Product: Vehicle loan or lease

Complainant : XXXX XXXX Address : XXXX XXXX XXXX XXXX XXXXXXXX XXXXXXXX XXXX  XXXX Ph : XXXX Contact information : XXXX This elaborate scheme introduces a Class of Consumers to the fraud of the inducement and concealment by these tactics. ( this complex situation of the Complainant who is a member of this class ) List of the interested parties, including violations : Texas Finance Codes, The Texas Administrations Codes, the Texas Deceptive Practice Act the GrammLeachBliley Act, the Program Fraud Civil Remedies Act according to 43 C.F.R 35.1-35.47, the Fair Credit Reporting Act pursuant to 15 U.S.C. 1681. Texas Finance Code : Illegal transfer of title ( Chapter 348 ), falsification of title documents ( Chapter 503 ), violations of dealer licensing requirements. Texas Deceptive Trade Practices Act ( DTPA ) : Deceptive acts or practices in the sale or lease of a vehicle. State Insurance Regulations : Potential violations depending on their role in the alleged title fraud scheme. Texas Finance Code : Involvement in falsifying or forging title documents ( Chapter 503 ). Potential Criminal Liability : If they knowingly participated in a fraudulent scheme, they could face criminal charges. Violations of the Truth in Lending Act ( TILA ) ( if loan terms were misrepresented ), violations of state motor vehicle and titling laws Party 1 : XXXX BMW the dealership illegally transferred the title to XXXX XXXXXXXX XXXX XXXX and changed the sale dates on the Texas Registration for the title, following the date on the back of the title from XX/XX/XXXX, to XX/XX/XXXX. There were two transactions involved on one account/transaction, one for an XXXX, XXXX XXXX  XXXX XXXX, on XX/XX/XXXX, and the other for a BMW XXXX XXXX on XX/XX/XXXX. All trust documents are constructed the same way. 

Violations : 12 CFR 354.004 ( 12 ) ( Failure to disclose credit terms related to debt cancellation ) XXXX ( XXXX ) : Federal Trade Commission Act 16 U.S.C. 433.2 Preservation of Consumers Claims & Defenses Federal Consumer Financial Protection Bureau ( CFPB ) : Violation of Regulation Z ( Truth in Lending Act ) for failing to disclose the true cost of the debt cancellation agreement. 
Texas Finance Code 503.038 ( Illegal Transfer of Title ) Rule 83.812 GAP Waiver Agreement The Texas Finance Code 342.4021 ( a ) ( d ) ( 1 ) ( 2 ) ( b ) the disclosure must not be in the loan agreement Texas Deceptive Trade Practices Act ( DTPA ) ( Fraudulent Inducement, Concealment ) Illegally transferred the title of the vehicle to XXXX XXXX XXXX  XXXX and falsified sales dates on the Texas Registration and title documents. 
Gramm-Leach-Bliley Act ( GLBA ) ( Improper disclosure of personal information ) To other parties/ affiliates Texas Finance Code Chapter 348 ( Operating with an unlicensed lender ) Texas Administrative Code 348.501, 348.501 ( b ), 348.501 ( a ) ( b ), 84.401, 84.603, 84.607, 84.609 ( Unlicensed lending/lender activities ) No registration by OCCC since XX/XX/XXXX Texas Finance Code : Unlicensed lending activities ( Chapter 348 ), usury of interest rates they were charged without a license. 

XXXX XXXX : BMW Bank of North America ( Assignee/Seller/ Lienholder ) the outside Financial Institution that didnt lend credits/money NOTE DEFAULT/BREACH : All Retail Installment contracts are stated on page 7 of 7 in paragraph 21, under SELLER 'S SIGNATURE : The assignee BMW Bank of North America, a wholly-owned subsidiary of BMW Financial Services N.A., LLC. Court records show BMW FS is a wholly owned subsidiary of BMW of North America , LLC, which is out of state and holds a TDLR license only for Services and Products. 

