Prommis Holdings LLC Files for Bankruptcy Protection

I have not followed Prommis Holdings closely but I can recall that some people have sent in reports that Prommis was the named creditor in some foreclosure proceedings. The reason I am posting this is because the bankruptcy filings including the statement of affairs will probably give some important clues to the real money story on those mortgages where Prommis was involved. I’m sure you will not find the loan receivables account that are mysteriously absent from virtually all such filings and FDIC resolutions.

And remember that when the petition for bankruptcy is filed it must include a look-back period during which any assignments or transfers must be disclosed. So there is a very narrow window in which the petitioner could even claim ownership of the loan with or without any fabricated evidence.

US Trustees in bankruptcy are making a mistake when they do not pay attention to alleged assignments executed AFTER the petition was filed and sometimes AFTER the plan is confirmed or the company is liquidated. Such an assignment would indicate that either the petitioner lied about its assets or was committing fraud in executing the assignment — particularly without the US Trustee’s consent and joinder.

The Courts are making the same mistake if they accept such an assignment that does not have US Trustees consent and joinder, besides the usual mistake of not recognizing that the petitioner never had a stake in the loan to begin with. The same logic applies to receivership created by court order, the FDIC or any other “estate” created.

That would indicate, as I have been saying all along, that the origination and transfer paperwork is nothing more than paper and tells the story of fictitious transactions, to wit: that someone “bought” the loan. Upon examination of the money trail and demanding wire transfer receipts or canceled checks it is doubtful that you find any consideration paid for any transfer and in most cases you won’t find any consideration for even the origination of the loan.

Think of it this way: if you were the investor who advanced money to the underwriter (investment bank) who then sent the investor’s funds down to a closing agent to pay for the loan, whose name would you want to be on the note and mortgage? Who is the creditor? YOU! But that isn’t what happened and there is nothing the banks can do and no amount of paperwork can cover up the fact that there was consideration transferred exactly once in the origination and transfer of the loans — when the investors put up the money which the investment bank acting as intermediary sent to the closing agent.

The fact that the closing documents and transfer documents do not show the investors as the creditors is incompatible with the realities of the money trail. Thus the documents were fabricated and any signature procured by the parties from the alleged borrower was procured by fraud and deceit — causing an immediate cloud on title.

At the end of the day, the intermediaries must answer one simple question: why didn’t you put the investors’ name or the trust name on the note and mortgage or a “valid” assignment when the loan was made and within the 90 day window prescribed by the REMIC statutes of the Internal Revenue Code and the Pooling and Servicing Agreement? Nobody would want or allow someone else’s name on the note or mortgage that they funded. So why did it happen? The answer must be that the intermediaries were all breaching every conceivable duty to the investors and the borrowers in their quest for higher profits by claiming the loans to be owned by the intermediaries, most of whom were not even handling the money as a conduit.

By creating the illusion of ownership, these intermediaries diverted insurance mitigation payments from investors and diverted credit default swap mitigation payments from the investors. These intermediaries owe the investors AND the borrowers the money they took as undisclosed compensation that was unjustly diverted, with the risk of loss being left solely on the investors and the borrowers.

That is an account payable to the investor which means that the accounts receivables they have are off-set and should be off-set by actual payment of those fees. If they fail to get that money it is not any fault of the borrower. The off-set to the receivables from the borrowers caused by the receivables from the intermediaries for loss mitigation payments reduces the balance due from the borrower by simple arithmetic. No “forgiveness” is necessary. And THAT is why it is so important to focus almost exclusively on the actual trail of money — who paid what to whom and when and how much.

And all of that means that the notice of default, notice of sale, foreclosure lawsuit, and demand for payments are all wrong. This is not just a technical issue — it runs to the heart of the false securitization scheme that covered over the PONZI scheme cooked up on Wall Street. The consensus on this has been skewed by the failure of the Justice department to act; but Holder explained that saying that it was a conscious decision not to prosecute because of the damaging effects on the economy if the country’s main banks were all found guilty of criminal fraud.

You can’t do anything about the Holder’s decision to prosecute but that doesn’t mean that the facts, strategy and logic presented here cannot be used to gain traction. Just keep your eye on the ball and start with the money trail and show what documents SHOULD have been produced and what they SHOULD have said and then compare it with what WAS produced and you’ll have defeated the foreclosure. This is done through discovery and the presumptions that arise when a party refuses to comply. They are not going to admit anytime soon that what I have said in this article is true. But the Judges are not stupid. If you show a clear path to the Judge that supports your discovery demands, coupled with your denial of all essential elements of the foreclosure, and you persist relentlessly, you are going to get traction.

SMOKE AND MIRRORS: HOW TO FOCUS ON MORTGAGE AND FORECLOSURE DEFECTS

It is obvious that I feel it is important to understand securitization and more particularly, how it was faked in the mortgage meltdown and used to cover-up a Ponzi scheme. That is why I publish this blog and that is why I have written books and manuals and of course that is why I issue expert declarations. The issue, in court, is how do you educate the Judge in 5 minutes. The actual answer is that you don’t but your knowledge gained from these pages and other sources should guide you to your goals and guide your voir dire and cross examination of the witnesses for the other side.

Theoretically, most of what I have been suggesting for tactics and strategy ought to be the burden of the party seeking affirmative relief. DENY and DISCOVER arose out of the realization that Judges were placing the burden on the borrower instead and hanging their legal hat on the fact that the borrower was raising affirmative defenses and therefore required to prove them.

Most borrowers, even through counsel, compounded the problem by admitting all required elements of a judicial foreclosure as they emerged from the starting gate making it even easier for the Judge to place the burden of persuasion on the borrower — to prove facts that are exclusively within the possession, care, custody and control of the other side. And that is why discovery is so important.

Even borrowers who commence the litigation in both judicial and non-judicial states commence their complaints with the allegation that they had a financial transaction with the named lender on the note and mortgage — when in fact the borrower has no evidence to support that allegation other than the appearance or illusion of a transaction supported by the fact that the money for the loan showed up at the same time as the “closing.”

In general, a  careful examination of any loan now subject to a claim of securitization will reveal a fun house series of smoke and mirrors. Factually, you need to subpoena the trust officer or manager in charge of REMIC trusts including the subject REMIC for the subject loan. They should bring proof of filing with the IRS and/or any state in which they are doing business as trustee for the REMIC and proof that the money from investors was deposited into an account bearing the name of the alleged Trustee for the benefit of the named trust that is claiming ownership of the loan. Your goal here is to establish that the money was not deposited into any account held or controlled by the trustee and that withdrawals for funding or purchasing loans came from somewhere else. But that only gets you half way home.

