The mortgage securitization industry has just had a new major front open on its battle with those who are less than happy with the way it has run roughshod over the law. While there are a significant number of court rulings questioning foreclosures in the name of MERS or other practices commonly associated with the use of MERS (for instance, in Oregon, its violation of recording requirements mandated at the state level), no major regulator or public official (beyond county registers of deeds) has gone after MERS in a serious way (New York’s AG has opened an investigation, but it has not led to any litigation).
This has changed with the Delaware attorney general Beau Biden’s filing. The suit takes the interesting angle of pursuing MERS for engaging in deceptive consumer practices. Nevada’s attorney general has also used the deceptive practices argument in suing Countrywide for violation of HAMP procedures.
The damages sought are substantial, $10,000 per violation. Since MERS is a tiny company, with under 50 employees and many of its operations outsourced (and no reason for it to maintain a substantial balance sheet), success in court would almost certainly mean bankruptcy for MERS. In theory, a new consortium or private investors could buy the database out of bankruptcy, but how would one structure its operations so as to not run afoul of the law? Yet with so many mortgages recorded in the MERS database (the registry has claimed over 60 million) the banks will need to find a way to keep it going and operate it in an above-board manner.
I’ve not yet seen the claim, but DelawareOnline gives an overview of the case:
Delaware joined what is becoming a growing legal battle against the mortgage industry today, charging in a Chancery Court suit that consumers facing foreclosure were purposely misled and deceived by the company that supposedly kept track of their loans’ ownership.
By operating a shadowy and frequently inaccurate private database that obscured the mortgages’ true owners, Merscorp made it difficult for hundreds of Delaware homeowners to fight foreclosure actions in court or negotiate new terms on their loans, the suit filed by the Attorney General’s Office said.
Yves here. Notice the emphasis on the opacity and inaccuracy of the system. Back to the overview:
Because it purported to act as a “common agent” for whichever MERS member owns the mortgage loan at a given point, the company was frequently listed as the owner of record in foreclosure cases. And because it tracks ownership among members electronically, it is able to avoid the transfer fees that traditionally were paid to county Recorder of Deeds offices in such transfers.
Several governments have filed suit against MERS over that fee issue, but Delaware chose to challenge the firm through the state’s Uniform Deceptive Trade Practices Act, alleging that consumers were the ones shortchanged by its system.
Because changes in ownership are recorded only in MERS’ private database, there is “no public trail by which anyone can identify the principals or verify the propriety of the transfer,” the suit charges. The opaque nature of the database also makes it difficult for consumers “to know of or challenge inaccuracies in the MERS System.”
And when MERS foreclosed in its own name, the borrower’s ability to raise defenses was impaired, the suit charges.
So interestingly, Biden considered the filing fee issue but decided the deceptive practices angle was more germane. The dollar amounts that could be obtained under a recording-fee action are a fraction of the ones at issue here. Recording fees saved were typically in the range of $35, and the use of MERS would have saved typically 2 or 3 recording fees, or $70 to $105 per mortgage, versus the $10,000 civil penalty for each consumer violation here. It is still mind-boggling that the securitization industry saw it fit to run roughshod over the property records of this country to save such small amounts over money (over an entire 5000 mortgage securitization, the savings would be $350,000 which in all likelihood was ripped out in more fees rather than passed on to consumers).
Bloomberg adds some details:
Biden asked the court to bar MERS from initiating any foreclosure actions in the company’s name, from acting as a nominal mortgage lender when it didn’t have a “beneficial interest” in the property and from recording such mortgages in the company’s name.
Biden also asked the court to stop MERS from assigning or taking any other actions on Delaware mortgages until the company’s system has been “audited and corrected,” according to the complaint. The court should order MERS to correct the chain of title on Delaware mortgages that were recorded in county offices, Biden said.
Unless MERS gets injunctive relief, these two provisions effectively stop foreclosures in MERS’s name in Delware. MERS has repeatedly said it does not hold any interest in the property or note in depositions. And the mortgage registry system had also quietly put out a notice to members months ago telling members to stop foreclosing in the name of MERS. Not allowing MERS members (servicers, banks, and their foreclosure attorneys) to assign mortgages out of MERS will stop the foreclosure apparatus cold. This is a legitimate legal strategy to get a foreclosure freeze and force the servicing industry to the table to negotiate a much bigger fix.
