Product: Mortgage

Complaint ID # XXXX What date did the federal government, ( using tax payers dollars ), bailout the banks in the great housing market fraud crash of XXXX, including Bank of America , fka Countrywide Home Loans? 

The Emergency Economic Stabilization Act of XXXX, often called the " bank bailout of XXXX  '', was proposed by Treasury Secretary XXXX XXXX, passed by the 110th United States Congress, and signed into law by President George W. Bush. It became law as part of Public Law 110-343 on XX/XX/XXXX, in the midst of the financial crisis of XXXX. It created the {$900.00} billion Troubled Asset Relief Program ( TARP ) to purchase toxic assets from banks. The funds were mostly redirected to inject capital into banks and other financial institutions while the Treasury continued to examine the usefulness of targeted asset purchases. 

The glaring problem? In their rush to, so-call Save the Banks- the Federal Government ignored the largely innocent, completely unaware and disadvantaged homeowners, ( whos backs, - lets face it this bailout fell on and injured the most ). 

All as a result of the devastation caused by the deceptive fraud and greed in lending, appraisal, as well as servicing practices committed by gigantic financial institutions such as Countrywide Home Loans, currently known as Bank of America N.A. Home Loans. 

Wednesday, XX/XX/XXXX Contact : ( XXXX ) XXXX, XXXX https : //oag.ca.gov/news/press-releases/brown-sues-countrywide-mortgage-deception On XX/XX/XXXX, California Attorney General XXXX XXXX XXXX sues XXXX XXXXXXXX, its chief XXXX XXXX XXXX, and XXXX XXXX XXXX, for engaging in deceptive advertising and unfair competition. 

EVIDENCE : * * * 1 ) The lawsuits described a vast " conspiracy '' in which Countrywide provided financial incentives to large networks of brokers in exchange for their duping borrowers into taking out toxic loans. 

2 ) For several years, the scam worked. Countrywide grew from originating {$62.00} billion in loans in XXXX  to more than {$460.00} billion in XXXX, 3 ) while the lenders securities trading volume more than quintupled, from {$640.00} billion in XXXX  to {$3.00} trillion in XXXX.

4 ) The companys CEO, the flashily dressed and perma-tanned XXXX XXXX XXXX became one of the highest-paid executives in the nation, with an influence on markets approaching that of XXXX XXXX. 

5 ) The state lawsuits expose just how Countrywide built its sprawling empire.

6 ) One common loan product that came under harsh criticism in the lawsuit was the hybrid adjustable-rate mortgage, or ARM, in which mortgage rates were fixed for two to three years while borrowers made interest-only payments.

7 ) Afterward borrowers got hit with " payment shock '' when mortgage principal was added onto their monthly payments just as the starter interest rate converted to a variable rate that could shoot up to as high as 15 percent. 

8 ) XXXX lawsuit charges that Countrywides goal was to generate loans that paid the highest possible interest ratenot loans that offered the best deal for their customers. 
9 ) Low-income, first-time homebuyers became some of the best targets : the riskier the loan, the higher the interest rate. 
10 ) Countrywide packaged many of these loans into mortgage-backed securities and sold them to XXXX XXXX for windfall profits. 
XXXX ) Securities comprising Countrywide loans were in turn used to structure collateralized debt obligations, or CDOs, the implosion of which almost brought down the US financial system.

12 ) Risky Countrywide loans were linked to some of the most toxic CDOs. 

13 ) On XX/XX/XXXX, when XXXX announced in a call with XXXX XXXX bankers that housing prices would collapse on a scale not seen since the Depression, widespread panic ensued. By the end of XXXX, according to Countrywides own estimates, a staggering 27 percent of the lenders subprime loans were delinquent.

14 ) Once disaster struck, a quick settlement with the state attorneys general, under which Countrywide accepted no guilt and faced little financial liability, was not such a bad deal for the company. 

