Consumer complaint received 2025-04-03 00:00:00
Product: Debt collection — Mortgage debt
Issue: Attempts to collect debt not owed — Debt was paid
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: NY

Complaint narrative:
**LEGAL FINDINGS AND FACT SUMMARY** **RE : Unlawful Loan Laundering and Securitization Fraud Involving XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, and Related Parties** **I. INTRODUCTION** These findings establish irrefutable evidence of fraudulent and unlawful mortgage securitization practices, asset laundering, and double-pledging of trust assets orchestrated by Countrywide Home Loans , Inc. ( XXXX XXXX, XXXX  XXXX, XXXX XXXX XXXX  XXXX XXXX XXXX Bank of America , N.A. , and XXXX, resulting in violations of federal and state laws, including securities fraud, bank fraud, and racketeering. 

**II. KEY LOAN IDENTIFICATION** XXXX. XXXX # XXXX - **Borrower : ** XXXX XXXX - XXXX XXXX ** XXXX East XXXX XXXX, XXXX, NJ XXXX XXXX **Original Loan Amount : ** \ {$420000.00} - **Lender : ** XXXX XXXXXXXX - XXXX : ** XXXX XXXXXXXX XXXX XXXX. 
- **Trust : ** XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) - **Trust Closing Date : ** XX/XX/XXXX - **Mortgage Filed : ** XX/XX/XXXX, XXXX XXXX Records XXXX. **Loan # XXXX - **Originator : ** Countrywide XXXX XXXX, XXXX. 
- **Trust Claims : ** XXXX Asset-Backed XXXX XXXX XXXX, XXXX, and XXXX - **Status : ** Found listed in XXXX XXXX deal documents before origination ; ultimately included in XXXX XXXX final pool ; clear evidence of pre-securitization and unlawful asset laundering. 

XXXX. **Loan # XXXX - **Fabricated XXXX Account XXXX : ** Created by Bank of America , N.A . and XXXX XXXXXXXX XXXX XXXX, in collusion with XXXX, to conceal prior securitization failures and launder trust assets. 
- **Purpose : ** Used to fabricate a false paper trail, misrepresenting that Loan # XXXX was not securitized and creating the appearance of an internal file without trust entanglement. 
- **Status : ** No valid recorded mortgage or assignment of record ; an internal XXXX XXXX account number used as part of a fraudulent concealment scheme. 

**III. FINDINGS OF FRAUDULENT CONDUCT** XXXX. **Inclusion of Loan # XXXX in XXXX XXXX- The XXXX XXXX Affidavit ( XXXX XXXX penalty of perjury ) confirms that Loan # XXXX was sold into XXXX XXXX XXXX Trust XXXX for XXXX prior to its trust closing date. 
- XXXX XXXX XXXX XXXX XXXX and trust disclosures confirm the inclusion of this loan based on origination date, amount, and underwriting characteristics. 
- XXXX XXXX XXXX  XXXX, as servicer, subsequently initiated foreclosure and obtained assignment of the mortgage, repurchasing the loan from the trust following default and processing an FHA insurance claim. 

XXXX. **Illegal Loan Laundering Scheme - Loan # XXXX **CWABS XXXX ( Series XXXX ) : ** - No evidence of Loan # XXXX in any SEC filings or final pool documents. XXXX established in early XXXX prior to loan origination. 

**CWABS XXXX ( Series XXXX ) : ** - XXXX # XXXX was listed in preliminary collateral disclosures prior to its XX/XX/XXXX origination. 
- Appears in early XXXX free writing prospectus but not included in final pool as of XX/XX/XXXX due to non-availability by cutoff date. 

**CWABS XXXX ( Series XXXX ) : ** - XXXX # XXXX was added to the trust 's collateral during the Funding Period. 
- Transferred via Subsequent Transfer Agreement dated XX/XX/XXXX, after its XX/XX/XXXX origination. 

This demonstrates that Countrywide intended to securitize XXXX # XXXX prior to origination, initially reserving it for CWABS XXXX and ultimately laundering the asset into CWABS XXXX after origination. 

XXXX. **Fabrication of Loan # XXXX by Bank of America XXXX XXXX XXXX XXXX and XXXX - After discovering securitization failures, XXXX XXXXXXXX XXXX XXXX XXXX. and Bank of America, N.A., in conjunction with XXXX, fabricated XXXX # XXXX as an internal account number. 
- This loan number was created to falsely represent that Loan # XXXX was an internal, unsecuritized file when in fact it had already been sold to XXXX XXXX XXXX XXXX XXXX. 
- The fabricated account number was used to initiate foreclosure proceedings and conceal the loan 's trust asset status, violating state and federal laws. 

XXXX. XXXX XXXX XXXX  XXXX XXXX XXXX XXXX - XXXX XXXX XXXX XXXX XXXX XXXX falsely claimed " XXXX '' ( Person Entitled to Enforce ) status over XXXX # XXXX, despite irrefutable evidence that the loan was sold into GNMA XXXX. 
- XXXX XXXX 's assignment of mortgage recorded XX/XX/XXXX was void, as the loan was a trust asset of GNMA XXXX, and no lawful assignment could occur absent a repurchase. 

XXXX. **Violation of UCC and State Recording Laws** - The indorsement chain fails to comply with N.J.S.A. XXXX, XXXX, and XXXX, as neither XXXX XXXX nor XXXX could legally enforce the obligation. 
- The recorded assignment and foreclosure actions were in violation of XXXX. XXXX and N.J.S.A. XXXX, as the mortgage assignment was legally defective and void XXXX XXXX XXXX 

XXXX. **Investor and Government Defrauding** - By unlawfully securitizing, re-originating, double-pledging, and fabricating internal account numbers for the same debt instruments, Countrywide, XXXX XXXXXXXX XXXX XXXX XXXX XXXX Bank of America XXXX and XXXX XXXX private RMBS investors ( XXXX XXXX ) and the XXXX Government ( XXXX XXXX and FHA insurance program ). 

**IV. LEGAL IMPLICATIONS** The above findings establish violations of : - Securities Fraud ( XXXX XXXX XXXX XXXXXXXX, XXXX XXXX XXXX of XXXX ) - Bank XXXX XXXX XXXXXXXX XXXX XXXX XXXX ) - XXXX XXXX ( XXXX XXXX. XXXX ) - False Claims XXXX ( XXXX XXXX. XXXX et seq. ) - XXXX XXXX ( XXXX XXXX. XXXX et seq. ) - New Jersey State Laws governing real property and XXXX XXXX XXXX enforcement **V. CONCLUSION** These findings will be incorporated into forthcoming litigation, regulatory complaints, and settlement demands against XXXX XXXX XXXX  XXXX XXXX, Bank of America/XXXX  XXXX XXXX XXXX XXXX XXXX XXXX and related parties. The fraudulent securitization scheme and unlawful laundering of trust assets caused financial harm to the XXXXXXXX XXXX XXXXXXXX XXXX, XXXX, investors, and the federal government. 

All parties involved will be provided formal notice, and immediate equitable and monetary relief will be pursued, including treble damages under XXXX and civil penalties under the False Claims Act.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation