform the Borrower prior to 2007 that it was the owner of the loan, and Wells Fargo continued foreclosure proceedings despite being aware of the judgment against the originating lender.  In addition, Litton sent the Borrower a letter proposing a modification of the subject loan in 2007, and also made a payoff demand in that same year. 

 

In 2007, the Borrower brought this lawsuit against Wells Fargo and Litton, alleging unconscionability and fraud under Illinois state law, violations of HOEPA, and race discrimination under the ECOA and FHA.

 

The district court dismissed the Borrower's state law, HOEPA and ECOA claims, and granted summary judgment in favor of Wells Fargo and Litton as to the FHA claim.  The Seventh Circuit "agreed with the district court's analysis of all" but the Borrower's FHA claim, but as that error was harmless, the Court affirmed the judgment of the district court entirely.

 

The Court first held that the lower court properly dismissed the Borrower's state law unconscionability claim on statute of limitations grounds. 

 

Under Illinois law, claims for unconscionability are subject to a five-year statute of limitations. 735 ILCS 5/13-205.  The Court reasoned that "under Illinois law [unconscionability] requires a showing that either the formation of the contract or a contractual term was improper, and none of the Borrower's allegations falling within the limitations period related to the formation of a contract."  The Borrower argued "that her claim of unconscionability should be extended to the defendants' later attempts to enforce the mortgage contract and should not be limited to the contract's formation."  However, the Court held that the language of relevant Illinois statute "addresses only the facts and evidence that may come to bear on the underlying question of whether a contract or a particular contractual term was unconscionable under Illinois law" and "does not change the underlying question itself."

 

The Court also affirmed the lower court's dismissal of the Borrower's state law fraud claim.  To prove fraud under Illinois law, the Borrower "must show that the defendant made a knowingly false representation of a material fact" and that the Borrower "reasonably relied on the false representation to her detriment."  On appeal, the Court agreed with the Borrower that the district court erred in not considering the defendants' demands that she pay her loan, which continued even after the defendants knew that the state court had ruled that her loan was based in part on the originating lender's adjudicated fraud.  However, the Borrower "did not allege that she had relied on the defendants' demands for payment or that she had suffered any damages as a result of those demands."

 

The Court next held that the lower court properly dismissed the Borrower's HOEPA claim because the Borrower's loan closed well outside the "one-year statute of limitations for money damages and a three year statute of limitations for rescission."  See 15 U.S.C. §§ 1635(f), 1640(e).  Relying on Swanson v. Bank of America, N.A., 566 F. Supp. 2d 821 (N.D. Ill. 2008), aff'd, 559 F.3d 653 (7th Cir. 2009), the Borrower argued that the additional allegations against Wells Fargo and Litton effectively extended the statute of limitations under HOEPA.  However, Swanson was a credit card case involving alleged failures to provide proper notices of interest rate increases.  The Borrower's "loan was a closed-end mortgage" and "not an open-ended home-equity loan or revolving credit account," as in Swanson.  In addition, the Borrower did not allege "that the defendants failed to notify her of a change in her loan terms after she signed the closing documents or that there was any change in her loan's terms."

 

The Court next affirmed the lower court's judgment dismissing the borrower's ECOA claims.  However, the Court held that the lower court erred in finding that the Borrower was not an "applicant" under the ECOA.  The ECOA makes it illegal for creditors to "discriminate against any applicant, with respect to any aspect of a credit transaction . . . on the basis of race." 15 U.S.C. § 1691(a)(1).  The statute defines "applicant" as "any person who applies to a creditor directly for an extension, renewal, or continuation of credit, or applies to a creditor indirectly by use of an existing credit plan for an amount exceeding a previously established credit limit." 15 U.S.C. § 1691a(b).  Regulation B (at 12 C.F.R. § 202.2(e)), which further defines "applicant" under the ECOA as "any person who requests or who has received an extension of credit from a creditor, and includes any person who is or may become contractually liable regarding an extension of credit."  The Court reasoned that, "as the recipient of the defendants' offer to modify the Borrower's loan," the Borrower "'received an extension of credit' and thus became an 'applicant' under 12 C.F.R. § 202.2(e)." 

 

However, the Court further held that remand of the Borrower's ECOA claim would be fruitless because the Borrower failed to come forward with evidence showing race discrimination.