Violations : 12 CFR 354.004 ( 12 ) ( Failure to disclose holder, BMW FS related to debt cancellation ) XXXX ( Administrator ) : Federal Trade Commission Act 16 U.S.C. 433.2 Preservation of Consumers Claims & Defenses, acted as the assignee and lienholder on the vehicle despite having a canceled license in Texas, invalidating the contract. While all times taking payments from Complainant since XX/XX/XXXX. BMW Bank of North America is responsible for the actions of its subsidiary and involved in the securitization of the loan. 
Federal Consumer Financial Protection Bureau ( CFPB ) : Violation of Regulation Z ( Truth in Lending Act ) for failing to disclose the true cost of the debt cancellation agreement. 
Texas Finance Code Chapter 348 ( Operating as an unlicensed lender ) Rule 83.812 GAP Waiver Agreement The Texas Finance Code 342.4021 ( a ) ( d ) ( 1 ) ( 2 ) ( b ) the disclosure must not be in the loan agreement Texas Administrative Code 348.501, 348.501 ( b ), 348.501 ( a ) ( b ), 84.401, 84.603, 84.607, 84.609 ( Unlicensed lending activities ) No registration by OCCC since XX/XX/XXXX Texas Finance Code : Unlicensed lending activities ( Chapter 348 ), usury of interest rates they were charged without a license. And show a debt of {$9.00}, 597.01, to XXXX XXXX, that the finisher failed to disclose to the plaintiff. 
Gramm-Leach-Bliley Act ( GLBA ) ( Improper disclosure of personal information ) To other parties/ affiliates Civil Liability ( Invalidation of contracts, damages ) Party XXXX : XXXX  ( Administrator ) Violations : 12 CFR 354.004 ( 12 ) ( Failure to disclose credit terms related to debt cancellation ) XXXX ( Administrator ) : Federal Trade Commission Act 16 U.S.C. 433.2 Preservation of Consumers Claims & Defenses Federal Consumer Financial Protection Bureau ( CFPB ) : Potential violation of Regulation Z ( Truth in Lending Act ) for failing to disclose the true cost of the debt cancellation agreement. 
Texas Administrative Code 348.501, 348.501 ( b ), 348.501 ( a ) ( b ), 84.401, 84.603, 84.607, 84.609 ( Unlicensed sale of debt cancellation agreements ) no licenses or regulation with OCCC Texas Finance Code 503.038 ( Unlicensed activity ) Texas Finance Code : Unlicensed lending activities ( Chapter 348 ), usury of interest rates they were charged without a license. 
Rule 83.812 GAP Waiver Agreement The Texas Finance Code 342.4021 ( a ) ( d ) ( 1 ) ( 2 ) ( b ) the disclosure must not be in the loan agreement Gramm-Leach-Bliley Act ( GLBA ) ( Improper disclosure of personal information ) To other parties/ affiliates Civil Liability ( Invalidation of agreements, damages ) Party 4 : BMW Financial Services N.A. ( Depositor ) Servicer Violations : 12 CFR 354.004 ( 12 ) ( Failure to disclose credit terms related to debt cancellation ) XXXX  ( Administrator ) : Federal Trade Commission Act 16 U.S.C. 433.2 Preservation of Consumers Claims & Defenses, acted as the assignee and lienholder on the vehicle despite knowing a canceled license in Texas, and no regulation by the administrator, invalidating the contract. 
Federal Consumer Financial Protection Bureau ( CFPB ) : Violation of Regulation Z ( Truth in Lending Act ) for failing to disclose the true cost of the debt cancellation agreement. 
Gramm-Leach-Bliley Act ( GLBA ) ( Improper disclosure of personal information ) Texas Deceptive Trade Practices Act ( DTPA ) ( Deceptive practices ) Texas Administrative Code 348.501 , 348.501 ( b ), 348.501 ( a ) ( b ), 84.401, 84.603, 84.607, 84.609 ( Unlicensed sale of debt cancellation agreements Texas Finance Code 503.038 ( Unlicensed activity ), May be held responsible for the actions of its subsidiary, BMW Bank of North America XXXX 
Rule 83.812 GAP Waiver Agreement The Texas Finance Code 342.4021 ( a ) ( d ) ( 1 ) ( 2 ) ( b ) the disclosure must not be in the loan agreement Texas Finance Code : Unlicensed lending activities ( Chapter 348 ), usury of interest rates they were charged without a license. 
Texas Finance Code Chapter 348 ( Operating with an unlicensed lender ) Texas Administrative Code 348.501, 348.501 ( b ), 348.501 ( a ) ( b ), 84.401, 84.603, 84.607, 84.609 ( Unlicensed lending/lender activities ) No registration by OCCC since May 14, 2014 Illegally refinance Complainants car into a leased vehicle without consent On a Paid in Full Account. And show a debt of {$9.00}, 597.01 by XXXX XXXX, that the finisher failed to disclose to the plaintiff. 
Civil Liability ( Privacy violations, and all damages caused, aforementioned ) XXXX XXXX : XXXX XXXX XXXX XXXX Insurance Company ) Affiliated company ELT Violations : Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Civil Liability ( Privacy violations, aiding and abetting fraud ) XXXX XXXX XXXX the insurance company who shared Plaintiffs private information to illegally convert the title through affiliates, Involvement in the illegal conversion of the title and clouding of the digital title affiliate of ELT, involved in converting the paper title to a digital title and clouding the title with a new ID. 


