Consumer complaint received 2023-01-21
Product: Mortgage — VA mortgage
Issue: Closing on a mortgage — 
Company: United Military Mortgage, LLC (ID)

CFPB		Complaint by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Sellers Lenders Servicers Insurers; Originating, Participating & Profiting from Fraud in this VA Home Loan Real Estate Transaction of:	XXXX  XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Low VA Rates, LLC., are under a monitoring agreement with CFPB, and we believe their participation in the fraud outlined in this complaint clearly demonstrates their willingness to continue to deal in financial deceptions. 

This complaint involves the below companies, and the timelines they actively participated.

Referred to as		Company or Companies

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX (LVAR) XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, ceased to legally exist in XXXX  and were counterfeit and fraud in being used past that date. These identification numbers were used to create and develop the address of XXXX XXXX XXXX XXXX XXXX Idaho XXXX, as a legally New manufactured home, set and declared as real property.

These counterfeit numbers are the sole source of every contract in this complaint that every participating company or individual in this transaction relies upon. The creation of the fraud was intentionally calculated and designed to be concealed for illicit gain.

Unless otherwise stated, this section refers to the XXXX  transaction.  (mh) refers to manufactured home, whereas (ms) refers to manufactured salvage/structure. XXXX XXXX XXXX XXXX XXXX XXXX, responded to a publicly advertised real estate mls in XXXX  for a home on XXXX acres. The property at XXXX XXXX XXXX XXXX XXXX XXXX XXXX was offered by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, referred to as the XXXX Sellers. (Exhibit 1)
a.	XXXX  is affiliated with XXXX XXXX XXXX XXXX XXXX), the XXXX XXXX XXXX XXXX XXXX XXXX agent acted on behalf of us and XXXX Sellers and informed us that this property was sold a first-time in XXXX  and the manufactured home (mh) on it was new when set in XXXX. (Exhibit 1b)
i.	We asked why no title was obtained, and were assured the title had been eliminated, by the Certificate of Origin (as a new mh when set as real property in XXXX), and the vehicle title was surrendered through the DMV process.
c.	We had the right to believe and rely upon what was presented to us was true by XXXX  in the XXXX  deal. XXXX  breached contract by fraudulent misrepresentation. (Exhibit 1c)

2.	The property listing we were initially drawn toward was, (Exhibit 2), fit VA requirements, per our realtor and lender. The mls listed the manufactured home (mh), advertised as High-end XXXX  XXXX  XXXX sq. ft, VA financeable.
a.	It was originally presented to be new in XXXX, according to a prior mls listing. (Exhibit 2a) 