15 ) The settlement required Countrywide to make only XXXX loan modifications nationwide and did not set a dollar amount on how much these modifications had to save borrowers. 
16 ) Most of the loans covered by the settlement fell into one of two major types issued between XXXX and XXXX, at the height of the housing boom. 
17 ) One was the notorious pay-option ARM, in which the loan balance increased each month for borrowers who made only the minimum payment. 
17A ) Countrywide absurdly classified these loans as " prime '' productseven though many of them went to borrowers with very low credit scoresmaking it easier to sell them on the secondary market. 
18 ) The other was the subprime ARM, which had a fixed interest rate for a set period and then an adjustable rate for the remainder of the term. 
* * * 19 ) To comply with the settlement, Bank of America set up the Countrywide XXXX XXXX XXXX XXXX as a vehicle for providing relief. 
20 ) And the deal appeared, at first, to provide it. 
21 ) Eligible borrowers, according to XXXX analysis of the deal, may be considered for a range of modifications. 
22 ) Those with pay-option ARMs can reduce their outstanding balance to 95 percent of their homes current value, getting them out from under water.

23 ) 24 ) But Countrywide has no obligation to offer these terms to any particular eligible borrower. 


COMPLICIT GOVERMENTAL CORRUPTION : 25 ) A key weapon in BofAs arsenal is something called a foreclosure avoidance budget, which gives the bank the option of foreclosing on homeowners whenever, in the judgment of the banks analysts, more money can be recouped by foreclosing than by modifying the loan. 
26 ) Housing advocates speak with frustration of how BofA often refuses to grant modifications to eligible borrowers, based solely on the banks analysis of its foreclosure avoidance budget. 
27 ) Yet bank officials have refused to make public how they calculate that budget. 
XXXX ) XXXX XXXX, a lawyer with XXXX XXXX XXXXXXXX XXXX XXXX, an XXXX nonprofit, says she repeatedly attempted to obtain that information from BofA. " One of the things we kept asking, '' she says, " is, Can we see those analyses? Can we see the foreclosure avoidance budget? 
29 ) The answer was always no. '' In the end, she simply gave up on using the Countrywide settlement as a means of helping borrowers. 
30 ) Even information on how many homeowners are facing foreclosure under the foreclosure avoidance budget is not publicly available. 
31 ) I requested these numbers from the California attorney generals office, which directed me to Bank of America, which refused to divulge the data. 

32 ) Last XXXX I interviewed XXXX XXXX, Bank of Americas senior vice president for public relations and communications, at a meeting between BofA executives and distraught homeowners in a church in XXXX, XXXX, and XXXX ) he said something telling : " We dont call it a settlement, but our agreement with the attorneys general. '' Apparently BofA doesnt believe it owes anybody anything. 

34 ) Despite XXXX  XXXX XXXX failure to help hundreds of thousands of homeowners ruined by Countrywide, 35 ) the bank claims it is on track to fulfill its obligations under the settlement. 
36 ) According to the one publicly available page of a quarterly compliance report the bank is required to file with the state attorneys general, as of the end of the second quarter of XXXX, BofA had modified a total of XXXX loans under the settlement, achieved an expected interest and principal savings for borrowers of {$3.00} XXXX and provided {$170.00} XXXX in relief to people who had lost their homes to foreclosure. 

XXXX ) These numbers look impressive, at first glance. 
XXXX ) But a XX/XX/XXXX study by XXXX of the loans covered by the settlement projected that 50 percent of the modified loans are so untenable they will re-default within a year. 
XXXX ) The terms being offered are so bad that many lawyers are not bothering to seek relief, says XXXX XXXX, an attorney representing underwater borrowers northeast of XXXX XXXX. 
40 ) XXXX estimates that in the past three years he has worked with about 1,000 clients seeking modifications, half of them from Countrywide. 
41 ) He projects that for borrowers who get the five-year, interest-only payments, there is going to be major trouble down the line. " We havent seen the effect yet, '' he says. " They took them out of one loan that was a ticking time bomb and put them into another loan with ticking time bomb features. '' 42 ) Bank of America officials concede that re-default is a major threat, projecting a rate of XXXX percent. 
43 ) But they claim most of these defaults will be a product of growing unemployment, not unfair loan modifications. 
44 ) Housing counselors and attorneys tell a different story. 
XXXX ) They say the modifications BofA is offering under the settlement are not sustainable even for many borrowers with jobs. 
46 ) " As far as I know, none of our clients have gotten a modification under this program, '' says XXXX XXXX, an attorney and director of the XXXX XXXX, a nonprofit community development corporation based in XXXX. 
47 ) " The offers I have seen so far are basically a low-interest-only, fixed rate for five years, and then the loan converts to a principal and interest, which of course, depending on the total amount due, could be a huge jump in the persons total monthly payment ''. 