 

Similarly, the Borrower "failed to bring forth any admissible evidence of racial discrimination" in support of her FHA claim, and the lower court therefore correctly granted summary judgment to Wells Fargo and Litton on this claim.  In support of her cross-motion for summary judgment on the FHA claim, the Borrower sought to have four affidavits introduced.  However, the lower court struck two of the affidavits because they "failed to comply with the requirements of Rule 56(e) and 28 U.S.C. § 1746," and struck the other two affidavits of former Wells Fargo employees because neither affiant "attested to having any personal knowledge of Mrs. Davis's loan or its surrounding circumstances."  The only evidence of discrimination which remained was the Borrower's "unsubstantiated belief that she was mistreated by the defendants because she was black" which "was insufficient to support her discrimination claims."

 

 

Let me know if you have any questions.  Thanks.

 

 

Ralph T. Wutscher

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 551-9320 

Fax:  (866) 581-9302
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FYI: Cal App Upholds Lower Court Victory for Bank in State Escheat Law Case

The California Appellate Court, First District recently held that a bank's practice of appropriating as income amounts accumulated through processing errors when clearing checks did not violate either the California Unclaimed Property Act, Cal. Code Civ. Pro. § 1500, et seq. ("UPL"), or the California False Claims Act, Cal. Govt. Code § 12650, et seq. ("CFCA").

 

A copy of the opinion can be found at:
http://www.courtinfo.ca.gov/opinions/documents/A126494.PDF

 

Two former employees of Bank of America brought a claim under the CFCA for alleged violations of the UPL.  The former employees claimed that Bank of America maintained a policy of not diligently researching errors that could result in credits to presenting banks when clearing checks.  The employees argued that these unidentified credits should revert to the State under the UPL, and that Bank of America's failure to report these credits to the State violated that statute.  The employees brought their claim under the CFCA, contending that Bank of America's purported UPL violation amounted to knowingly and improperly avoiding an obligation to pay money to the State.

 

The Appellate Court rejected the employees' arguments under both statutes. 

 

As to the UPL claim, the Appellate Court found that the unidentified credits at issue are not unclaimed property under the UPL.  The Appellate Court noted that the employees had not pled the existence of specific amounts due to specific presenting banks.  Observing that no presenting bank has ever made a claim against Bank of America in relation to these credits, the Appellate Court stated that it was difficult to conceive that the sophisticated financial institutions who were parties to these transactions would have abandoned the amounts due if they were identifiable.  The Appellate Court further commented that the shared characteristic of the types of property covered under the UPL is that they all encompass specific amounts due to identified persons, which the employees had failed to plead.

 

The Appellate Court additionally held that the CFCA imposes its own requirement that the obligation to the state be liquidated and certain.  The Appellate Court specifically held that the obligation to the State cannot be a mere potential liability.  The defendant must have a present duty to pay money or property created by statute, regulation, contract, judgment, or acknowledgment of indebtedness.  In this case, the Appellate Court found no such duty, as the unidentified credits at issue were neither liquidated or certain.

 

The Appellate Court also reiterated previous rulings requiring CFCA claims to be pled with specificity.  The Appellate Court rejected the employees' argument that Bank of America's actions in not diligently researching errors related to the unidentified credits relieved them of meeting the CFCA's heightened pleading standard, stating that CFCA actions "are meant to encourage private whistleblowers, uniquely armed with information about false claims to come forward.  These insiders should have adequate knowledge of the fraudulent acts to comply with the pleading requirements."

 

 

Let me know if you have any questions.  Thanks.

 

 

Ralph T. Wutscher

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 551-9320 

Fax:  (866) 581-9302
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Federal Reserve Study Finds No Evidence of Disparate Impact Discrimination in Loan Mods

The San Francisco Federal Reserve recently issued the results of its study, conducted with assistance by the Institute for Research on Poverty at the University of Wisconsin-Madison, regarding potential disparate impact discrimination in the area of mortgage loan modifications.

 

A copy of the report is available at:
http://www.frbsf.org/publications/community/wpapers/2010/who-receives-mortgage-modification.pdf

 

The study found no evidence of disparate impact discrimination.