The next thing you have to do is subpoena the records of the entity to whom the Trustee will testify was the party to whom the trustee delegated the trustee’s duties. Here again you are looking for an account in the name of the REMIC trust claiming ownership of the loan into which the investor funds were deposited and from which the funding for origination or purchase of the loan took place. You will most likely find again that no such account exists but that there is agreement that the party receiving the investor money was the investment banker and that the account was a commingled account in which the investment bank made decisions as to how much it would take for itself under the  rubric of “proprietary trading.” The balance of the money was used for fees, costs and other expenses and then finally the balance after deductions was used for funding origination or purchase of mortgages.

The trustee should be encouraged to admit that if the loan is not performing or if the loan purchase or assignment, the trustee is prohibited from accepting such loans inasmuch as it would have an immediate negative economic and tax consequence to the investor. The trustee should also be encouraged to admit that the parties to whom duties were delegated were acting within the scope and course of their agency, with the Trustee (or the investors) as the principals and ultimate beneficiaries.

A subpoena to the CDO manager should expose the transactions entered into by the investment bank or an affiliate with respect to the value of the bonds or loans in the alleged investment pool. But under proper questioning, if the money for the loan didn’t come from the investment pool entity, then it came directly from the investors, not the REMIC trust. The point to be made is that the REMIC trust was ignored in all actual financial transactions in which money exchanged hands but principal-agent relationship still existed with the investors as principals and the investment bank et al as agents.

In all cases you wish to establish that no loan receivable account was established on the balance sheet of the REMIC trust claiming ownership of the loan, and probably that no such balance sheet or income statement exists. The investors were not given the note signed by the borrower. They were given a bond issued by the REMIC trust which was worthless because the proceeds of their investment never reached the REMIC trust.

Thus, oversimplifying a bit, you have established that the REMIC trust is not the payee, holder or owner of the debt because (1) it wasn’t the source of funds and (2) the transactions did not comply with the PSA and Prospectus, requiring strict adherence to the REMIC provisions of the Internal Revenue Code.

All of this is done not as an exercise in training the Judge on securitization but under the rubric of tracing the money to the real creditor who had a real loss that would entitle them, if they are secured, to enter a credit bid at the time of auction of a foreclosed property. This would be the same party(ies) that could faithfully execute a satisfaction of mortgage and deliver the note back in its original form with “Paid in Full” Stamped across the front of it. This latter point leads to more complications when you realize that the subject loan was a refinancing of another loan that was also subject to claims of securitization, potentially leaving the homeowner with multiple unsatisfied mortgages, notes or debts.

Your inquiry should focus on the actual receipts and statements showing deposits and withdrawals and transfer of money rather than an assignment which merely tells a story about the transaction. Just as the mortgage is not the note and the note is not the debt, the assignment is no substitute for the actual exchange of money in the sale of the loan. You will find that no such exchange of money took place and then be faced with the question that if the note terms differed from the bond terms, if the payee on the note and mortgage were different than the actual source of funds, and there was no consideration passed (for value received), is there any legally existing transaction? The answer, I think, is NO.

This leaves the situation in murky waters: the transaction about which the origination and transfer documents tell “the story” never took place. So you have documentation without the underlying debt. The actual transaction was with the investors not merely of the REMIC claiming ownership (and by this time has been proven not to own the loan), but all investors whose money was in the source account from which money was taken to fund the origination or purchase of the loan. This commingled account therefore creates under common law a general partnership of the investors that has nothing to do with the REMIC trust which has been ignored by all parties. Thus the partnership consists of all investors who had money in the commingled account. Those investors thought they were advancing money for the purchase of bonds issued by a worthless REMIC trust but found that the Trust had been ignored by their agents. Thus investors from multiple REMIC bond sales find themselves all in the same pot.

This accounts for the allegation from investors in suits against investment bankers that they have been subjected to illegal transactions with borrowers against whom they could enforce neither the note nor the mortgage — because although they did indeed loan money to the borrowers, the documents signed by the borrowers say otherwise. [You should have a couple of those lawsuits under your arm when arguing these points with the Judge]. This leaves the true transaction trail without any documentation other than a wire transfer receipt and perhaps wire transfer instructions. And what was intended to be a secured transaction turns out to be an unsecured transaction even though both sides intended it to be a secured transaction — but subject to different terms (the terms of the repayment on the mortgage bond issued by the empty REMIC trust and the terms of repayment on the promissory note signed by borrower).

The end of this is unclear except to say that settlements will become more frequent. But the negotiations start on a level playing field with the investors rather than the servicers. In most cases it is apparent that borrowers will consent to a new mortgage document directly with the investors thus securing the debt, after reducing it for payments received by the investors or their agents.

 

Banks Restarting Private Label “Securitizations”

CHECK OUT OUR EXTENDED DECEMBER SPECIAL!

What’s the Next Step? Consult with Neil Garfield

For assistance with presenting a case for wrongful foreclosure, please call 520-405-1688, customer service, who will put you in touch with an attorney in the states of Florida, Tennessee, Georgia, California, Ohio, and Nevada. (NOTE: Chapter 11 may be easier than you think).

Editor’s Comment: As we travel down the road of misguided policy and judicial decisions, the banks are starting up a major effort to sell more mortgage securities under private label, which means that (a) they are not required to register them with the SEC and (b) they will continue to veil the secret movement of money making it more difficult for any borrower to know the identity of the lender in a residential loan transaction, contrary to the requirements of Federal and State laws.

The whole purpose of the Truth in Lending Act was to give the consumer an opportunity to choose between one vendor of loans and another. The banks obliterated that choice in the first round of the mortgage meltdown and you can be sure that the only reason they are doing it again is because they intend to make the same gargantuan “profits” in this second round, so far, at $25 Billion.

One of the reasons why they feel emboldened to do this is because the basic laws have not been changed regarding the definition of a security, which excludes mortgage bonds and the hedges like insurance and credit default swaps, courtesy of laws passed in 1998. Another reason is that the Wall Street club still has enough strength to sell the mortgage bonds through intermediaries who trumpet higher returns for stable funds, which we have all seen went from stable in the layman sense to completely unstable and underfunded. The pension funds that got hit the hardest will be the first ones to announce that the pensioners are not going to get the full amount of their payments because of losses in the fund, vested or not.