Consumers are very upset about MERS (I find it resonates with readers more than many of the other securitization abuses). The sketchy details of the 50 state attorney general draft settlement release leaked thus far suggest that it would include actions related to the creation of mortgage securities, which may well be construed to include the use of and reliance on MERS.
This is going to get interesting. This action raises the embarrassment level and political risk of any state signing on to the so-called 50 state attorney general mortgage settlement. It also points out the degree to which the Federal bank regulator eight week investigation into mortgage securitizations and subsequent actions have been a cover-up. There were plenty of legal theories the Feds, HUD, and the DoJ could have used to apply pressure to get real reform and fix a broken securitization model. But that was never the intent of this exercise. I hope readers will write Biden’s office and thank him for his action at Attorney.General@State.DE.US
Update 11:20 PM: Reader Barbara W pointed us to the claim on the Delaware website, which we somehow missed when we wrote the post this afternoon. There are two items in the pleading that stood out. One was that the AG did a small scale study of 100 foreclosures in a single county and found that 21 the party listed in the filing did not match the information on MERS’s website. Second, the case makes an interesting use of the chain of title argument. It points out that the mortgages may not have made their way to the securitization trust, and so any filing or action done in via MERS in the name of a trust may be invalid.
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Go Beau!!
Ha Ha, Joe’s son delivers another blow to the crumbling dike of FIRE industry criminality and corruption. I’m not sure this alone will break the camel’s back, but man, it sure is piling up.
And the Occupiers have changed the national attention from (F)Austerity to corporate pillaging. Even O’bumma feels compelled to make more noises about reining in those savvy biznezmen, liar that he is. But hey, if anyone knows which way the wind is blowing, it the blow-jobber-in-chief!
More likely handjobs. Easily taken care of under the table while all the while both parties smile at us.
the Bible tells us not to steal
it’s there in black and white
our laws are based upon it too
do not do wrong – do right
but somehow since these laws were writ
we’ve seen the system fail
but things will change for all the best
when the bankers go to jail
http://thepeakoilpoet.blogspot.com/2011/07/when-bankers-go-to-jail.html
Relevant news re: “peak oil”:
http://esciencenews.com/articles/2011/10/26/astronomers.discover.complex.organic.matter.universe
…but otherwise, that’s OT.
Unobtainium! Must – have – unobtainium!
Wouldn’t MERS enable the manipulation of mortgages for purposes of securitization? (A la: to get my CDO to lose enough value that I can collect on the opaque CDS ‘bet’ that I’d placed against it, I needed to identify 40 more mortgages that are overdue by two months or more and move their ownership records. I could do that via a database search, then shift the ‘ownership’ records into that CDO, could I not?)
Was this feasible?
The whole notion of ‘property ownership’ appears to have been subverted by MERS. I hope Biden is going for the jugular.
“Oh what a tangled web we weave
When first we practice to deceive”
Methinks I see the first threads in unweaving this massive fraud-a-palooza that Wall Street has unleashed upon us.
Dollars to donuts that Beau is just rounding 1st base with this move. Can’t wait to see what he comes up with next.
Talk big, co-opt the issue, cave, take donations. Repeat.
Blow me, Beau.
sheesh, I hope not…
Newby student of the financial decline of America here.
Is it true that MERS was formed so as to save the
step of going to individual county courthouses
and filing the necessary paperwork for each action
relative to a property?
that is the pablum you will get from FIRE droids.
what they fail to leave out is they also skirted the laws of each and every state, avoided the filing fees, and violated UCC for perfecting original mortgage and transfers/assignments.
the system that they subverted has worked flawlessly for over 200 years. the property records of the US were meticulous, and clear until the banksters unilaterally decided to do their own thing.
