Our firm, XXXX XXXX, has been monitoring our clients ' request for mortgage assistance with Bank of America ( " Bank '' ) to help facilitate the process and ensure the Bank 's compliance with Regulation X. For the past several months, the Bank has failed to act diligently and continues to send our clients inappropriate requests for documents that were previously provided or are otherwise unnecessary with no reasonable purpose. Our clients submitted a Request for Mortgage Assistance application on XX/XX/2016 via facsimile ( " Application '' ) to the Bank. The Application was also sent to the Bank as an attachment to a Request for Information sent via certified mail, which they received on XX/XX/2016 according to U.S. Postal Service. Even though the Bank was informed and is fully aware that our clients are represented by counsel in connection with their mortgage loan, the Bank keeps sending correspondence directly to them despite being instructed to send such information to our office instead. 
Our clients submitted applications for assistance for their home mortgage loan and their home equity line of credit account. Bank of America services both accounts and the applications contained identical information and documents. By XX/XX/XXXX, our clients received a trial modification offer in connection with their home equity line of credit account. Despite the foregoing, the Bank still continues to claim the Application for the home mortgage loan is incomplete and ca n't be reviewed. We believe that is nonsense and impossible. 
For the past 5 months, the Bank has been requesting erroneous or duplicate documents in connection with their Application. First, the Bank requested an updated Profit & Loss Statement, XXXX Tax Form, and the XXXX Form instead of the Request for Mortgage Assistance Form that was submitted. The requested items were faxed to the Bank as instructed on XX/XX/XXXX. Five days later on XX/XX/XXXX, the Bank sent another request for documents, which listed the SAME items that were just sent to them. The documents were faxed to the Bank again on XXXX XXXX. Then on XXXX XXXX, the Bank requested updated pay stubs for the co-borrower and another copy of the Profit & Loss submitted claiming they could n't read the one provided. Even though the Bank 's delay is the reason the pay stubs were now " outdated '', we complied with the request and faxed the Bank updated pay stubs and a new copy of the Profit & Loss on XX/XX/XXXX. 
Subsequently on XX/XX/XXXX, the Bank sent our client ANOTHER letter stating the Application was incomplete and requested a letter explaining an item on his Profit & Loss Statement. We faxed the letter of explanation to the Bank on XX/XX/XXXX. Less than a week later, the Bank sent ANOTHER letter requesting the same information about our clients ' Profit & Loss Statement and requested updated pay stubs again too. We sent another letter of explanation related to the Profit & Loss Statement issue to the Bank via fax on XX/XX/XXXX. However, we have not sent updated pay stubs yet because we believe it is incredibly unfair to our clients to have to keep submitting documents on a rolling basis all because the Bank ca n't finish its review in the required time frame. 
We believe these requests are ridiculous and unnecessary. We know the Bank is simply using nonsense to delay the processing of our clients ' Application. Since their other application was already accepted and reviewed, we are absolutely certain the Bank has had a complete package for months and has just been finding ways to delay the process and cause the homeowners XXXX. Since the Borrower XXXX and has provided his XXXX, his business tax returns, and his signed Profit & Loss ; there should n't be anything else holding up the review of the Application.