Product: Mortgage

VIA EMAIL XXXX XXXX XXXX, XXXX. 
XXXX XXXX XXXX Suite XXXX XXXX, PA XXXX Re : XXXX XXXX XXXX XXXX XXXX XXXX XXXX and XXXX XXXX XXXX XXXX Bucks Cty., No. XXXX Property Address : XXXX XXXX XXXX, XXXX, PA XXXX XXXX No. XXXX KML File No : XXXX Dear XXXX : This law firm has been retained by XXXX XXXX XXXX and XXXX XXXX XXXX XXXX XXXX to the above-referenced mortgage loan and foreclosure action. Our clients were in near constant communication with your firm for several years as part of their efforts to seek a loan modification over the course of nearly three ( 3 ) years. 

Our clients never obtained any modification, nor was their request for modification denied. 

After our law firm has conducted extensive research, investigation, evaluation and analysis of the XXXX XXXX XXXX ( request for mortgage assistance - a loan modification ) and loan modification abuse abuse. 

It is clear to the Princes and this law firm that your client ( BOA/Citimae ) never had any intention of granting the loan modification - which all parties agreed to work toward a loan modification in the Princes bankruptcy plan, but instead BOA acted in bad faith by continuously stonewalling and delaying the Princes 3 + year loan modification process. 
From our extensive review of the pertinent communications ( emails ) with XXXX, it appears that your client XXXX requested information and documentation that had already been provided time and time again, which was duplicative, and/or unnecessary. XXXX Laws XXXX XXXX even stated in writing that the Princes had submitted all information necessary for the loan modification to be determined. We hold in our possession unequivocal proof of those redundant email requests for duplicative information requests and stonewalling behaviors. 

Our clients never obtained any modification offering during this ( 3 ) three-plus year timeframe, even as their financial situation materially and favorably improved year over year ( only bolstering the financial documentation/support that was repetitively requested month over month ). 

In fact, the Princes financial position improved so dramatically during this almost XXXX modification process since the Princes originally submitted their initial XXXX ( XXXX for mortgage assistance request for a loan modification in XX/XX/XXXX ) that the Princes are now in a position, if they so desire, to pay off the entire mortgage balance today as we speak. 
Now, Forty-One ( 41 ) -months after filing the Princes initial XXXX ( XXXX XXXX for mortgage assistance in XX/XX/XXXX ), there has still not been any denial or determination ( and there were several additional RMAs completed in between those dates due to the continuous delays and stonewalling from XXXX ). 
Furthermore, the Princes have continued to receive ( nearly ) monthly communications ( calls and mailings see attached ) from BOA requesting, almost demanding that the Princes seek BOA modification assistance. This is more evidence of deceit and bad faith compliance with federal mortgage assistance program guidelines. 
Every single BOA representative told the Princes that this 3-year mortgage modification process was impossible, and that it was federal and state guidelines/policy and the banks guidelines that all RMAs were to be completed in a 30-day timeframe, and in rare instances- 45 days. The Princes have logged the names and dates of the BOA representatives they spoke with and the formal BOA formal complaint filings the Princes filed with BOA regarding the BOA stonewalling tactics, in which these complaints were also never responded to either. 

Per BOA representatives ALL of the information in this letter is documented in BOA files including taped voice recordings, that our client the Princes called on and/or were called by BOA representatives XXXX, XXXX handling XXXX XXXX XXXX XXXX XXXX ( request for mortgage assistance XXXX loan modification ) process ( with still no answer to date as of XX/XX/XXXX - modification notification -acceptance or denial ) is beyond any reasonable sense of good faith where XXXX  completely ignores and disregards the very essence of federal home loan assistance programs. We also plan to file a federal lawsuit complaint regarding this issue as well as the financial damages from XXXX actions- or better stated non-action. 

The persistent stonewalling and continuous delay tactics are both epic in nature and abusive in consequences- causing the Princes serious financial hardship and emotional scars/stress with the constant reminders of BOA threatening to take their home of 30 plus years- due to economic hardship created by the economy, job displacement and a XXXX daughter, hardships beyond their control detailed in their hardship letter as part of the XXXX. 

Our clients ( the Princes ) have incurred considerable economic damages as a result of your clients failure to grant the modification, including but not limited to the loss of the ability to obtain alternative financing at a much lower interest rate. Our clients expended substantial time and resources complying with your clients demands and suffered emotional distress and anguish as a result of the above. 

To further demonstrate the emotional distress and financial hardship caused and created by BOA to the Princes - after the Princes filed for Chapter 13 bankruptcy in XX/XX/XXXX ( and the bankruptcy plan included BOA cooperating with a loan modification - while interest rates at the time were between 2 % and 3 % ), the Princes proceeded to pay every months mortgage payment - on time - for the duration of the bankruptcy plan ( XXXX plus months ) then suddenly in XX/XX/XXXX BOA began to return the Princes on-time monthly mortgage payments ( btw we have documentation for all those payments and BOAs return payments ). 

At that time ( XX/XX/XXXX ) BOA demanded that all the arrears payments of more than {$150000.00} plus the current monthly mortgage payments be made/paid by the Princes to avoid foreclosure and sheriffs sale even though those monthly mortgage payments were being made religiously by the Princes every month ) once again all the Princes returned monthly mortgage payments are documented ). 

Shortly after BOA demanded all the arrears and current monthly mortgage be paid in full again without any response from BOA XXXX + years of XXXX ( request for mortgage assistance a loan modification ) BOA began foreclosure proceedings and put the Princes home up for Sheriffs sale still without BOA responding to the Princes loan modification ( XXXX ) request for mortgage assistance since XX/XX/XXXX. Does this BOA behavior not define both arrogance and bad faith in complying with the guidelines of federal mortgage assistance programs. 

We write to advise that our clients have every intention of reinstating their mortgage/bringing the loan current and begin legal action against the bank.