* * * PUBLIC EMPLOYEE PENSION FUNDS INVESTED HEAVILY IN COUNTRYWIDES CDOs : 48 ) As it turns out, BofA has had good reason not to make its modifications affordable for mortgages now owned by a third party, such as the public employee pension funds that invested heavily, and disastrously, in Countrywides mortgage-backed securities. 
49 ) From XXXX to XXXX, the years covered by the settlement, Countrywide sold most of its first-lien subprime loans as mortgage-backed securities or loan packages, 50 ) but it generally kept the lucrative servicing contracts. 
51 ) BAC Home Loan Servicing ( formerly Countrywide Home Loans Inc. ), Countrywides servicing arm, acts as a bill collector, gathering mortgage payments from borrowers and distributing these payments to the investors who actually own the mortgages. 
52 ) Servicers earn a small percentage of mortgage payments, but what has made the business especially profitable are late fees and other ancillary costs such as property inspections, collected from borrowers in delinquency and in default. 

53 ) Those revenues will be lost through the settlement with the state attorneys general, 54 ) which requires BofA to waive outstanding late fees for delinquent Countrywide borrowers who receive a modification. 
55 ) But BofA can start the lucrative late-fee gravy train all over for all the borrowers who re-default on modified loansa staggering number, if the XXXX projections prove to be accurate. 
56 ) When these financially exhausted borrowers finally go into foreclosure, any outstanding late fees can be tacked onto the bill BofA submits to investors. 

57 ) Only about 12 percent of the first-lien loans initiated by Countrywide remain on BofAs books 58 ) Investors in mortgage-backed securities, including major pension funds like XXXX  XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX  XXXX XXXX own the other 88 percent, 59 ) and it is these investors who will bear most of the expense of complying with the settlement, in the form of permanently reduced principal and interest payments on their bond holdings. 
60 ) Believe it or not, this aspect of the deal was overlooked by the settlement. 
61 ) XXXX XXXX, attorney general of Connecticut, one of the original parties to the suit, seems to have missed it entirely, claiming in his XX/XX/XXXX announcement, " This settlement will cost BofA as much as {$8.00} XXXX, but no cost, not a dime, to taxpayers.? '' 62 ) In fact, as it turned out later, much of the settlements cost would be covered by taxpayers. 
63 ) Bank of America is allowed to use federal incentives under President Obamas {$75.00} XXXX Home Affordable Modification Program ( HAMP ) toward the loan modifications it is required to make as the mortgage servicer for the Countrywide portfolio. 
64 ) In total, of its entire Countrywide financial servicing portfoliowhich goes beyond the loans covered by the settlementBofA is eligible for as much as {$4.00} XXXX in federal incentives for completed modifications, according to an analysis by the XXXXXXXX XXXX XXXX XXXX as reported in XXXX XXXX. Thats a hefty government rebate. 

65 ) There are indications that Bank of Americas slow progress on loan modifications is intentional. 
66 ) Many service providers on the front lines of the crisis were unaware of the settlement more than a year after it took effect. 
67 ) Take XXXX XXXX, a team leader in the housing department of XXXX XXXX XXXX, a HUD-approved counseling agency in XXXX XXXX XXXX Of the hundreds of Countrywide borrowers, hes tried to obtain loan modifications for, " not one of them has mentioned anything regarding the attorneys general modification, '' he says. 

68 ) Why dont borrowers know about the settlement?

69 ) If they received a notification letter like the one Bank of America officials gave me after weeks of prodding, they would have no clue they were one of the covered homeowners. 

70 ) Nowhere in the letter is there explicit mention of the settlement. Theres no mention of borrowers rights, such as waiving of late fees for those who qualify for modification.

71 ) And the letter fails to mention the settlements most attractive modification option : principal write-down, the only measure that could make a significant difference to borrowers who have seen the value of their homes decline by 50 percent or more. 


71 ) Bank of Americas opaque public outreach apparently passes muster with the California attorney general. 

72 ) An official in the AGs office who declined to be named told me the notification letter " is not necessarily going to reference the settlement. '' 73 ) He went on to express concern about the plaintiffs themselves, the very people the settlement was designed to protect. 