Reading between the lines of the snippets of the complaint I have read in the press release it would appear that Biden’s ire is up. He basically asserts that MERS has damaged a property ownership recordation system that traces back to the 1600s. This is true – a good friend of mine has been in the title business for 20 years and they frequently trace title back to king’s grants and the like. Land titles are foundational to our republic. Further, Biden is going for the jugular as it would not take too many counts of deceptive practices for MERS to get wiped out. As regards MERS title data-base, my pal in titles was getting title information from private data-bases in the mid-90s for pretty high access fees (TRW I believe) so I believe there would be a market for the data. However, the real problem is in the counties where legitimate ownership is clouded by MERS’ failure to properly record transfers. Thus, the judgement for MERS should include an obligation to complete those transfers, properly – and that duty should stay with the company through any sale or bankruptcy – which would effectively render the company a liability. Gee, maybe BAC would buy it.
“Land titles are foundational to our republic”-in theory-land ownership has always been a contentious issue
Early entitlements were huge blocks(the whole states of NJ, PA, VA, 8-12 counties along the Hudson and so on) that got divided several times -large estates were built up -later sold off in a confused mess.
-Early speculators bought land en mass-half a county, defaulted on payments and left deeds in courthouses with their names -name only-no real owner after the landholding-speculator -disappeared into oblivion, -meanwhile squatters moved in -I mean homesteaders-and would be thrown off the land-or attempts would be made-by the new corporate owners who picked up the bankrupt speculator-new company now shows up as the owner on paper-homesteader -or squatter goes to the likes of Abe Lincoln-(I know, another Abe Legend but its real) shows up and defends the small guy and wins.
The fact that even that even before there was a United States, there were established court actions to quiet title, and that those actions worked – the courts had clear rules for determining who had what rights to which piece of land, and there were clear rules to follow in order to assert those rights, and that after applying those rules land titles by and large were quieted and then stayed quiet for over 200 years – suggests that the old system worked just dandy.
For over 200 years, anyone could go to the courthouse and find out with certainty who had which rights to which land, whom they got those rights from, etc.. It was a beautiful thing.
MERS wrecked all that.
Massachusetts courts basically seem to have ruled that all MERS transactions were a sham and that the last locally recorded document is the only thing the law will pay attention to.
So in some sense MERS hasn’t wrecked the system. It has simply defrauded hundreds of millions of people by selling them phony land titles!
The MERS data base can be destroyed, put beyond operational use. It does not have to be considered anything other than a criminal device, like an arms cache or other contra band, like knock off designer goods, it does not have to be sold as an asset for creditors out of bankruptcy, because it is the data base itself that breaks the law, by digitizing what should be a corporeal paper trail. By representing and warranting a service as a mortgage servicing software, implies legal compliance with state and federal banking laws.
Since it is the digital or virtual record keeping, which allows for the criminal activity, it is the digital service, along with the content, that should be destroyed.
Slow down Paul.
We don’t want to destroy that data base until we understand how “they” used it in the securitization and derivative slice and dice escapade. The meta data structure and such could be quite telling as to usage.
I sure as hell hope someone has seized enough MERS records, software and such to help provide some opacity as to its use in the Great Mortgage Robbery.
Is anyone in jail yet? Why not?
Another thing. Yves said, “Consumers are very upset about MERS (I find it resonates with readers more than many of the other securitization abuses).” Why? The amount of money denied counties by MERS is likely only a few billion dollars while in totality, the frauds in securitization likely exceed $1 trillion. Why does the general public care more about this minor sideshow of the scheme than the big show itself? Simple really. I don’t know a single person who owns a CDO or a CDS. Yet, I know quite a few homeowners. And let us not forget, even though I strongly disagree with this perception, home ownership is the cornerstone of the American Dream. Hence, MERS messed with us, John Paulson did not. And it is one thing to be swindled by sharpies on Wall Street, it is quite another to have high school dropouts taint a centuries-old property recordation system. Like I said, its foundational.
It resonates with me. A home is usually the single biggest purchase somebody makes. Anything that can potentially damage the clarity of title or liens would be a major threat to the current homeowner and future buyers.
I have absolutely no concern about foreclosing on people who truly bought too much house and simply can’t afford it. But illegal and incomplete recording of titles and liens as well as illegal application of payments and fees are simply unconscionable and are a separate issue from defaulting on payments.