XXXX XXXX : ELT ( Affiliate ) Electronic Liens, and Title System to the DMV Violations : Involvement in illegal title conversion and fraud. ELT who clouded the digital title by giving it a new I.D . Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Civil Liability ( Privacy violations, aiding and abetting fraud ), involvement in the illegal conversion of the title and clouding of the digital title affiliate of XXXX XXXX XXXX, involved in converting the paper title to a digital title and clouding the title with a new ID.

Party XXXX : XXXX XXXX XXXX XXXX  Violations : Involvement in receiving a fraudulently transferred title XXXX XXXXXXXX XXXX XXXXXXXX who claimed the plaintiffs title by the DMV since XX/XX/XXXX, then sold the Plaintiffs car on XX/XX/XXXX. Violations of the Texas Deceptive Trade Practices Act ( DTPA ) Claimed the plaintiff 's title fraudulently and sold the vehicle without the plaintiff 's knowledge or consent. Federal Trade Commission Act 16 U.S.C. 433.2 Preservation of Consumers Claims & Defenses, Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Civil Liability ( Privacy violations, aiding and abetting fraud ) Party XXXX : XXXX XXXX XXXX ( CRA ) Violations : Federal Consumer Financial Protection Bureau ( CFPB ) : Violation of Regulation Z ( Truth in Lending Act ) for failing to disclose an accurate, fair credit report, and or documents. 
Fair Credit Reporting Act ( FCRA ) ( Failure to disclose credit history, inaccurate reporting ) Failure to investigate disputes, buying, and selling the Complainants private data ) Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Civil Liability ( Damages for credit report errors ) XXXX Information Solution the CRA Publisher of Credit Information failed to disclose to the complainants credit history for over 17 months and showed a debt of {$9.00}, 597.01 that the finisher failed to disclose to the plaintiff Party XXXX : XXXX ( CRA ) Violations : Federal Consumer Financial Protection Bureau ( CFPB ) : Violation of Regulation Z ( Truth in Lending Act ) for failing to disclose an accurate, fair credit report, and or documents, buying, and selling the complainants privet data Fair Credit Reporting Act ( FCRA ) ( Failure to disclose credit history, inaccurate reporting ) Failure to investigate disputes. ) XXXX the CRA who failed to report any credit history on the complainants credit history tradeline and showed a charged off of Paid in Full, following showing zero charged off Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Civil Liability ( Damages for credit report errors ) buy and sell complainants privet data. 