 

Specifically, the Federal Reserve study concludes as follows:

 

"The results suggest although loan modifications remain a rarely used option among the servicers in these data, there is no evidence that minority borrowers are less likely to receive a modification or less aggressive modification. These borrowers are more likely to be delinquent, but controlling for delinquencies we find no evidence of disparate impact. We also find that preliminary performance of loans post-modification is positive, particularly for minority borrowers."

 

The study also notes that, "[g]enerally modifications involve modest interest rate reductions and increasing loan balances."

 

The Federal Reserve study used data on 105,769 non-agency securitized subprime loans made in 2005.  The researchers examined the incidence of defaults and modifications among loans managed by one large trustee of securitized loans covering 94 loan servicers in California, Oregon and Washington. HMDA data was used to assess borrower characteristics.

 

 

Let me know if you have any questions.  Thanks.

 

 

Ralph T. Wutscher

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 551-9320 

Fax:  (866) 581-9302
Mobile:  (312) 493-0874

Email:  RWutscher@kw-llp.com

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7th Cir Rules Against Servicer on QWR Issues, RESPA Safe Harbor

The United States Court of Appeals for the Seventh Circuit recently held that borrower inquiries to a loan servicer that either request information, or that state a belief as to an error in servicing, are "Qualified Written Requests" under RESPA.  The Court further ruled that in order to invoke the "safe harbor" provisions under Section 6 of RESPA, a servicer must at least, upon discovery of a servicing error, notify the borrower of that error within 60 days, and before the borrower files suit. 

A copy of the decision is available online at: http://caselaw.findlaw.com/us-7th-circuit/1551915.html

Plaintiff borrowers' loan was assigned to GMAC after a lengthy period of mishandled servicing by a prior servicer.  Upon transfer, GMAC failed to provide borrowers with notification of the transfer of servicing and also sent account statements to the borrowers reflecting incorrect information that had been provided by the prior servicer.  Based on this incorrect information, GMAC also returned uncashed several payments, submitted negative information to several credit bureaus and initiated foreclosure proceedings.

Attempting to resolve these problems, the borrowers submitted a series of letters to GMAC outlining their concerns.  GMAC acknowledged receipt of these letters, but provided no further response to the borrowers' inquiries.  The borrowers filed suit, alleging violations of RESPA for GMAC's failure to notify of the transfer of servicing or to respond to their inquiries and also alleging negligence and breach of contract under state law.  The District Court granted summary judgment in favor GMAC as to all claims; the borrowers appealed.

The Appellate Court first examined the applicability of RESPA's "safe harbor" provisions under 12 U.S.C. § 2605(f)(4).  Although the Court declined to examine all of the requirements necessary for its protection, it did rule that one requirement is that upon discovering an error, a servicer must notify the borrower of that error within 60 days, and before the borrower files suit.  Because GMAC had failed to so notify the borrowers, the Court ruled, it could not claim RESPA's "safe harbor" protections.

The Court then considered GMAC's arguments that the borrowers' letters were not "Qualified Written Requests," and thus did not trigger obligations under Section 6 of RESPA, because they "merely dispute a debt or request information."  The Court noted that RESPA requires that a request (1) "must reasonably identify the borrower and account," and (2) must "include a statement of the reasons for the belief of the borrower, to the extent applicable, that the account is in error or provide sufficient detail to the servicer regarding other information sought by the borrower."  Thus, the Court explained, any "reasonably stated written request for account information can be a qualified written request."  Further, "[t]o the extent that a borrower is able to provide reasons for a belief that the account is in error, the borrower should provide them, but any request for information made with sufficient detail is enough under RESPA to be a Qualified Written Request…" 

The court then applied this analysis to the borrowers' letters.

The borrowers' first letter complained in "great detail" that previous payments had been submitted, that they had not been properly credited, and that additional fees had been improperly assessed.  The letter also requested "very specific information," including the reasons for failing to apply payments, an accounting of the funds previously applied and information related to the transfer of the servicing to GMAC.  The Court concluded that although some of the information requested might have been unavailable to GMAC, the letter itself "provide[d] sufficient detail...regarding other information sought by the borrower" to be considered a Qualified Written Request.