The “qualified mortgage” regulations passed by the Federal Agency, which might lose its head literally if Cordray’s appointment remains rejected by the Courts, still have plenty of daylight in them to push through false appraisals and false data on the ability of the borrower to pay, and the viability of the loan over its entire term. The easily projected fall in prices to the values charted by Case-Schiller together with reset provisions on adjustable mortgages and “teaser” rates that could be paid only if the majority of the required payment was added on to the principal due on the mortgage, made the crash inevitable and remains unaddressed by law or regulations.

So despite the 0.1% contraction of the economy in the last quarter of 2012, we have the banks again ramping up to make trillions more while the economy stagnates from lack of oxygen — the money diverted from the economy by the banks whose officers have escaped prosecution and whose antics in corrupting the title system of the all the states, have created massive uncertainty over the end result.

Wall Street is allowed to exist as the engine of growth, stability and confidence in our economy. As intermediaries, they are required to meet the needs of the times in terms of providing capital in a capitalist society. Instead, they have become principals without anyone noticing. And their motive is not to intermediate but to make a profit, taking advantage of every loophole in laws, rules or the enforcement thereof. A receding economy won’t stop the banks from making money as long as they are permitted to lie.

If the economy is contracting, Wall Street activity should be expected to drop as the need for capital declines. Instead we see that over the last 4 years and we will see over the coming four years and beyond, an increase in profits for Wall Street firms which are owned by shareholders and directed by officers whose main goal is to create and enlarge their own wealth.

A lot of this has been made possible by the average citizen who can’t be expected to understand the complexities of finance or the law. Of paramount importance in the process is the shame heaped upon borrowers who are all seen as deadbeats despite all evidence to the contrary. And lastly, all this is possible because of the general assumption, often mistakenly used as a conclusive presumption in court, that the borrower received a loan, didn’t pay it back, therefore is in default and based upon the terms of their contract, their homes are sold at auction to satisfy as much of the debt as possible.

The idea that the money demanded as the balance of principal and interest due might be totally misstated, and that the repayment provisions loan is NOT represented by the note and mortgage (or deed of trust), seems impossible to both borrowers and judicial participants alike. The banks laid a trap in setting up bad paperwork because there was no real paperwork that would actually track the movement of money in bona fide transactions with money exchanging hands. Lawyers and pro se litigants cried foul and yet the foreclosures kept proceeding because the judge figured that the bad behavior of the banks was a separate matter from the “obvious” fact that the borrower took a loan and didn’t repay it.

It’s true that the money arrived at the closing table, but beyond that, there is nothing but misdirection, lies and fraud. The money arrived at the closing table from a source that was never disclosed to the borrower, preventing the borrower from any choice in the matter.

The nominee used to play the part of “lender” was not even allowed to touch the money — Wall Street having determined that some “originators” might find it too tempting to let the tens of millions going through their own account go by without skimming some of it or even taking all of it. Wall Street thought this way because it was what they were doing when they sold the original mortgage bonds.

The money was never put in a trust, as specifically provided for  in the enabling documents which might or might not have legally created a common law trust. The bankers took out as much as 1/2 of the investor money as trading profits when they arranged fictitious sales of actual and fictitious loans to the unfunded trust without consideration. The consideration was passed from investors directly to the investment bank that underwrote the sale of the mortgage bonds.

The balance of the investor money was used for fees and costs that were problematic at their best and then finally the balance was used to fund loans (and bets against the loans) that were completely undocumented in terms of the actual financial transactions that took place. None of the paperwork upon which the banks rely in reporting their assets or enforcing invalid notes and mortgages is supported by any transaction in which the named parties exchanged actual money. Thus none of the paperwork could be considered valid or enforceable (lack of consideration). They can sue but they can’t win if the borrower denies the transaction, the note, the debt, the mortgage and lays claim to false disclosures.

The banks understood this fatal error and thus created massive efforts at robo-signing, surrogate signing, fabrication, forgery, and fraud in supporting the alleged transfer of the loan from a nominee who originated the loan but who never funded the loan, up the false securitization chain. In simple words the mountain of paperwork produced by the banks covers a cup that is empty. There was no money involved in ANY of the transactions from origination through assignments that were offered but could not be accepted because they were specifically prohibited by the PSA and Prospectus.

Lawyers and pro se litigants went down the rabbit hole after the false paperwork leaving the judge with the simple proposition that there was a loan, it wasn’t paid back, and therefore the enforcement provisions apply. Nobody asked WHY there was need for false paperwork. What was the false paperwork hiding?

It was hiding an empty cup in which the borrower signed loan documents and never received a loan pursuant to those documents. The borrower received a loan from other parties whose identity was intentionally concealed, and if the various compensation and profit and fees had been disclosed as required by TILA the borrower would have been alerted tot he fact that half or all of his loan was generating fees, profits and costs either equal to or even more than the loan itself. Even an unsophisticated borrower confronted with these facts would get nervous about a transaction where he knew that the real parties were making excessive profits had this been disclosed as required by law.

Hence our strategy of DENY and DISCOVER, which will be the subject of tonight’s discussion on the member teleconference. If you go after the money first, demanding proof of payment and proof of loss you stand a good chance of knocking out both the filing of the foreclosure and the ability of the forecloser to submit a credit bid — simply because they are not the creditor. By going after the money first, the attack on the paperwork becomes both relevant and corroborative of the principal attack over consideration between the borrower and nominee lender who seemed to be the lender at the closing of the loan.

If you assume all of the above is correct, then it is malpractice for any lawyer to admit the debt, the security, the balance due, the note, the mortgage and the enforceability of the note and mortgage. And it is malpractice for a lawyer doing real estate closings to fail to question title and demand a guarantee of title from a qualified source.

As seen in California this will cause even a non-judicial state to  go judicial in practice because the forecloser has a case to prove and in most cases it can’t because it can never show that it ever took the loan in as a loan receivable — which in accounting, is inevitable because there is no place for an entry debiting a cash or other asset account to make the loan.

The entire loan is off balance sheet and solely appears on the income statement as a fee for service transaction in which the apparent lender was really a nominee for undisclosed parties who promised the real lenders one set of terms in the bogus mortgage bonds and an entirely different set of terms in the note signed by the borrower which was unsupported by consideration.

