This complaint is in regard to a Home Equity Line of Credit XXXX " HELOC '' ) and is supported by a sworn affidavit based on firsthand personal knowledge. XXXX has written several inquiries in the form of Qualified Written Requests ( " QWRs ) to Chase ( JPMCB ) in an effort to ascertain information about the subject HELOC without success ( Attachment A ). Letters sent to Chase asking pertinent details were not answered in full as required by RESPA 12 USC 2605 -e. 

Evidence found in the public record and copies of certain documents received from Chase ( JPMCB ) in response to requests reveal that fraudulent activity has taken place throughout the transaction, from the beginning, and that fraudulent activity continues to the present day. 
In violation of RESPA, Chase failed to respond to QWR inquiries into the relevance and significance of XXXX different account numbers associated with the Home Equity Line of Credit ; Chase failed to respond to QWR inquiries into 'Accounting and servicing systems ' stating, " This information is proprietary and will not be provided. " ; Chase failed to fully respond to QWR inquiries into 'Debits and credits ' stating, " Some of this information is either proprietary or unavailable, and will not be provided. " ; Chase failed to fully respond to QWR 'Servicing-related questions ', stating, in part, " Any assignment of the Security Instrument, previous sellers, purchasers, assignors, and assignees would be a matter of public record. Please review public record for this information. " ; and, " Some of the information requested under this section is either proprietary or unavailable, and will not be provided. " ; Chase failed to respond simple " yes '' or " no '' questions in QWR dated XXXX XXXX, 2015. 
There is evidence that the original Loan Application contained figures falsified by Chase - not by the Applicants - representing amounts which greatly overstated Applicant ( XXXX XXXX true monthly income under each of the XXXX the sections captioned " Gross Income '' for the Applicant ( XXXX ). 
We allege that the original application was altered by parties employed or authorized by Chase without Applicants ' knowledge or permission in order to monetize and/or securitize the line of credit. 
It is our position that the alterations were made with the intent of increasing the value of the application and/or related documents to Chase for use in subsequent JPMCB deals, transactions, sales, conversions, contracts, and other schemes to benefit JPMCB. 
In addition, unbeknownst to Applicant XXXX XXXX ), JPMCB converted or otherwise misused Applicant XXXX XXXX XXXX personal information and data on the application, along with the other documents/and credit agreements Applicants were induced to sign, to create other type XXXX XXXX ) of financial instrument ( XXXX ) and/or securities. 
Applicants did not sign a Note. It is our position that JPMCB ( Chase XXXX, in fraudulently creating said Note ( XXXX XXXX, engaged in Identity Theft of XXXX 's personal identifying information in violation of the Identity Theft and Assumption Deterrence Act of 1998 XXXX " the Act '' ), XXXX XXXX XXXX, making it a felony to knowingly transfer without lawful authority a means of identification of another person with the intent to commit ... or aid and abet any unlawful activity. 
Further, Affiant alleges that Chase is pursuing a foreclosure action in the XXXXe Court XXXX New York XXXX XXXX of XXXX, which is unwarranted and that Chase has come to the court with unclean hands : The mortgage transaction is void. ( It is legal maxim that fraud vitiates all contracts. ) A valid note does not exist. A default of the subject HELOC has not been proved - due to improper, undisclosed, incomplete and inaccurate accounting. The law firm of XXXX, XXXX and XXXX XXXX has committed fraud upon the court by submitting false documents.