In the second letter, the borrowers explained their understanding of the amounts then due on the loan, and enclosed a check for that amount.  The borrowers also described a series of "expectations" as to how GMAC would handle their account moving forward, including that GMAC would provide any requested information, that GMAC would respond in writing, and that their payments would be applied in a timely manner.  However, they did not describe any disputes or errors with the servicing of the account.  Because the borrowers' statements of "expectations were not requests for information," the Court ruled, this letter was not a qualified written request.

In their third and fourth letters, the borrowers requested that GMAC apply the payments previously received, and also recounted their various frustrations with GMAC's failure to apply payments, but did not articulate any specific belief that GMAC's failure to apply the payments submitted was due to a servicing error.  Therefore, the Court ruled, although these letters clearly related to servicing, they did not either request information or state a belief as to an error in servicing, and thus were not Qualified Written Requests.

In their final letter, the borrowers disputed GMAC's "attempt to collect on [the account]" and further alleged that GMAC's failure to apply, and subsequent return of, the previously-submitted payments was a servicing error and further requested a specific explanation of the fees and costs applied to their account.  This, the Court ruled, was "unequivocally a Qualified Written Request under RESPA."

The Court next considered the borrowers' breach of contract claim and noted "is a basic tenant of contract law…that where time for performance is specified, the law implies a reasonable time."  Because the reasonableness of GMAC's admitted failure to apply immediately apply payments was a question of material fact, the Court ruled, the summary dismissal of these claims by the District Court was an error.

The Court also considered the District Court's dismissal of borrowers' negligence claims.  In affirming the lower decision, the Court observed that the economic loss doctrine bars tort recovery for purely economic losses based on failure to perform contractual obligations.  Although there are exceptions to this doctrine, these exceptions require "the existence of an extra-contractual duty between the parties," such as a fiduciary duty.  Because the borrowers failed to demonstrate a fiduciary or other such duty, the Court affirmed the dismissal of the negligence claims.

Finally, the Court examined the question of possible damages, either as a result of borrowers' denial of further credit or emotional distress.  Noting that RESPA allows for actual damages to the borrower as a result of compliance failure, the Court then examined the factual record and concluded that based on the record, a reasonable jury could conclude that GMAC's actions resulted in actual damages, either due to a denied business loan application, or due to emotional distress, and that these questions of fact would bar summary judgment.

 

Let me know if you have any questions.  Thanks.

 

 

Aaron Freeman

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 416-6170

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Email:  AFreeman@kw-llp.com

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MA Sup Jud Ct Invalidates Foreclosure Sales for Lack of Proof of Mortgage Assignments

The Massachusetts Supreme Judicial Court recently held that two foreclosure plaintiffs, "who were not the original mortgagees, failed to make the required showing that they were the holders of the mortgages at the time of foreclosure," and that "[a]s a result, they did not demonstrate that the foreclosure sales were valid to convey title to the subject properties, and their requests for a declaration of clear title were properly denied."  A copy of the opinion is attached.

 

The Court emphasized that the asset securitization trustee plaintiffs both "asserted in their respective complaints that they had become the holder of the respective mortgage through an assignment made after the foreclosure sale."  The factual discussion of each case in the opinion specifically states that the servicer of the mortgage loan was the record mortgagee, and that the mortgage was assigned the trustee after the foreclosure sale occurred.

 

The trial court judge ruled that the foreclosure sales were invalid because, in alleged violation of Mass. G.L. c. 244, § 14, the notices of the foreclosure sales named the asset securitization trust trustees as the mortgage holders where they had not yet been assigned the mortgages. The trial court judge found, based on each plaintiff's assertions in its complaint, that the plaintiffs acquired the mortgages by assignment only after the foreclosure sales, and thus had no interest in the mortgages being foreclosed at the time of the publication of the notices of sale or at the time of the foreclosure sales.

 

The plaintiffs moved to vacate the trial court's judgments.  In so doing, the plaintiffs submitted hundreds of pages of documents to the trial judge, attempting to establish that the mortgages had been assigned to them before the foreclosures.  Many of these documents related to the creation of the securitized mortgage pools in which the mortgages were included.  Nevertheless, the trial judge denied the plaintiffs' motions, concluding that the newly submitted documents did not alter the conclusion that the plaintiffs were not the holders of the respective mortgages at the time of foreclosure.

 

Importantly, the Court noted that each plaintiff did not provide the trial judge with any mortgage schedule identifying the subject loans as among the mortgages that were assigned in the purchase and sale and trust agreements.

 

Moreover, Massachusetts is not a "mortgage follows the note" state.  The Massachusetts Supreme Judicial Court here noted:

 

In Massachusetts, where a note has been assigned but there is no written assignment of the mortgage underlying the note, the assignment of the note does not carry with it the assignment of the mortgage. Barnes v. Boardman, 149 Mass. 106, 114 (1889). Rather, the holder of the mortgage holds the mortgage in trust for the purchaser of the note, who has an equitable right to obtain an assignment of the mortgage, which may be accomplished by filing an action in court and obtaining an equitable order of assignment. Id.

. . .

In the absence of a valid written assignment of a mortgage or a court order of assignment, the mortgage holder remains unchanged. This common-law principle was later incorporated in the statute enacted in 1912 establishing the statutory power of sale, which grants such a power to "the mortgagee or his executors, administrators, successors or assigns," but not to a party that is the equitable beneficiary of a mortgage held by another. G.L. c. 183, § 21, inserted by St.1912, c. 502, § 6.

 

In addition, the Court specifically stated as follows:

We do not suggest that an assignment must be in recordable form at the time of the notice of sale or the subsequent foreclosure sale, although recording is likely the better practice. Where a pool of mortgages is assigned to a securitized trust, the executed agreement that assigns the pool of mortgages, with a schedule of the pooled mortgage loans that clearly and specifically identifies the mortgage at issue as among those assigned, may suffice to establish the trustee as the mortgage holder. However, there must be proof that the assignment was made by a party that itself held the mortgage. See In re Samuels, 415 B.R. 8, 20 (Bankr.D.Mass.2009). A foreclosing entity may provide a complete chain of assignments linking it to the record holder of the mortgage, or a single assignment from the record holder of the mortgage. See In re Parrish, 326 B.R. 708, 720 (Bankr.N.D.Ohio 2005) ("If the claimant acquired the note and mortgage from the original lender or from another party who acquired it from the original lender, the claimant can meet its burden through evidence that traces the loan from the original lender to the claimant"). The key in either case is that the foreclosing entity must hold the mortgage at the time of the notice and sale in order accurately to identify itself as the present holder in the notice and in order to have the authority to foreclose under the power of sale (or the foreclosing entity must be one of the parties authorized to foreclose under G.L. c. 183, § 21, and G.L. c. 244, § 14).

. . .

A valid assignment of a mortgage gives the holder of that mortgage the statutory power to sell after a default regardless whether the assignment has been recorded. See G.L. c. 183, § 21; MacFarlane v. Thompson, 241 Mass. 486, 489 (1922). Where the earlier assignment is not in recordable form or bears some defect, a written assignment executed after foreclosure that confirms the earlier assignment may be properly recorded. See Bon v. Graves, 216 Mass. 440, 444-445 (1914). A confirmatory assignment, however, cannot confirm an assignment that was not validly made earlier or backdate an assignment being made for the first time. See Scaplen v. Blanchard, 187 Mass. 73, 76 (1904) (confirmatory deed "creates no title" but "takes the place of the original deed, and is evidence of the making of the former conveyance as of the time when it was made"). Where there is no prior valid assignment, a subsequent assignment by the mortgage holder to the note holder is not a confirmatory assignment because there is no earlier written assignment to confirm. In this case, based on the record before the judge, the plaintiffs failed to prove that they obtained valid written assignments of the Ibanez and LaRace mortgages before their foreclosures, so the postforeclosure assignments were not confirmatory of earlier valid assignments.

However, the Court specifically rejected the plaintiffs' request that its ruling only be prospective in its application. The Court held it did not make significant change in the common law, but rather "[t]he legal principles and requirements we set forth are well established in our case law and our statutes. All that has changed is the plaintiffs' apparent failure to abide by those principles and requirements in the rush to sell mortgage-backed securities."

 

Let me know if you have any questions.  Thanks.

 

 

Ralph T. Wutscher

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 551-9320 

Fax:  (866) 581-9302
Mobile:  (312) 493-0874

RWutscher@kw-llp.com

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