The bottom line is that the discovery should be directed at all parties who have knowledge of the actual transfer of money and documents, including internal documents. The Master servicer, the investment banker, the Trustee of the so-called trust should all be subpoenaed if necessary to determine what records they have and who handled them. And the principal record you want to see is a copy of a canceled check or wire transfer receipt (and wire transfer instructions).

‘Private Label’ Gains Appeal in Mortgage Market
http://blogs.wsj.com/developments/2013/01/29/private-label-gains-appeal-in-mortgage-market/

BANK AMNESTY AGAIN: Leaving Consumers to Fend (Litigate) for Themselves

“To someone who lost his house to mortgage servicer incompetence or malfeasance, that’s not restitution. It’s an insult. “The capped pool of cash payments is wholly inadequate in light of the scale of the harm,” says Alys Cohen, staff attorney for the National Consumer Law Center.”   Adam Levin, abcnews.com

Editor’s Analysis: In case after case across the country it is readily apparent that there complete strangers making claims on mortgages, foreclosing, evicting and even collecting “Trial Payments” while they intend to do nothing other than Foreclose — because that is where the money is and because it is only through a foreclosure that they cap the losses and pass them onto investors despite having received large scale payments of insurance and other hedges.

The Banks have it their way despite the obvious unconscionable, illegal, immoral and unethical breach of trust between consumer and bank and between banks.

Whether it is the Chase WAMU deal, or the BOA countrywide deal, or the Indy-mac One West deal, the facts are in — we don’t need to theorize anymore — the banks are NOT the creditors, they cannot shows proof of loss, proof of payment or any financial transaction that would entitle them to enforce an invalid note or foreclose on an invalid, unperfected mortgage lien.

But the institutionalization of hypocrisy and deviant behavior on the part of the Banks has left us with “settlements” that settle nothing, leaving millions of homeowners who lost their homes to entities that received a windfall from the foreclosure process and the windfall from dual tracking “modification” reviews that were a pure sham designed only to get the homeowner in the deepest hole possible so that foreclosure would become inevitable.

At our members conference this Wednesday, we will talk about what is getting traction in the modification of mortgages and what is getting traction in the litigation of mortgage disputes.

The important thing to remember that is that the MONEY never came from ANY of the parties in the sham securitization chain starting with the originator. While there are exceptions — like World Savings — the truth defeats further claims regarding the Wachovia acquisition and then the Wells Fargo acquisition of Wachovia. Either the assignments were missing or they fabricated and forged.

If you ask yourself why they wouldn’t have had the assignments done all nice and proper which is the way the banking world works when BORROWERS must sign documents, you will feel uncomfortable with Wall Street explanations of volume causing the paperwork confusion. It was the exact same volume that produced millions of “originated” mortgages where the i’s were dotted and T’s were crossed —- that is, where the Borrower had to sign. The banks had no trouble then — it was only when the banks had to sign that there was a problem. Where the securitization participants had to sign was neither disclosed nor drafted nor executed.

The simple reason is that there was nothing to sign. There was no financial transaction where money exchanged hands which is why I am pounding on the point that the lawyers should be aiming at the money rather than the documentation. “For value received” means that value was paid or transferred. When you ask for the wire transfer receipt or cancelled check that shows payment and which would establish proof of loss, you are asking to see the transaction upon which the banks place all their reliance.

Their argument that they don’t need to show the actual transaction is a dodge to protect themselves from showing that the transactions in the bogus securitization scheme were all a sham. Your argument should be simple — they say they lost money and that the homeowners owes it. Let’s see the actual proof that they made the loan, lost the money and have not already been paid. The assignments are not accompanies by actual money exchanging hands which means that the assignment lacked consideration and was therefore an executory contract at best, pending payment.

Then you need to ask yourself why there was no consideration when you know that money was funded from somewhere for a loan to the “benefit” of your client (albeit based upon fraud in the execution and fraud in the inducement including appraisal fraud). YOU must tackle the basic issue in the mind of just about every judge — as long as the money was there at the “closing” of the loan, and the borrower signed the papers, and then defaulted on those promises, what difference does it make whether some OTHER papers were fabricated or even forged.

The fact remains, your client, in the eyes of the Judge, got the loan, agreed to the terms and then defaulted. In our world, when you default on a loan, judgment is entered, foreclosure is completed and eviction, if necessary proceeds. The banks have relied upon this perception for years which considerable success. The reason borrowers often lose in litigation is that they arguing about the wrong thing. As soon as they go after the documentation first they are going down a rabbit hole. It is a tacit admission that the loan was valid, the note is evidence of the loan and the mortgage secures the note. DENY and DISCOVER puts that front and center as an issue of fact in dispute.

By going after the money transactions and requiring proof of payment and proof of loss and asking for the accounting data that shows the loan receivable on the books of an entity, you are striking at the heart of the sham transaction.

If you ask me for a loan for $100 and I say “Sure, just sign this note,” and you go ahead and sign the note, what happens when I don’t give you the $100 loan. The answer, which has caused considerable confusion in the foreclosure defense world is that I can nonetheless sue you (on its face the note LOOKS like a negotiable instrument) , but I can’t win. Because if you deny that I ever completed the loan transaction by funding the loan to you, then I have to prove that I gave you the money. I can’t because I didn’t. My argument that you did receive a loan that day and therefore you owe me the money is a lie. You owe the money to whoever actually gave you the money.

At the closing of these loans originated by nominees with no power to touch the money and whose only source of income was fees, not interest on the loan, the borrower was fooled by the fact that the money showed up for the loan. It never occurred to the borrower to ask any questions since the paperwork, and all the disclosures required by law told him a story about the loan. The borrower could not possibly know that the story told by the documents, the documents he or she signed at closing were all a lie.

The Banks will take the position that everyone was authorized to make representations and act for everyone else — except when it comes to paying down the debts with money received from insurance and the proceeds of credit default swaps, federal bailouts etc. In THAT case the bank says it was not the agent of the investors and had no duty to either the investor or the borrower since the banks were the named insureds — made possible only because they purposefully put the name of a nominee on the note, a nominee on the mortgage (or even two nominees on the mortgage) so that the banks could open up a window of time during which they could claim ownership of the loans despite the fact that they had not funded one dime to originate or purchase any loan.

