Product: Mortgage

REBUTTAL TO WELLS FARGO RESPONSE TO COMPLAINT # XXXX To : Wells Fargo Bank , N.A . 
RE : Unverified Mortgage Obligation and Fraudulent Foreclosure Activity From : XXXX XXXX, Secured Party Date : [ Insert Todays Date ] Address : XXXX XXXX XXXX, XXXX, NY XXXX RE : Your Unsupported Response Regarding Alleged Mortgage Account for XXXX XXXX XXXX, XXXX, NY XXXX To Whom It May Concern : This response is made pursuant to your recent communication attempting to validate an alleged debt and justify foreclosure activity associated with the above-referenced property. I, XXXX XXXX, secured party and real party in interest, hereby issue the following formal rebuttal. 



XXXX. Validation of Debt and Assignment of Mortgage Your statement that there are no issues with the assignment is conclusory and unsupported. I demand : A certified copy of the original promissory note with a complete chain of endorsements. 

All assignments of mortgage, including XXXX XXXX and notarized assignment documents. 

Proof of possession and standing at the time foreclosure was initiated. 

Under 15 U.S.C. 1692g, the burden of proof is on you to validate the debt and your legal right to enforce it. An unsubstantiated claim is not validationit is a violation.

2. Right to Cancel You allege that Notice of Right to Cancel is not required because this was a purchase transaction. However : The record must show the true nature of the transaction, especially if it involved builder-financing, seller-lender arrangements, or TILA-triggering terms ( cash-out, interest recalculations, etc. ). 

If any part of the loan was structured as a refinance or carried deceptive disclosures, 15 U.S.C. 1635 and Regulation Z may still apply.

Failure to provide a Notice of Right to Cancel when required is a material violation under the Truth in Lending Act and grounds for rescission.

3. Foreclosure Activity You claim foreclosure activity is valid. This is a false and misleading representation : The foreclosure was initiated without verified ownership or standing. 

XXXX XXXX and CPLR XXXX were violated due to failure to properly serve a 90-day pre-foreclosure notice and certificate of merit. 

Your own response fails to rebut the fact that the original note was never presented, and thus foreclosure lacks jurisdiction and is void ab initio.

4. Credit Reporting Obsolescence Rule You claim that no correction will be made due to the XXXX exceeding 80 months. However : The FCRA ( 15 U.S.C. 1681s-2 ) requires the removal of inaccurate, unverifiable, or disputed entries. 

The foreclosure process itself is in dispute and under legal challenge, making your refusal to suppress or correct the record an ongoing FCRA violation. 

Ceasing to report due to age does not cure wrongful reporting already committed. 



XXXX. Previous Reviews & Denials You state that prior requests for assistance were denied. I demand a full accounting of : Each submission received from me and why it was deemed incomplete. 

All correspondence, internal notes, and records of evaluation for loan modification or hardship relief. 

Proof that you did not engage in dual tracking during loss mitigation review in violation of 12 C.F.R. 1024.41 ( f ).

6. Your Denial of Allegations and Compensation You respectfully deny all allegations and compensation. However : Your denial does not rebut the sworn facts presented in my Affidavit of Truth. 

Your failure to provide specific, itemized rebuttals or documentary evidence means my affidavit stands unrebutted in commerce and truth in fact and law. 



DEMAND FOR IMMEDIATE REMEDY Pursuant to the Fair Debt Collection Practices Act ( 15 U.S.C. 1692 et seq. ), the Fair Credit Reporting Act ( 15 U.S.C. 1681 et seq. ), and New York foreclosure and banking law, I demand : Immediate withdrawal of the foreclosure action as unlawful and lacking standing. 

Complete and permanent suppression of any credit entries tied to the disputed account. 

Delivery of the original wet-ink signed promissory note within ten ( 10 ) business days. 

Formal apology and monetary compensation in the amount of $ XXXX, for damages caused by unlawful foreclosure proceedings and credit damage. 

Disclosure of all third-party entities that received my personal, financial, or mortgage-related data.

Failure to cure these violations will result in escalation through : Formal litigation in state and federal court ; Complaints to CFPB, NYDFS, FTC, HUD, and the NY Attorney General ; A criminal referral to appropriate state and federal agencies regarding fraudulent foreclosure and data handling. 

Govern yourself accordingly. 

Sincerely, XXXX XXXX XXXX XXXX, XXXX XXXX in Interest