3.	Our realtor agent urged a referral for Lenders agent, who was with XXXX XXXX XXXX, who in turn referred us to the structural engineer, appraiser and the property Title Insurer, XXXX XXXX XXXX XXXX XXXX. We were told that this little group worked well together, and each knew their duties.
a.	The Appraiser, in his VA and Lender appraisal, noted no HUD Labels, (Exhibit 3a), yet still completed his appraisal, comparing this illegally set structure to legally set ones.
i.	Appraiser, according to the HUD rules, should have stopped. Instead he continued and completed his appraisal report as if everything was complete and legal. (Exhibit 3i)
b.	The VA has informed us that if the facts of this appraisal do not meet the requirements, their remedy could be to indemnify the VA obligation in this loan/contract.
c.	In XXXX, VA staff verbally advised us not to make further repair on the (ms) since our intent is to have it removed and replaced to the legal purchase that we intended and believed was made in XXXX.
d. Sellers and Lenders did not obtain the legally required HUD certification verified through the national database, IBTS, (Institute of Building Technology & Safety). (Exhibit 15) e. Given that the (mh) was presumed and advertised as new in XXXX, there was no logical excuse or reason for this legally vital information to not have been available. (Exhibit 3e)
f.	We have been repeatedly informed by nearly everyone we have discussed this with, that the process is simple; when HUD Labels are missing, then an IBTS equivalent is required, which, to this date, on this property, nobody but us has ever provided. The one we got in XXXX  should have been obtained in XXXX  by Sellers, Lender, etc., and our IBTS confirms the transaction was never legal. 4. The entire XXXX home property sale and purchase turned out to be a clear fraud.
a.	The (mh) being advertised, presented and sold, was not even close to any of the mls descriptions. The claimed (mh) was, in fact, legally a manufactured salvage (ms), and legally non-existent past XXXX. 5. Sellers, Lenders, Servicers, etc., had a duty to know this sale was not legal, that the (mh) was not financeable under VA, nor legally existed past XXXX, when it was wrecked, HUD decertified and only for salvage use.
a. Sellers, Lenders, Servicers and Insurers rules, guidelines and/or procedures, require knowing it.
i.	Each financial institution admits knowing the rules; each point to another for liability. 6. The fact is that all the profiting institutions and/or agents misrepresented and misled us in the XXXX fraudulent sale, and none complied with the legally required duty to disclose.
a.	The financially profiting parties assured us all requirements were met and the sale was good to go. We believed and trusted them that the (ms) was as advertised, and was legally set, legally declared and legally taxed as real property. 7.	Additional concealment was in Sellers  contract, where Sellers inserted non-existent HUD Label certification numbers as if they had legal standing, knowing they were not legitimate. (Exhibit 7)
a.	Every contract or obligation that relied on this forged and fraudulent information is counterfeit. 8. With parties assurances of legal compliance, we closed the mortgage deal in XXXX, XXXX. This closing further buried the intentionally, fraudulently concealed information, that is now known to us, from which Sellers, etc., created the financial fraud which continues to compound damages.
a.	The VA (Veterans Affairs) acted as guaranty and has informed us that it would not have done so had the true history and character of the home property been known. 9.	Sellers breached our XXXX  contract; the (ms) property was not legally insurable. (Exhibit 9). a.	Our home-owner insurance was cancelled after the confirmed fraud. Multiple attempts to obtain other home property insurance (aside from liability), is unavailable. (Exhibit 9a)
b.	Sellers, XXXX XXXX XXXX, had a duty to know of the fraud in XXXX. (Exhibit 13a) c. Sellers  all had a duty to not commit real property mortgage fraud; the (ms) was not eligible to sale for habitation purposes, and Sellers, Realtors, Lenders and Insurers knew that our intent was to purchase a home. (Exhibit 9c).
d.	We relied on the representation of the (ms) as legally qualifying and it did not. (Exhibit 9d) Sellers, etc., had a duty to know the (ms) was not eligible under Seller, VA, etc., rules. (XXXX)
XXXX.	Our XXXX  title insurance policy/contract with XXXX, etc., states, Amount of Insurance: XXXX. This figure is derived from the entire purchase price which included the (ms), not just the XXXX valuation for acreage only, that Insurers  now claim thats all it covers. (Exhibit 10)
a. Insurers took money from us to cover the (ms). We insist this is proof the (ms) is fully covered.
b.	Our contract affirmatively covers adverse events of fraud, forgery, improper or unauthorized filings in official records, and adverse events affecting property marketability, insurability, use, enjoyment, and character. (Exhibit 10b) 11.	The description of land in the contract include the structures, i.e., affixed improvements (ms).
(g) "Land": The land described in Schedule A, and affixed improvements that by law constitute real property... 
XXXX	ALTA (American Land & Title Association) adopted XXXX  rules that clarify a manufactured home set as real property is to be covered. (Exhibit 11a and 11b) 12.	In order for Insurer to exclude/deny coverage of the (ms) in an adverse (fraud or other) event discovered, a XXXX Exception is required to have been issued in our XXXX  contract in Schedule B, and there is no XXXX existing anywhere in this contract. (Exhibit 12) a.	Insurers failed or refused to use the required XXXX language shows an understood intent that this (ms) is covered. This is confirmed by the XXXX  Commitment requiring (mh) Endorsements (Exhibit 12a) and the Lenders were specifically issued added XXXX XXXX  Endorsements. (Exhibit 12b and 12c) ii.	We question Insurers motivation in omitting the required XXXX language in the contract, as a deliberate, extension of favoritism to the Lender in order to grant XXXX XXXX Endorsements.
	iii.	Had Insurers used the XXXX in the policy/contract, Lenders would not have had any access to any XXXX XXXX  Endorsement granting any security for any loss incurred by the (ms) title matters. If XXXX  didnt get XXXX XXXX protections, we are convinced this sale would have been rejected by them.
b.	Having no XXXX in our contract requires Insurers pay our total loss claim. i. Insurers denial of our claim reflects being clearly ambiguous and prejudicial.
	ii.	We would have rejected the entire purchase if there was XXXX  language as that would have clearly omitted the purpose for the home loan purchase.
c.	Our contract instructs Insurer  is to pay a claim within 30-days of the claim submitted to them. We can only conclude that Insurers denial of our claim is intentionally motivated to cause us harm. i. Insurers are to pay an additional XXXXXXXX for delay of payment in covering this claim.
ii. Insurers  are to pay to replace the (ms) at todays replacement costs per our contract. 13. Insurer  agentXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, has used the word fraud in verbally discussing this case. XXXX XXXX has refused to respond to inquiry.
a. Insurers who exclude coverage after a claim is filed for discovered and confirmed adverse event, is nothing short of a fraudulent act in itself, or an outright theft, by Insurers. 14. When the fraud was confirmed XXXX  of XXXX, it was becoming clearer of how involved this concealed fraud and forgery matter is. It was exposed only in going outside of the small circle of the XXXX  recommended individuals who all participated in this sale. What we were starting to discover was:
a.	The (ms) was not eligible by governing rules to sell as VA financeable. (Exhibit 13a). b.	It is logical to conclude that if Sellers, by their own rules are prohibited from obtaining control of a property, then its equally logical to conclude they had no legal right to sell it.