Thus if go for the money first and THEN show the the fabrication, forgery and perjury in documents, the case makes sense and can be presented to the court without giving one inch of admission that the loan, the note or mortgage were real, valid or enforceable. AND by sending a standard QWR and FDCPA letter, the banks have nowhere to hide. In litigation the motion becomes a petition to enforce the RESPA 6 inquiry and the FDCPA inquiry either through direct order or through discovery.

THEN you force the disclosure of the identity of the creditor who actually has a negative account balance on their books for the loan, directly or indirectly, and seek modification or settlement based upon the facts of the case. HAMP modification is impossible, settlement is impossible without first establishing who could submit a credit bid at auction or who could execute a valid satisfaction and release of the debt.

Latest Bank Amnesty Leaves Consumers Adrift

Fraud Is The Biggest Bubble In History
http://www.ritholtz.com/blog/2013/01/fraud-is-the-biggest-bubble-in-history/

Peeling the Onion: Morgan Stanley Forced to Produce Documents Corroborating Illegal Acts

CHECK OUT OUR EXTENDED DECEMBER SPECIAL!

What’s the Next Step? Consult with Neil Garfield

For assistance with presenting a case for wrongful foreclosure, please call 520-405-1688, customer service, who will put you in touch with an attorney in the states of Florida, Tennessee, Georgia, California, Ohio, and Nevada. (NOTE: Chapter 11 may be easier than you think).

Editor’s Comment and Practice Tips: There are two things you should know going into foreclosure defense. One is that the best decisions on the trial and appellate level came from cases where both sides were institutional in nature. So if the adversaries were both banks, or one was a managed fund, or perhaps a Homeowners or Condominium Association, the Court was a lot more receptive to the same arguments they routinely rejected from Borrowers. That alone suggests some strategies both for investors and homeowners (particularly those hard hit by the mortgage meltdown). The second is that an increasing number of courts are, in the words of one judge who WAS ruling routinely against borrowers, “getting tired of the sloppiness” with which the loan deals were originated, allegedly transferred and claimed as owned by one of a number of parties. They are entering more orders requiring proof of loss, proof of payment and proof that any financial transaction took place in which the forecloser was either the recipient (payee) or the payor of actual money that exchanged hands.

We have seen how the same homeowner with the same property has been assaulted by two completely different “holders”, neither of whom were creditors, each claiming to be producing the original note — and there it was in all its glory, two “original” notes both of which had been printed the previous day on a very good printer. We have seen how the appraisals went further and further off the reservation under pressure from the banks and how the applications were changed under pressure from the banks to close the deal regardless of outcome or viability of the loan.

Strategically I have been encouraging practicing attorneys to pay close attention to the dozens of lawsuits filed against the banks by institutional plaintiffs — pension funds that bought bogus mortgage bonds, government agencies whose findings might be incorporated as fact in your case (especially if the case settled), HOA’s and banks fighting over priority of liens. The facts alleged are fairly uniform — all leading to the conclusion that the loans were neither underwritten in conformity with industry standards (leading to fraud or breach of contract actions) nor supported by documentation that is enforceable (i.e., the mortgage lien was never perfected and the note was incorrectly fabricated and executed without consideration from the named payees or nominees.

The latest rumble over the lack of prosecution on this mortgage mess has produced the resignation of the guy at DOJ who was supposed to be prosecuting these cases. Maybe the change will come. But by this time int he Savings and Loan scandal of the 1980″s there were more than 800 people sitting behind bars with others on probation. The PBS piece “Untouchables” has kicked up a fore storm over the issue of criminal prosecution. Those cases too should be watched carefully and your wording in your pleading ought to be as close to their wording in their lawsuits especially where they have already survived the usual motion to dismiss.

Robert Schiller the economist who created the black letter basis for measuring economic data relating to the housing industry says we are far from done with the damages and debris left by the mortgage meltdown. And out of 105 economists who participated in an independent survey very few had anything good to say about housing or the economy — with the two inextricably entwined. Fixing housing is not merely about stopping foreclosures or increasing modifications. At the heart of the mortgage meltdown was fraud.

And fraud comes in two flavors — civil and criminal. Both require receivers and restitution if prosecuted properly. Investors and homeowners alike are entitled to receive as much restitution as possible that can be clawed back by properly appointed court receivers. Both were decided by appraisal fraud, by deceptive disclosures in which the actual lender was intentionally concealed so that the investment bank could claim ownership and buy insurance payable to the bank instead of the investors, buy credit default swaps with the same result, and apply for Federal bailout with the same result.

Housing won’t be fixed until the corruption of title caused by a nominee on the mortgage and nominee on the note is fixed and settled. The economy won’t be fixed until investors get their share of the insurance and bailouts. The consumer sector won’t be fixed until all that is done, because it is only after the money is allocated to the investors that we can know the actual balance due, if any, on any of the loans.

One thing we know at this point is that most foreclosures (at least 65% according to the San Francisco study) are initiated by “strangers to the transaction” who were not creditors, holders or anything else that would entitle them to enforce the closing documents on a loan that came not from the named payee but from another source entirely. We know that the “credit bid” submitted at auction was pure fiction and fraud and should be corrected in the property records. And we know that the the proceeds of insurance, credit default swaps and federal bailout should be applied to the receivables owed to the investors. Lastly, we know that when those monies are allocated the balance due on those receivables will be far less than what has been or will be demanded from borrowers in past, present and future foreclosures.

 

NY Times: Morgan Stanley Forced to Reveal Truth

Are You Kidding? AIG to Join Suit Against Goverment for Bailout Terms

CHECK OUT OUR DECEMBER SPECIAL!

What’s the Next Step? Consult with Neil Garfield

For assistance with presenting a case for wrongful foreclosure, please call 520-405-1688, customer service, who will put you in touch with an attorney in the states of Florida, California, Ohio, and Nevada. (NOTE: Chapter 11 may be easier than you think).

Editor’s Comment: It is a total farce. Companies that were supposedly saved from the brink of bankruptcy and shame, who played a part in defrauding investors and homeowners across the world are now suing their savior and protector. The people who sit on the Board of Directors of these companies are sitting in a bubble of pure fiction. Yet AIG is now considering the lawsuit as a channel by which they can get even more money from the U.S. Taxpayers and cause even more damage to the U.S. economy.

Greenberg, the head of AIG has had the lawsuit going on for a while now saying, on behalf of himself as a shareholders and on behalf of other shareholders that the onerous terms placed on AIG deprived shareholders of value without due process!