NOW WHEN IT COMES TO HOMEOWNRES - THEIR WORRIED ABOUT MORAL HAZARD? 
IN THE FACE OF TRILLIONS OF DOLLARS OF SWINDELED LOSSES COMMITTED BY CORRUPT BANKING AND MORTGAGE INSTITUTIONS, AS WELL AS CORRUPT GOVERNMENATL REGULATION AND SO-CALLED OVERSIGHT! 
ALL - AT THE ULTIMATE EXPENSE OF HOMEOWNERS AND INVESTORS 74 ) " There is a moral hazard problem with all of this, which is that you dont want to encourage borrowers who can afford their loans to default, or borrowers who dont believe they were victims of fraud to default, '' he says. 
75 ) " So, there is a fine line that had to be walked in figuring out how to publicize, announce and communicate with borrowers. '' * * * 76 ) The settlements most fatal flaw may be its failure to cover second liens. Bank of America still owns a large number of Countrywides second liens outright, including its once popular Home Equity Lines of Credit ( HELOCs ). 

77 ) Today the bank is the largest holder of second-lien loans in the country, which are valued at {$140.00} XXXX. ( Second-lien loans, which are tacked onto the original first-lien mortgage, include home-equity loans used to finance everything from home improvements to hospitalization to coverage of 1520 percent of the purchase price of a house. ) 78 ) XXXX alleges that Countrywide employees broke the same laws in selling those loans as they did in selling first liens. 
79 ) According to the XXXX lawsuit, Countrywide loan officers " further [ ed ] their deceptive scheme '' by " urging borrowers to encumber their homes up to 100 % ( or more ) of the assessed value ; and placing borrowers in piggyback second mortgages in the form of higher interest HELOCs while obscuring their monthly payment obligations. '' 80 ) A settlement that covered second liens would have improved the prospects for victims of Countrywides predations. 
81 ) Federal officials and mortgage analysts have identified second liens as a major factor in at least half the mortgages in danger of default. Such a loan works against borrowers in several ways. 

82 ) Not only does it stick them with a greater debt burden ; it also stands in the way of principal reduction on the first mortgage, since a second lien must usually be wiped out before principal can be written down on the first loan. 

83 ) The attorneys general seem to have left this gaping loophole for pure expediency. 
84 ) " We do allege misconduct related to the origination of second liens and HELOCs, '' says the XXXX AG official. " However, for purposes of settling the case, we wanted to craft a settlement that, while not perfect, would have the most effective chance of saving homeowners as quickly as possible. We were in a situation where the housing crisis was expanding by the moment. They [ Bank of America ] could have dragged out the negotiations for two years, during which time innumerable residents of California and other states could have lost their homes to foreclosure. '' 85 ) Earlier this year Bank of America finally indicated some willingness to address the second-lien issue XXXX On XX/XX/XXXX the bank announced to much positive press that it was the first servicer to sign up for a resuscitated federal effort known as the Second Lien Modification Program, which the Obama administration had been trying to get off the ground since spring XXXX. 

86 ) In XXXX, facing additional legal action over Countrywides predatory lending practices, Bank of America reached another settlement, this one with Massachusetts. 
87 ) Under that deal, the settlement XXXX negotiated was expandedBank of America would now offer principal reductions to about 45,000 severely underwater Countrywide borrowers. Notably, BofA will offer these principal reductions only to borrowers who qualify for HAMP, under which the bank gets bailed out by taxpayers. 


88 ) The Countrywide settlement, says XXXX XXXX, associate director of the XXXX XXXX XXXX, a statewide organization that advocates for low-income communities, has failed to protect homeowners who were the victims of predatory lending on an epidemic scale. 
89 ) " Fraud and predatory lending really created this crisis we are in, and nobody is taking that into account, '' says XXXX. " That was a concern we had with the original settlement. They dont admit any fraud. "? 


90 ) Now state attorneys general might finally have an opportunity to help the thousands of defrauded Countrywide borrowers who have fallen through the cracks. 
91 ) On XX/XX/XXXX Bank of America announced that it was temporarily suspending foreclosures in all fifty states in response to revelations of false or fraudulent documentation and at least one BofA " robo-signer '' who approved thousands of foreclosure papers without proper review. 
92 ) Even so, BofA appears confident that it has done nothing wrong. " We will stop foreclosure sales until our assessment has been satisfactorily completed, '' states a BofA press release. 
93 ) " Our ongoing assessment shows the basis for our past foreclosure decisions is accurate. We continue to serve the interests of our customers, investors and communities. Providing solutions for distressed homeowners remains our primary focus. '' Its up to the attorneys general, in their newly announced investigation, to hold BofA to its word. 