15. The fraud remained concealed in Sellers and Lenders  refusal to obtain IBTS  in XXXX. Had it been done, the fraud would have been revealed as it was when we received IBTS  letter in XXXX. (Exhibit 15) a.	Had Sellers and Lenders  obtained the required IBTS, this legal dilemma would not exist.
	i.	The only questions we now have are, was this gross negligence, or something more nefarious, for example, did one or more individuals have personal knowledge of the fraud, refused to admit what they knew, and chose to participate in it?
	ii.	We do know that a representative at XXXX XXXX in XXXX XXXX Idaho, had heard of this event. The representative admitted that there were only a handful of transport companies, and the news of this transport damage apparently made it a talking point in the local region. So, how many others participated in this industry conversation?
b.	The ms did not legally exist after being wrecked, decertified and paid off as total loss by XXXX XXXX XXXX in XXXX. (Exhibit 15b) c.	Manufacturer built a new manufactured home for the original buyer. (Exhibit 15c)
i.	The salvage structure was obtained by a dealer who originated this intentional, concealed, orchestrated real property fraud for the purpose of illicit financial gain.
ii.	The (ms) HUD Labels were ordered removed. The supporting documents, including the XXXX, and XXXX  should have been removed and destroyed or returned to the manufacturer and in compliance with this process it would have ensured that this fraud never could have happened.
iii.	The documents were not returned. In fact, they were used in the official records, and later relied upon by the appraisers and the engineers reports. (Exhibit 3a and 15ciii)
d.	On XXXX XXXX XXXX, a manufacturer manager stated the (ms) did not legally exist; he advised we speak with the XXXX  Dept. of Building Safety, XXXX XXXX (Exhibit 15d) XXXX XXXX XXXX later informed us: not for human occupancy or habitation and there is no process in Idaho to set (XXXX on a permanent foundation as real property. (Exhibit 15e)

16.	The wrecked, for salvage use ms, was obtained by a then XXXX  dealer, who bought this property and developed it, into what is now known as XXXX XXXX XXXX XXXX XXXX Idaho.
a.	The mh  dealer knowingly used fraudulent, forged, non-existent HUD Certification Labels of XXXX and XXXX, in union with Serial XXXX and XXXX.
i.	These numbers legally ceased to exist in XXXX, were used, and theres your fraud.