Now AIG itself is thinking of joining the lawsuit because if Greenberg wins then the Board could be liable for failure to act.

“Thank you America” has been advertised by AIG since the bailout. I would now add THANK YOU to Greenberg and AIG for bringing up the one thing that Judges don’t want to hear from investors or shareholders — due process under the 5th and 14th Amendment to the U.S. Constitution.

Besides being spectacularly hypocritical, ungrateful and greedy, Greenberg and AIG have become the new poster boy for Wall Street arrogance. They have also opened the door to consideration of non-judicial foreclosure, as applied, and judicial foreclosure, as applied, in the absence of any proof of payment and standing as a creditor with rights to submit a credit bid at auction.

In the non-judicial states the “private contract” has allowed actions of controlled trustees on deeds of trust appointed by non-creditors in a document common to all loans subject to false claims of securitization (substitution of trustee). The notice of default and notice of sale take the place of a judicial foreclosure — but they are false and we know they are false. The same parties filing a judicial foreclosure would lose.

In both judicial states and all judicial actions the courts have made the assumption that the debt is valid (not true as to the party filing) the default is real (not if the payment isn’t due to the actual creditor who continues receiving payments after notice of default), the note is proper and presumptive evidence of payment or funding of the loan by the payee (almost never true) and that an assignment is presumptive evidence of the sale without proof of payment. The requirement that the party seeking affirmative relief (the forecloser) actually prove a case rather proffer it has been discarded.

There is nothing wrong with the statutes in the judicial states but the non-judicial states have opened a hole of moral hazard the size of the Grand Canyon. And where moral hazard is present, the banks are not far behind. In this case AIG took advantage of the receipt of fees for insurance of bogus mortgage bonds; their failure to perform due diligence and verify the validity of the bonds and the non-existent mortgages that “backed” the bonds was either intentional or negligent. They had insured more than they were worth and that was either intentional or negligent. The government came in, paid off the insurance contracts, and then gave the company back to AIG shareholders when it was “healthy.”

AIG has already sued Goldman on the same facts. The insurance contracts expressly waived any right to go after the borrowers. In most insurance contracts subrogation it is expressly assumed and allowed. The reason for this anomaly was that the banks were able to get 100 cents on the dollar of a loss they never had and they refused to give up a penny of it to the investors they had defrauded or the borrowers whose loan balances would have and should have been correspondingly reduced. What a deal! The investors lose their money, the insurers lose their money, the borrowers don’t get credit for the pay-down of their loans and the bank, claiming the loss to be their own, get the insurance, federal bailout money and the proceeds of credit default swaps.

When I practiced law I learned the hard way that demanding and getting more than your client should get will get you reversed on appeal on the basis that the evidence doesn’t support the verdict or judgment. In lay language, if you are going to be a pig about it, expect to be cooked.

These developments are upside down. AIG should be thanking the American people for the next 100 years and perhaps learning a few things of the due diligence expected of them. Instead, in our litigious society, the lawyers think they have created a long shot of getting billions of dollars more FROM the American taxpayer instead of FOR the American taxpayer.

Many of us were taught as children that there is no free ride. Now we hear there will not be a free house for homeowners whose loan balance has been paid in full. The assumption is that debt is correctly stated and the creditor is correctly identified when neither assumption is true. But the bigger assumption is that all borrowers are either deadbeats or potential deadbeats and that just isn’t true either.

And worst of all, you have AIG et al tying up the government process with a discovery demand of 16 million documents — opening yet another door for those practicing under the rubric of Deny and Discover. Don’t shy away from asking for what you want and nail down the money trail with demands for canceled checks, wire transfer and ACH receipts. And where a judge accepts a proffer instead of proof, call him or her out on it. That’s where due process comes in. Due process doesn’t promise justice but it does promise a hearing in accordance with required notice and an opportunity to be heard. At that hearing the burden is always on the party seeking affirmative relief (foreclosure). Once it comes down to real proof instead of proffers, it is the banks who reveal themselves as pigs to be cooked.

Deny the whole transaction because there was no payment or funding alleged and no payment or funding proven. That is because investors supplied the money thinking that they were buying into REMICs. They didn’t. Investor money was commingled from all investors in accounts that were layered over with false documentation to give the investor the impression he was the owner of a bona fide mortgage backed bond issued by a REMIC trust. In fact the pension fund investor owned nothing and had merely loaned the money to the investment banker who played with it and created the appearance of trading profits and fees and expenses and then funding bad mortgages in REMIC tranches where the investment banker could torpedo the whole thing, collect insurance, CDS proceeds and federal bailouts.

The government has been reluctant to get into the complexity of these fictitious transactions. Now that they are being sued, they might well be forced to do the digging they should have done in the first place. So Thank You again Mr. Greenberg!

Rescued by a Bailout, A.I.G. May Sue Its Savior

By BEN PROTESS and MICHAEL J. DE LA MERCED
NY Times

Fresh from paying back a $182 billion bailout, the American International Group Inc. has been running a nationwide advertising campaign with the tagline “Thank you America.”

Behind the scenes, the restored insurance company is weighing whether to tell the government agencies that rescued it during the financial crisis: thanks, but you cheated our shareholders.

The board of A.I.G. will meet on Wednesday to consider joining a $25 billion shareholder lawsuit against the government, court records show. The lawsuit does not argue that government help was not needed. It contends that the onerous nature of the rescue — the taking of what became a 92 percent stake in the company, the deal’s high interest rates and the funneling of billions to the insurer’s Wall Street clients — deprived shareholders of tens of billions of dollars and violated the Fifth Amendment, which prohibits the taking of private property for “public use, without just compensation.”

Maurice R. Greenberg, A.I.G.’s former chief executive, who remains a major investor in the company, filed the lawsuit in 2011 on behalf of fellow shareholders. He has since urged A.I.G. to join the case, a move that could nudge the government into settlement talks.

The choice is not a simple one for the insurer. Its board members, most of whom joined after the bailout, owe a duty to shareholders to consider the lawsuit. If the board does not give careful consideration to the case, Mr. Greenberg could challenge its decision to abstain.

Should Mr. Greenberg snare a major settlement without A.I.G., the company could face additional lawsuits from other shareholders. Suing the government would not only placate the 87-year-old former chief, but would put A.I.G. in line for a potential payout.

Yet such a move would almost certainly be widely seen as an audacious display of ingratitude. The action would also threaten to inflame tensions in Washington, where the company has become a byword for excessive risk-taking on Wall Street.