Party XXXX : XXXX XXXX ( Attorney for BMW FS ) Violations : Ethical violations by representing a client engaging in fraudulent activities, mail fraud by sending and filing deceptive debt collection into court filings, through deceptive misleading information, the counsel XXXX XXXX for BMW FS committed mail fraud on more than a few occasions, by certified mail, extortion of a fraudulent debt, also requested payment from plaintiff through defaults, and fraudulent contracts, by requesting Attorney fees. ethical violations for filing a fraudulent claim and misrepresenting information to the court Violations of the Fair Debt Collection Practices Act ( FDCPA ) Attorney for BMW FS, engaged in fraudulent and deceptive practices in pursuing the collection of the debt, filing frivolous claims Gramm-Leach-Bliley Act ( GLBA ) ( Receiving improperly disclosed personal information ) Feedback : This complex scheme involves multiple parties engaging in coordinated illegal and deceptive practices. The complainant has a strong case for pursuing legal action against all involved parties, seeking damages for fraud, regulatory violations, privacy breaches, breach of contracts, breach of trust, defaulted, voided, unenforceable contracts, and false credit reporting errors. 

Rescission of Contracts : The illegal actions by XXXX BMW, ( BMW ) BMW Bank of North America, BMW FS, and XXXX invalidated the contracts. 


Outcomes : Civil Liability : All parties involved could face civil liability for their respective roles in the scheme. This could result in significant financial penalties and damages for the plaintiff. 
Regulatory Sanctions : Regulatory agencies like the OCCC could impose sanctions on the unlicensed entities and individuals involved. 
Criminal Charges : In some cases, individuals involved in fraudulent activities could face criminal charges, such as forgery, fraud, or theft. 
Texas Finance Code violations related to improper disclosure and sale of debt cancellation agreements violation of the Gramm-Leach-Bliley Act ( GLBA ) for unauthorized disclosure of personal financial information Class Action : Given the potential for widespread harm, the plaintiff may consider pursuing a class action lawsuit on behalf of other consumers, a class who have been affected by similar practices NOTICE TO DISCLOSE ALL DOCUMENTS UNDER RULE 26 ( a ). DUTY TO DISCLOSE ; GENERAL PROVISION GOVERNING DISCOVERY AND ALL INTER-AGENCY COMMUNICATIONS WITH THIS ACCOUNT : 1. Attention to BMW Bank of North America, ( BMW ), BMW Financial Services 2. Provide a full Amortization of Account Number. XXXX by XXXX XXXX XXXX. Provide all Posted Payment History Transactions 4. Provide all consumer information sent to XXXX XXXX XXXX. 
5. Provide all information sent to ELT 6. Provide posted payment check to statement XXXX of XXXX from the date of XX/XX/XXXX, of {$490.00} account XXXX XXXX XXXX XXXX payable to BMW Bank of North America 7. Provide posted payment check to statement XXXX of XXXX dated XX/XX/XXXX, of payment received on XX/XX/XXXX, in the sum of {$20000.00} on account number XXXX XXXX XXXX XXXX payable to BMW Bank of North America 8. Provide the Asset-Backed Securities, the Bookkeeping 9. Provide the OMB APPROVAL OMB Number XXXXXXXX FORM attached to as Exhibit herein Provided by the United States Securities and Exchange Commission under 18 U.S.C 1001. 

10. Attention to XXXXXXXX BMW MINI 11. Provide all transactional documents as of the date of XX/XX/XXXX. On the BMW XXXX XXXX XXXX XXXX # XXXX including and not limited to the Application for the title and registration, bill of sale, copy of title, and all other supporting documents about the retail installment sale of this motor vehicle. 
12. Provide all transactional documents as of the date of XX/XX/XXXX. On the BMW XXXX XXXX XXXX XXXX XXXX # XXXX including and not limited to Application for the title and registration, bill of sale, copy of title, and all other supporting documents about the retail installment sale of this motor vehicle. 

13. Attention to XXXX XXXXXXXX XXXX XXXXXXXX XXXX. Provide all transactional documents as of the date of XX/XX/XXXX. On the BMW XXXX XXXX XXXX XXXX XXXX # XXXX including and not limited to Application for the title and registration, bill of sale, copy of title, and all other supporting documents about the retail installment sale of this motor vehicle.