XXXX. Sellers, Lenders, etc., had to clearly know that this sale was not legally allowed to be performed.
a.	Sellers, etc., committed financial mortgage fraud. 18.	XXXX XXXX, XXXX, linked to XXXX, XXXX XXXX XXXX XXXX, had legal and regulatory duty to maintain filed proof of the (ms) as HUD certified or XXXX  verified.
a.	XXXX  and XXXX  Lenders  immediately transferred the Servicer  contract to XXXX XXXX XXXX No Seller, Servicer or Lender has produced to date the HUD certification or XXXX  equivalent.
19. The Veteran Affairs has informed us that the Lenders are required to obtain HUD certification verification from the national databank when HUD Labels are missing from a (ms) in a VA home loan.
a. XXXX XXXX XXXX, VA communication with us confirms Lender had a duty to obtain the XXXX verification letter to assure compliance. (Exhibit 19a)

XXXX LVAR  Actively Conceals the Fraud

From what we have learned from the Lender, LVAR, between this current (XXXX) situation dealing with this property fraud, and their past history of deceptive actions towards veterans, we think the CFPB will be justified to take a closer look at their participation in the XXXX  refinance to now.

Lender  Low VA Rates, LLC., (LVAR), utilized fraudulent and incomplete documents from the XXXX  file for the XXXX  refinance of our VA home property loan.

XXXX.	In XXXX, interest rates were low, and we looked into a refinance with Low VA Rates, LLCXXXX LVAR informed us the refinance (which would cost us nearly XXXXXXXX), would be a fixed rate at 1.75% for the first three years, and then would become an ARM, with an up to 1% increase or decrease in any given year, depending on the apr, but insisted they have never witnessed an increase or decrease of more than half a percent. This would eliminate the fixed rate of 3.75% we were paying.
a.	The economy was drastically different in XXXX  from XXXX, and equity was climbing.
b.	We asked LVAR if we needed to obtain a new appraisal and were informed none was required in a refinance. We were also told since the original was already in the file, that is what they would use.
c.	We paid professionals and believed hook, line and sinker, what we were being told was true, having no idea of the fraud at this point, though the fact information, i.e., referring to the XXXX  appraisal was in the file and should have red-flagged and killed the refinance being sought. (Exhibits 3a, 3e and 3i) 

21. LVAR never addressed the missing HUD Labels, though they had the appraisal.
a.	It makes us wonder what documents XXXX XXXX received from LVAR to grant XXXXXXXX  7 favoritism regarding the (ms). (Exhibit 21a)

XXXXXXXX XXXX XXXX XXXX continued as Servicer.

In XXXX, the Confirmation of the Mortgage Fraud

Due to the economic chaos and instability real estate property values were sky-rocketing and interest rates were dropping, we decided to look into consolidating some high-interest debt into a low-interest HELOC. 23.	In XXXX  of XXXX, we wanted to clear up credit card debt and free up funds for home repairs. Our bank required HUD Label pictures. We couldn't find any HUD Labels (tags), which were to be on the outside of the 'home'. (Exhibits 3a, 3e and 3i) 24.	We spoke with our XXXX  realtor who said the that the (mh) was HUD certified, and likely the tags were painted over or accidently removed in a re-siding or repair.
a.	We attempted to communicate with the (mh) dealer who developed this property and declared in XXXX  that the (mh) he placed here was new. The dealer never took up residence at this address.
b.	We asked the (mh) manufacturer where else the HUD Labels might be and were told they are on the outside end corners of each section of the (mh). We were advised that people often accidentally paint over them or remove them in re-siding, not realizing their importance. We were told to feel for raised areas for the XXXX riveted metal tags.

25.	Finding no HUD Labels, our HELOC  was denied. XXXX XXXX spoke with the bank President who granted the small HELOC using realtor assurance and tax records that the (mh) was HUD certified.