While visiting with a neighbor recently, we were discussing the whole real estate/financial crash. He expressed dismay that courts were giving away houses for free to people behind in their payments. I explained how that wasn’t happening then told him that the people I really worry about are the millions of poor schlubs out there who are faithfully making their payments every month and will find, when they go to pay off the mortgage or sell, that they don’t have clear title to their homes.
He blanched.
If more people knew about the epidemic of servicer fee fraud (basically, charging homeowners illegal fees so as to steal money from them and hopefully force them into default), I suspect that that would be just as unpopular as MERS.
Those are the two big ones, because theose are the two which are hitting middle-class people who “did everything right”.
Servicer fee fraud is huge. Several lawyers with mortgages have posted talking about their multi-year-long cases filed on their own behalf trying to force the banks to abide by the mortgage contract which they signed. The banks simply feel that they can arbitrarily demand money from the homeowner any time, rather than actually following the terms of the mortgage.
Biden said some good things. It is important to stop the abuses , end MERS (bringing back transferring of mortgage rights and questions of title back to the States), but the skeptic in me acknowledges that being A.G. is a great spring board to being governor. I hope this isn’t a dog and pony show.
I think the time has finally arrived when the smug, let those deadbeat losers lose their home crowd, wakes up and realizes they are at even more at risk than their unfortunate neighbors.
If I’m reading this bit right:
“Biden also asked the court to stop MERS from assigning or taking any other actions on Delaware mortgages…”
ANd ‘any other action’ includes title transfers on payoffs, then we’re officially into the next phase.
This won’t just stop foreclosures.
It sounds like it halts ALL transfers of property with a mortgage that was included in a securitization registered with MERS.
Am I reading this wrong?
awaiting moderation? WTF?
I sent the following laudatory email. If it
agrees with your sentiments, feel free to cut and paste.
Dear Mr. Biden,
As a US citizen who is very concerned with the direction our country is taking in many spheres, with particular concern for the outrageous disregard of lawful procedures in the mortgage and banking industries, I thank you for your thoughtful and courageous actions in initiating this suit.
Although I am a mortgage owner, I am fortunate enough not to be in trouble, but am still very concerned about how the big banks and mortgage companies have taken advantage of many of my less fortunate fellow citizens.
My very best wishes in your pursuit of justice. Delaware is fortunate to have you fighting justice for its citizens.
Best regards,
Bill Carroll, Ph.D.
Clinical Psychologist, retired
Williamsburg, VA
MERS… undoing 500 years of property law in 5 years.
I’ve lost the fox here.
There is nothing illegal or improper about selling a mortgage.
MERS worked with Fannie Mae and Freddie Mac to set up a system to keep track of who the mortgage was sold to. That is, who had current ownership of the note.
Each state may have it’s own rules about how those transfers should have been recorded. So, if those steps were skipped then there is a legitimate complaint to set those records straight.
I can see that if the database is full of errors then it is going to be more difficult to get the recordings straightened out.
I don’t see how any of these facts lead to a claim of purposefully misleading homeowners. The claim is that it was a “shadowy opaque inacurate” database that hindered homeowners from discovering the owner of the mortgage. Also, since mortgage transfers weren’t recorded then the ownership could not be determined from County records.
Isn’t this last part discoverable in court? The database is private property, so it is not available to the public for viewing. But, if during a foreclosure proceeding the homeowner requested to see the chain of transfers, and the judge agreed, then wouldn’t MERS be compelled to produce it.
If, before the foreclosure proceeding, the homeowner wanted to negotiate wouldn’t they do that with the mortgage servicer (the one they sent their monthly check to when they were making their payments)? I don’t see MERS being involved in that part of the situation at all. They get involved when the foreclosure process begins.
So, does it boil down to a private data base with potential errors being unavailable for people to find out who owns their mortgage? I’m back to wondering why the servicer wouldn’t have that information. They might not share it, but they would have it. And since they are the agent for the owner then the owner can decide if they want the agent to disclose their ownership or not. After all, that’s what agents are for – to represent to owner.
When my refi mortgage was sold I got a letter from the servicer telling me that my mortgage was now owned by someone else. I thought that was standard operating procedure. I’m still wondering if MERS has any obligation to the homeowners in this situation.
Sounds to me like it is the servicer that has the primary obligation to the homeowner.