Some government officials are already upset with the company for even seriously entertaining the lawsuit, people briefed on the matter said. The people, who spoke on the condition of anonymity, noted that without the bailout, A.I.G. shareholders would have fared far worse in bankruptcy.

“On the one hand, from a corporate governance perspective, it appears they’re being extra cautious and careful,” said Frank Partnoy, a former banker who is now a professor of law and finance at the University of San Diego School of Law. “On the other hand, it’s a slap in the face to the taxpayer and the government.”

For its part, A.I.G. has seized on the significance and complexity of the case, which is filed in both New York and Washington. A federal judge in New York dismissed the case, while the Washington court allowed it to proceed.

“The A.I.G. board of directors takes its fiduciary duties and business judgment responsibilities seriously,” said a spokesman, Jon Diat.

On Wednesday, the case will command the spotlight for several hours at A.I.G.’s Lower Manhattan headquarters.

Mr. Greenberg’s company, Starr International, will begin with a 45-minute presentation to the board, according to people briefed on the matter. Mr. Greenberg is expected to attend, they added.

It will be an unusual homecoming of sorts for Mr. Greenberg, who ran A.I.G. for nearly four decades until resigning amid investigations into an accounting scandal in 2005. For some years after his abrupt departure, there was bitterness and litigation between the company and its former chief.

After the Starr briefing on Wednesday, lawyers for the http://topics.nytimes.com/top/reference/timestopics/organizations/t/treasury_department/index.html?inline=nyt-org”>Treasury Department and the http://topics.nytimes.com/top/reference/timestopics/organizations/f/federal_reserve_bank_of_new_york/index.html?inline=nyt-org”>Federal Reserve Bank of New York — the architects of the bailout and defendants in the cases — will make their presentations. Each side will have a few minutes to rebut.

While the discussions are part of an already scheduled board meeting, securities lawyers say it is rare for an entire board to meet on a single piece of litigation.

“It makes eminent good sense in this case, but I’ve never heard of this kind of situation,” said Henry Hu, a former regulator who is now a professor at the University of Texas School of Law in Austin.

It is unclear whether the directors are leaning toward joining the case. The board said in a court filing that it would probably decide by the end of January.

Until now, the insurance giant has sat on the sidelines. But its delay in making a decision, some officials say, has drawn out the case, forcing the government to pay significant legal costs.

The presentations on Wednesday come on top of hundreds of pages of submissions that the government prepared last year, a time-consuming and costly process. The Justice Department, which assigned about a dozen lawyers to the case and hired outside experts, told a judge handling the matter that Starr was seeking 16 million pages in documents from the government.

“How many?” the startled judge, Thomas C. Wheeler, asked, according to a transcript.

Struck just days after the collapse of Lehman Brothers in September 2008, the bailout of A.I.G. proved to be among the biggest and thorniest of the financial crisis rescues. The company was on the brink of collapse because of deteriorating mortgage securities that it had insured through credit-default swaps.

Starting in 2010, the insurer embarked on a series of moves aimed at repaying its taxpayer-financed bailout, including selling major divisions. It also held a number of stock offerings for the government to reduce its stake, which eventually generated a roughly $22 billion profit.

Overseeing that comeback was a new chief executive, Robert H. Benmosche, a tough-talking longtime insurance executive. Mr. Benmosche has won plaudits, including from government officials, for his managing of A.I.G.’s public relations even as he helped nurse the company back to financial health.

But he and the rest of A.I.G.’s board must now confront an equally pugnacious predecessor in Mr. Greenberg.

In the case against the government, Mr. Greenberg, through his lead lawyer, David Boies, contends that the bailout plan extracted a “punitive” interest rate of more than 14 percent. The government’s huge stake in the company also diluted the holdings of existing shareholders like Starr, which at the time was A.I.G.’s largest investor.

“The government has been saying, ‘We’re your friend, we owned and controlled you and we let you go.’ But A.I.G. doesn’t owe loyalty to the government,” a person close to Mr. Greenberg said. “It owes loyalty to its shareholders.”

The government, Starr argues, used billions of dollars from A.I.G. to settle credit-default swaps the insurer had with banks like http://dealbook.on.nytimes.com/public/overview?symbol=GS&inline=nyt-org”>Goldman Sachs. The deal, according to the lawsuit, empowered the government to carry out a “backdoor bailout” of Wall Street.

Starr argued that the actions violated the Fifth Amendment. “The government is not empowered to trample shareholder and property rights even in the midst of a financial emergency,” the Starr complaint says.

The Treasury Department declined to comment. A spokesman for the Federal Reserve Bank of New York, Jack Gutt, said, “There is no merit to these allegations.” He noted that “A.I.G.’s board of directors had an alternative choice to borrowing from the Federal Reserve, and that choice was bankruptcy.”

A federal judge in Manhattan agreed, dismissing the case in November. In an 89-page opinion, Judge Paul A. Engelmayer wrote that while Starr’s complaint “paints a portrait of government treachery worthy of an Oliver Stone movie,” the company “voluntarily accepted the hard terms offered by the one and only rescuer that stood between it and imminent bankruptcy.”

The United States Court of Appeals for the Second Circuit recently agreed to review the case on an expedited timeline. The judge in the United States Court of Federal Claims in Washington, meanwhile, has declined to dismiss the case and continues to await A.I.G.’s decision.

Banking Shaping American Minds

“I wish someone would give me one shred of neutral evidence that financial innovation has led to economic growth — one shred of evidence.” — Paul Volcker, former Fed Chairman, 2009

“We have allowed the borrower to get raped and then we have gone to the rapist for a course on sex education. Thus the investors (pension funds who will announce reductions in vested pensions) and the homeowners have been screwed on such a grand scale that the entire economy of our country and indeed the world have been turned upside down.” — Neil F Garfield, livinglies.me 2012

CHECK OUT OUR DECEMBER SPECIAL!

What’s the Next Step? Consult with Neil Garfield

For assistance with presenting a case for wrongful foreclosure, please call 520-405-1688, customer service, who will put you in touch with an attorney in the states of Florida, California, Ohio, and Nevada. (NOTE: Chapter 11 may be easier than you think).

Editor’s Comment: The article below is very much like my own recent article on privatized prisons and the inversion of critical thinking in favor of allowing economic crimes to have a special revered status in our society. Kim highlights the rampage allowed to continue to this day in which Banks are ravaging our society and supporting anything that will confuse us or indoctrinate us to accept outright theft from our society, our purses, and our lives.