LOOKING BACK AND MOVING FORWARD 26.	About XXXX XXXX XXXX, we received confirmation of irreversible real property mortgage fraud. With the confirmation, we realized the bank had every right to reject the HELOC. (Exhibit 15e) a.	Prior to XXXX XXXX, we were assured by the XXXX Realtor, Lender and Engineer agents that the (ms) was HUD certified, or the XXXX  loan could not have closed, and we were worried about nothing. These individuals recommended that we seek legal counsel and to file a claim with our title insurance.
	i.	We communicated with and later retained counsel in the fall of XXXX.
	ii.	We informed our home property insurance, who advised we file a title insurance claim.
		A.	We filed a claim with the Title Insurers; XXXX  denied the claim. 27.	After informing our bank of our findings, we were told no further loan will be granted with this property as collateral.
a.	Through the grace of God, the bank said we could just continue making our payments and they would not require the full balance to be returned immediately.

CONFIRMING FRAUD

28.	On XXXX XXXX XXXX, the (ms) manufacturer sent us the wreck report. (Exhibit 15b & c). a.	This information prompted us to contact the XXXX  XXXX  agent who insisted that the VA home loan could not close without the XXXX  HUD certification. She insisted the (ms) was HUD certified. 
	i.	She said since she no longer was with XXXX XXXX XXXX (now XXXX), she had no access to the old file, and to contact them and request a copy. When XXXX  said it was no longer the lender and we needed to contact LVAR for the information, our Lender agent said all we needed to do was to purchase an IBTS letter and this would verify HUD compliance.
b.	We purchased the XXXX  connected with this (ms); it confirmed the wreck report. (Exhibit 15) c.	To date the appraiser has refused to comment why he did not condition the (ms) appraisal for XXXX  compliance status. (Exhibit 15f)
	i.	We want to know how he compared a non-HUD certified (ms) with certified properties. 29.	The Engineer was reached in XXXX  of XXXX. He was asked why his XXXX XXXX, XXXX, report to the XXXX  Lenders stated the HUD Label numbers as if he had seen them, when obviously he did not. The Engineer admitted he didnt report the missing HUD so not to kill our loan.
a.	The jaw-dropping information was not taken well. We told the Engineer that truth would have protected us all from this fraud. It was not his job to be concerned whether we got a loan on this property or found another property instead.
b.	The Engineer said he would speak with a friend in the county assessor office to find out how an appraiser was able to compare a non-HUD certified, for salvage use only, (ms), to property legally HUD certified. He said the response received was comparable for salvage is nil, meaning they dont exist. 
c.	The Engineer advised we speak with the Idaho  Dept. of Building Safety to inquire about the recertification process.
	i.	We did, and the response was Idaho has no re-certification process. A decertified, for salvage structure is no longer legal for human habitation. (Exhibit 15e)
a.	This eliminated any question or doubt as to fraud existing.

30.	We filed our claim in XXXX  of XXXX, with XXXX  XXXX, XXXX as stated above. 
a.	Our insurance contract covers fraud, forgery, etc., and our situation clearly was in the coverage.
b.	XXXX  denied our claim in XXXX  of XXXX  and has denied all requested reconsiderations.
c.	Insurers agent, at XXXX  XXXX, now XXXX XXXX XXXX XXXX XXXX, admits this is fraud, but says XXXX, the (XXXX) dealer, is liable, not the insurance company.  Our contract is with Insurers, not with XXXX.

In XXXX  Continued Inquiry into Mortgage Fraud

We were advised by counsel to inquire about refinancing about how this information would be handled or dealt with by the professionals in the industry.

We put an inquiry into the mortgage web-stream, and were immediately inundated daily with phone calls, postal service and emails -- with offers to refinance!