Countrywide exploited the American dream of homeownership and then sold its mortgages for huge profits on the secondary market, Attorney General XXXX said. The company sold ever-increasing numbers of complex and risky home loans, as quickly as possible. Countrywide was, in essence, a mass-production loan factory, producing ever-increasing streams of debt without regard for borrowers who were ripped off by Countrywides deceptive scheme.

Despite receiving numerous complaints from borrowers claiming that they did not understand their loan terms, Countrywide ignored loan officers deceptive practices and loose underwriting standards. Countrywide also pushed its borrowers to serially refinance, repeatedly urging borrowers to obtain home loans to pay off their current debt. 

http : //ag.ca.gov/contact/complaint_form.php? cmplt=CL People v. Countrywide XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX 


Intentional Misrepresentations : ( Appraisal Process ) XXXX XXXX XXXX XXXX XXXX XXXX , thXXXX appraisal company used by Countrywide in my XXXX loan origination, - settled class action lawsuit accusing them of illegal appraisals regarding title and collateral valuation within their loan origination operational practices. 

Countrywides Mandate for Growth - Countrywide ceased acting as a conventional money lender, but instead morphed into an enterprise engaged in systematic fraud. This systematic fraud extended to the fraudulent appraisal process of a silent market fixing scheme through a policy of exercising control over appraisers including their loan origination values. 

1A ) Countrywides massive scheme to artificially inflate property values and fix the Real Estate Market through its wholly-owned subsidiary, XXXX XXXX authority to bind, meant to difference between being qualified for a home loan and being able to afford a home loan. 

1B ) Countrywide turned substantial profit through their borrowers default, - furthering their incentive to intentionally place borrowers into impossible and unaffordable home loans. 

1C ) Countrywide misled public and were well aware of their fraud. Countrywide intentionally misrepresented, and concealed information which they knew was highly material to the decision for a prospective customer to enter into a loan with Countrywide. 

1D ) Countrywides improper securitization, the foreclosing trusts had no ownership interest in homeowner Notes or Deeds of Trust under the explicit terms of their own Pooling and Service Agreements. There is no Chain of Title. Understanding MERS, - and its role in Countrywides wrongful foreclosure process. 

1E ) Countrywides violation of numerous other laws, and pervasive schemes of fraud and deception, ( along with many other financial institutions, such as Bank of America ), substantially contributed to the United States national housing market crash of XXXX, essentially, overnight wiping out the home values of millions of America homeowners nationwide, who were otherwise completely innocent of these events! Triggering the overnight catastrophe that resulted in the substantial devaluing of millions of American homeowner properties, which directly lead to millions of American homeowners losing their properties through foreclosure nationwide! 

Relationship of Bank of America to Countrywide 63. BofAs public disclosures, as reflected in its filings with the SEC, make clear that BofA considers itself both a common enterprise operating as a greater whole and without meaningful distinctions as to its operating units, and the successor to Countrywide and its subsidiaries. As stated in BofAs Annual Report on Form 10-K for the fiscal year ended XX/XX/XXXX ( BofA XXXX XXXX K ), [ i ] n XXXX of XXXX, we made a {$2.00} XXXX investment in Countrywide Financial Corporation ( Countrywide ), the largest mortgage lender in the U.S. 
In XX/XX/XXXX, we announced a definitive agreement to purchase all outstanding shares of Countrywide... The acquisition would make us the nations leading mortgage lender and loan servicer. BofA XXXX 10-K, at XXXX. 
64. Thereafter, as stated in BofAs Quarterly Report on Form 10-Q for the quarterly period ended XX/XX/XXXX ( BofA XX/XX/XXXX 10-Q ), On XX/XX/XXXX, the Corporation acquired Countrywide through its merger XXXX a subsidiary of the Corporation. BofA XX/XX/XXXX 10-Q at XXXX. 

- 17 XX/XX/XXXX the extent that certain Plaintiffs herein become aware of information that provides a basis for asserting the Defendants herein are liable for the origination of their loans, those Plaintiffs reserve the right to seek leave of this Court to re-assert the appropriate claims herein. 

COMPLAINT Lawley, et. al. v. Bank of America, et. al. 
Again, BofA boasts in the BofA XX/XX/XXXX 10-Q that The acquisition of Countrywide significantly improved our mortgage originating and servicing capabilities, while making us the nations leading mortgage originator and servicer. BofA XX/XX/XXXX 10-Q at XXXX. 
65. BofA further makes clear the commonality of its business enterprise with that of Countrywide, and the greater whole of its various subsidiaries and operating units, by stating again that On XX/XX/XXXX, the Corporation acquired Countrywide... creating the nations largest mortgage originator and servicer. BofA XX/XX/XXXX 10-Q at XXXX. 
66. Countrywides remaining operations and employees have been transferred to Bank of America, and Bank of America ceased using the Countrywide name in XX/XX/XXXX. 
# 6 Specific Bank of America Violations On XX/XX/XXXX, a XXXX XXXX XXXXXXXX XXXX Form 25 was utilized to deregister and delist Countrywides common stock, and on XX/XX/XXXX Countrywide filed Securities and Exchange Commission Form 15 deregistering its common stock under Section 12 ( b ) of the Securities Exchange Act of 1934, as amended.

67. Plaintiffs are informed and believe, and thereon allege, that : ( 1 ) BofA and its wholly- owned and controlled subsidiaries are liable for all wrongful acts of Countrywide prior to the date thereof as the successor-in-interest to Countrywide ; ( 2 ) BofA directly and through its subsidiaries and other agents sued herein as Does have continued the unlawful practices of Countrywide since XX/XX/XXXX, including, without limitation thereof : 1 ) writing fraudulent mortgages as set forth above 2 ) concealing wrongful acts that occurred in whole or in part prior thereto, 3 ) BofA and its subsidiaries are jointly and severally liable as alter egos and as a single, greater unified whole. 

Bank of America N.A. Successor by Merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP, its Assignees and Successors.

If a Trustee, Paying Agent or Registrar consolidates with, merges or converts into, or transfers all or substantially all of its corporate trust assets to another corporation, the resulting, surviving or transferee corporation without any further act shall be the successor. 





Dear Bank of America N.A. Home Loans, - according to your own research per Department of Justice notice dated XX/XX/XXXX, Bank of America N.A. Home Loans, fka Countrywide Home Loans, my Home Equity Line of Credit, ( HELOC ), account ending in XXXX was approved for participation in a principal forgiveness program offered as a result of the Department of Justice and State Attorneys General national settlement with major mortgage services, including Bank of America. 

I stated, I received a full forgiveness not because of some random form of charity, or anonymous altruism, because my family is just one of literally millions of unsuspecting, Innocent homeowners who fell prey to the unbelievable scale of fraud, especially within the appraisal process engaged in by Countrywide Home Loans, currently Bank of America N.A. 

I am again requesting that Bank of America return in full all payments made between XX/XX/XXXX to XX/XX/XXXX, approximately, {$5000.00}. 

Also, the fraudulent reverse mortgage my mother entered into with Financial Freedom Senior Funding in December 2004, is a subsidiary of Countrywide Home Loans, and therefore with the purview and responsibility of Bank of America N.A. as successor by merger to Countrywide Home Loans LP. 

Also, as I have repeatedly complained, my refinance of my parents home is riddled with fraud and abuse, especially within the XXXX XXXX process as I have repeatedly tried to draw your attention to? 

Not only was I at a complete disadvantage dealing with the predatory refinance department at Countrywide, but I was devastated and in severe mourning at the death of my dear and sweet mother. The refinance department at countrywide saw me coming, and took complete advantage of me, having me assume not only a {$54000.00} plus reverse mortgage that my mother had unknowing entered just 2 years prior, but also the mind numbing fact that despite my parents having paid approximately {$82000.00} from the period between XX/XX/XXXX to XX/XX/XXXX in mostly interest only payments, and an additional {$54000.00}, with Countrywide charging a closing fee of {$10.00}, XXXX from XX/XX/XXXX to the time of my mothers death on XX/XX/XXXX. 

I am requesting that my complaint be immediately reconsidered with a positive resolution in the favor of myself and my family for we are the horrible victims of extremely documented fraud, misrepresentation and homeowner abuse.