It is this lack of critical thinking that has made it so difficult for homeowners to get credit on loan balances that are already paid down by parties who expressly waived any right to collect from the borrower. It is the reason Judges are so reluctant to allow homeowner relief because they perceive the fight as one in which the homeowners are only expressing buyer’s remorse on an otherwise valid transaction.

It is the reason why lawyers are reluctant to deny the debt, deny the balance, deny that a payment was due, deny the default, deny the note as evidence of any debt, deny the validity of the mortgage and counter with actions to nullify the instruments signed by confused and befuddled borrowers assured by the banks that they were making a safe and viable investment.

In most civil cases Plaintiff sues Defendant and Defendant denies most of the allegations — forcing the Plaintiff to prove its case. Not so in foreclosure defense. Lawyers, afraid of looking foolish because they have not researched the matter, refuse to deny the falsity of the allegations in mortgage foreclosure complaint, notice of default and notice of sale. Lawyers are afraid to attack sales despite decisions by Supreme Courts of many states, on the grounds that the sale was rigged, the bidder was a non-creditor submitting a credit bid, and the fact that the forecloser never had any privity with the homeowner, never spent a dime funding any mortgage and never spent a dime funding the purchase of a mortgage.

The quote from the independent analysis of the records in San Francisco County concluded that a high percentage of foreclosures were initiated and completed by entities that were complete “strangers to the transaction.” Why this is ignored by members of the judiciary, the media and government agencies is a question of power and politics. Why it MUST be utilized to save millions more from the sting of foreclosure is the reason I keep writing, the reason I consult with dozens of lawyers across the country and why I have moved back to Florida where I am taking on cases.

As a result of the perception of the inevitability of the foreclosure most court actions are decided in favor of the forecloser because of the presumption that the transaction was valid, the default is real, and that no forgery or fabrication of documents changes those facts. The forgeries and fabrications and robo-signed documents are bad things but the “fact” remains in everyone’s mind that the ultimate foreclosure will proceed. That “fact” has been reinforced by inappropriate admissions from the alleged borrower, who never received a nickle from the loan originator or any assignee.

The lawyers are admitting all the elements necessary for a foreclosure and then moving on to attack the paperwork. Theoretically they are right in attacking assignments and endorsements that are falsified, but if they have already admitted all the basic elements for a foreclosure to proceed, then the foreclosure WILL proceed and if they have any real damages they can sue for monetary relief.

But under the current perception carefully orchestrated by the banks, there are no damages because the debt was real, the borrower admitted it, the payments were due, the borrower failed to make the payments, and the mortgage is a valid lien on the property securing a note which is false on its face but which is accepted as true.

Even the borrowers are not seeing the truth because the people with the real information on the ones that are foreclosing on them. So borrowers, knowing they received a loan, do not question where the loan came from and whether the protections required by the truth in lending statute, RESPA and other federal and state lending laws were violated. We have allowed the borrower to get raped and then we have gone to the rapist for a course on sex education. Thus the investors (pension funds who will announce reductions in vested pensions) and the homeowners have been screwed on such a grand scale that the entire economy of our country and indeed the world have been turned upside down.

Deny and Discover is getting traction across the country, with a focus on the actual money trail — which is the trail of real transactions in which there was an offer, acceptance and consideration between the relevant parties. More and more lawyers are trying it out and surprising themselves with the results. Slowly they are starting to realize that neither the origination of the, loan as set forth in the settlement documents at closing nor the assignments and endorsements were real.

The debt described in the note does not exist and never did. Neither was it the same deal that the lender/investors meant to offer through their investment bankers.

The note and the bond have decidedly different terms of repayment. The payment of insurance and credit de fault swaps to the banks was a crime unto itself — a diversion of money that was intended to protect the investors. The balances owed to those investors would have been correspondingly reduced. The balances owed from the borrowers should be correspondingly reduced by payment received by the only real creditor.

Thus millions of homeowners have walked away from homes they owned on the false representation that the balance owed on their homes was more than they could pay. And the messengers of doom were the banks, depriving investors of money due to them and depriving the borrower of the real facts about their loan balances. Lawyers with only a passing familiarity have either told borrowers that they have no real case against the banks or they take a retainer on a case they know they are going to lose because they will admit things that they don’t realize are false. And Judges hearing the admissions, have no choice but to let the foreclosure proceed.

But that doesn’t mean you can’t come back and overturn it, get damages for wrongful foreclosure, and this is where lawyers have turned bad lawyering into bad business. There is a fortune to be made out there pursuing justice for homeowners. And the case far from the complexity brought to the table by the banks is actually quite simple. Like any other civil case or even criminal case, stop admitting facts that you don’t know are are true and which are in actuality false.

In every case I know of, where the lawyer has followed Deny and Discover and presented it in a reasonable way to the Judge, the orders requiring discovery and proof have resulted in nearly instant “confidential” settlements. Some lawyers and waking up and making millions of dollars helping thousands of homeowners —- why not join the crowd?

Banks Stealing Wealth and the Minds of Our Children

by JS Kim

In the past several years, people worldwide are slowly beginning to shed the web of deceit woven by the banking elite and learning that many topics that were mocked by the mainstream media as conspiracy theories of the tin-foil hat community have now been proven to be true beyond a shadow of a doubt. First there was the myth that bankers were upstanding members of the community that contributed positively to society. Then in 2009, one of their own, Paul Volcker, in a rare momentary lapse of sanity, stated “I wish someone would give me one shred of neutral evidence that financial innovation has led to economic growth — one shred of evidence.” He then followed up this declaration by stating that the most positive contribution bankers had produced for society in the past 20 years was the ATM machine. Of course since that time, we have learned that Wachovia Bank laundered $378,400,000,000 of drug cartel money, HSBC Bank failed to monitor £38,000,000,000,000 of money with potentially dirty criminal ties, United Bank of Switzerland illegally manipulated LIBOR interest rates on a regular basis for purposes of profiteering, and though they have yet to be prosecuted, JP Morgan bank, Goldman Sachs bank, & ScotiaMocatta bank are all regularly accused of manipulating gold and silver prices on nearly a daily basis by many veteran gold and silver traders.

http://www.zerohedge.com/contributed/2013-01-03/banking-elite-are-not-only-stealing-our-wealth-they-are-also-stealing-our-min

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