Low VA Rates, LLC. 31. Low VA Rates, LLC., was adamant it could work around the missing HUD information and could still refinance the property. 
a.	We provided all the information we had, that we are legally required to disclose; they were fully aware that there were problems with XXXX  information.
b.	LVAR  President, XXXX XXXXl admitted our concerns were valid, but obviously didnt care because the loan was already VA guaranteed. (Exhibit 31b)
i.	We were confused by LVAR response that it could work around fraudulent HUD info.
c LVAR continued to press to refinance. We questioned how it could be legally achieved given the situation. (Exhibit 31c).
d.	This shows that even the XXXX penalty imposed by CFPB upon LVAR clearly wasnt a large enough punishment to detour them from continuing to participate in deceptive practices. 32.	LVARs title insurer, Elevated Title, representative, XXXX XXXX  admitted he could not insure the (ms) after receiving the XXXX XXXX XXXX, XXXX  information that we provided to him. We are unclear if LVAR deliberately omitted the correct XXXX  or if it simply intentionally sent him the incorrect XXXX  document. We made it a priority to assure LVAR was informed of the conflict with XXXX  documents to avoid any errors of incorrect application. (Exhibit 32)
a.	We had demanded answers and required confirmation from the title insurance that the manufactured home structure would be covered if a refinance occurred. 33. That ended any hopes of LVAR refinance in XXXX.

-- 	In XXXX, LVAR  told the XXXX XXXX XXXX XXXX that it knew the loan required HUD Labels (tags) certification or XXXX  equivalent. LVAR claims to have the required file. LVAR  has refused to produce the XXXX  HUD certification to us or to the XXXX, to prove that the HUD Label numbers used in XXXX are not fraudulent. 
aXXXX LVAR compliance officer, XXXX XXXX informed us in XXXX, more than once, that a manufactured home involved in a VA refinance requires HUD certification or XXXX  equivalent. This is completely opposite of her boss (XXXX XXXX) position. 
b. LVAR  President, XXXX XXXX  in XXXX, claimed to the XXXX XXXX XXXX XXXX that LVAR would send the XXXX  XXXX  verification by email if requested through XXXX.
i.	This request to LVAR  has been sent multiple times and LVAR has sent nothing. XXXX XXXX XXXX XXXXXXXX XXXX XXXX

Similar to our experience with LVAR,  XXXX XXXX XXXX XXXX XXXX XXXX, appeared to mirror LVAR, in attitude, intent, and process, and was as equally intense to rush a refinance, even when provided full disclosure of the property history to the best of our information and ability.

Unknown to us, XXXX, the potential XXXX  XXXX, who was ultimately rejected by us, in dealing with this property fraud, has a past history of deceptive actions towards veterans, and we think the CFPB is justified to take a closer look at this organizations participation in continued mortgage financial frauds. 34.	In the XXXX  of XXXXXXXX XXXX  was made aware of the fraud connected with this property, including having the XXXX  letter that we personally provided to them.
a.	The company, after many months, eventually acknowledged it could not legally refinance our property. (Exhibit 34a). 35. XXXX was planning to accept the fraudulently created Servicing contract from XXXX XXXX XXXX  who had been the XXXX  since XXXX. XXXX, has since XXXX, been consistently approached by us and requested to provide evidence of their contract legality of XXXX  of XXXX.
a.	XXXX  computer-generated form letters claiming it was still looking for the document in question, were sporadically sent to us, and were nothing more than XXXX  refusal or failure to produce the simple national databank verification, (XXXX), or to just admit that the company never had the information. 36.	DMs  passing the illegal-counterfeit contract to XXXX is no longer passing concealed fraud along, but is in fact, knowingly and willfully participating in this mortgage fraud.
a.	Like XXXX, XXXX has also refused to provide the simple legal compliance proof. 37.	XXXX claim to be unaware of the fraud before taking possession of the contract in an undated, unsigned response to our written inquiries, is a straight up lie. (Exhibit 37)
a.	Multiple proofs exist of XXXX  being informed; evidence is both by electronic and written record.
a.	We demand XXXX explain how it can accept a fraudulent contract that it was aware of was fraud before it took possession of the contract, and how it can be legally enforced for XXXXI illicit gain.

38. The damage is now compounded in the recent loss of our home-owner insurance and our inability to obtain any type of full coverage due to the entire fraudulent and counterfeit transaction.
a.	XXXX informed us the company will obtain its own insurance and force us to pay for it, at a higher rate, as is required in their (legally unenforceable) contract. This is nothing short of actively taking part in extortion. (Exhibit XXXX)

In XXXX, the XXXX XXXX XXXX and LVAR 39. LVAR  multiple times told the XXXX XXXX XXXX XXXX that it had and would send the IBTS that it confirmed it was required to have in its refinance file of XXXX. (Exhibit 39)
a. LVAR has never fulfilled its offer to provide the simple proof. 40.	We have reached out to other finance companies and realtors who agree that the manufactured structure, being described for salvage use, has zero equity value and cannot be financed.
a.	One expert in the real-estate industry who is not part of any of the transactions discussed submitted their overview in writing. Identify is omitted to avoid any repercussion to them. (Exhibit 40a) 
Veteran, XXXX XXXX, has no intention of continuing to pay for the fraud, and intends to restructure how this deal proceeds.

We have submitted some of the many documents that we have in our possession that prove our claims.

SUMMARY 1.	HUD Certification Labels #XXXX  and #XXXX, in union with Serial #XXXXXXXX and XXXX ceased to legally exist in XXXX. They were used to create and develop the address of XXXX XXXX XXXX XXXX XXXX Idaho XXXX, as a legally New manufactured home, set and declared as real property.
a.	These counterfeit numbers are the sole source of every contract in this complaint that every participating company or individual in this transaction relies upon. The creation of the fraud was intentionally calculated and designed to be concealed for illicit gain. 2.	Every company and individual using the non-existent HUD Label information in any contract has actively participated in real property mortgage fraud, knowingly or by refused or failed duties, built on and profited from the original fraud, that should have been discovered during the XXXX  loan process.
a.	Federal CFRs, FHFA, Mortgage, Insurance and State Idaho  Codes of fraud are in violation. 4. Had ONE of the involved performed their legal and fact-check duties in XXXX, none of us would be here today. The fraud would have been revealed at that time. Instead all of the involved either change the subject (or transfer Servicer contracts) and none have stopped the financial hemorrhage of damages.

5.	None of the parties ever produced a scintilla of evidence that any of them were within the legal compliance in this transaction. Clear-cut mortgage fraud occurred, and each company and individual who profited holds a degree of liability, equal to or exceeding the value of our intended purchase in this real estate transaction. 
a.	It is hard to fathom, that out of all the involved companies, individuals and the roles each was to perform, that not one of them refused to move forward, when these missing HUD Labels were noted on the appraisal, and to only continue after the authorized documents were properly obtained. 6.	We have been informed by multiple entities that the restoration remedy here is to remove the structure and replace it with a legally recognized home. This will require major actions of effort, finances and time to address. 7. The issue itself is quite simple. Contracts generated fraud have no legal enforceability. Use of fraudulent contracts defeat the need of professional licenses and certifications to sell their product.
a.	Fraud weakens, cheapens and ultimately destroys everything it touches. 8. We have no intention of continuing to pay for fraud. We are resolved to restructure how this deal proceeds. 9. Sellers, Lenders, Servicers, and Insurers have obviously produced none of the required legal verification documents, because they dont now, nor have they ever obtained them, and all of them have just flat-out refused to admit this simple truth. 10.	Therefore, CFPB should find that all the involved parties be required to initiate full restitution stated below, promptly.

11.	We are in communication with the VA to review this fraudulent home property transaction, and that it indemnify itself from all liability. The VA cannot enforce or participate in acting as a conduit to mortgage fraud. Being a federal agency a higher standard is required by them.

12.	We, XXXX and XXXX XXXX, have submitted the documents needed that clearly prove all XXXX XXXX elements of fraud are met, against all of the companies involved.

If this matter is not resolved now, our intent is to: 1. File legal actions against all involved in the XXXX, XXXX  and XXXX  fraudulent sale and financing. 2. Cease all future mortgage payments to force addressing the finance fraud deception.

Our minimum resolution is below.