Many judges have been rubber-stamping foreclosures. Also, many states are “non-judicial” foreclosure states.
An important consideration is states that are “recourse” states where they can go after personal assets instead of the house. If the “official” mortgage note holder in the county records went after your assets even if you had paid off the mortgage to the MERS note holder, you would not enjoy the court battle.
Mers is a tool used by folks in power to take vital public records, and convolute and change them at will. The records are unavailable now to the public. This is important because as we now know, the notes never made it to the trusts. We will discover, that the same note was sold into more than one mbs. This has defrauded the investor in mbs, but it has also defrauded the tax payer.
I for one have absolutely zero trust in my servicer (wells fargo) to ensure my payment is applied correctly, or even applied to the party who has ownership interest in my debt. My first mortgage was serviced by taylor bean whittaker. we all know how well they did maintaining their data and acting honestly. So, who owns my note? I would request verification from my bank (wells fargo), but my understanding is that making such a request is seen by them as contesting the debt.If you make the request, they report to the credit agency that you are contesting the debt and your credit score drops about 100 points. Nice eh? They pretty well have it all sewed up.
If you want to understand Mers and the damage it has done, read Chris Petersens paper out of the university of Utah.
To add another layer of filling to the shi* burger we are choking on, read and understand what happens when a property line dispute occurs and one of the propertys has the mers disease. Now, all four adjacent propertys titles are fubard even if only one has the mers taint.
Wether or not Mers fails now is largely irrelevant in my opinion. The question I am asking is are we going to let our administration/ag/doj/irs/sec continue the charade of “settlement negotiations.” Is there one honest politician left who will adress this head on or are they all as evil as they appear?
level,
It did not merely “keep track of who owned the mortgage.” That is a REAL misconstruction on your part. MERS became the mortgagee of record, even though it did not own the note. In a lot of states, that isn’t even viable, only someone with a real interest in the property can be the mortgagee.
I can go on, but MERS was set up in a legally reckless manner (no review was done as to whether it was permissible or workable under the laws of the 50 states; Oregon courts have basically said it isn’t) and the database protocols and controls are stunningly lax.
The response to the Delaware suit by Janis Smith of MERSCORP is available at:
http://4closurefraud.org/2011/10/27/nye-lavalle-responds-to-statement-by-janis-smith-merscorps-vice-president-for-corporate-communications-on-the-complaint-filed-by-the-state-of-delaware/
In which she states:
“Homeowners have free access to their loan servicer information on the MERS® System at all times, and MERS’ website also provides them with access to mortgage counseling and foreclosure prevention organizations. The borrower’s customer relationship is with the servicer, and not with MERS, and federal laws require the servicer to disclose all changes in ownership to borrowers.”
Interestingly, she never addresses Delaware’s contention that borrowers can’t determine who owns their loan from MERS and never addresses the problem that MERS was so often listed as the owner. She bypasses that problem by saying that borrowers can find out who the servicer is from MERS and that the servicer should have communicated loan ownership to the borrower.
That seems both flimsy and untrue. And a very new, narrow explanation of MERS’ role.
“Each state may have it’s own rules about how those transfers should have been recorded. So, if those steps were skipped then there is a legitimate complaint to set those records straight.”
The rules were *deliberately violated* in each and every state, except Minnesota.
“I can see that if the database is full of errors then it is going to be more difficult to get the recordings straightened out.”
The database was insecure. Hundreds or thousands of people at many many different banks had the power to enter a “change of ownership” for *any* mortgage in the database with no tracking of who made the change or why. The database is actually *worthless*.
Someone’s going to have to track down the history of payments in order to straighten things out. MERS records are worth absoultely nothing at all.
As much as I think discrediting MERS is crucial to solving our housing problems, I’m curious about whether Biden’s suit really has merit. It strikes me that the “deceptive practice” Biden is using as fraud is actually the practice of the bank issuing the mortgage (that is, you get a mortgage from Bank A, but, using MERS, that bank then reassigns the loan), or perhaps, the mortgage servicer (which represents itself as the holder of your mortgage, because MERS, but isn’t). I’m sort of left thinking “MERS is guilty of something… but this isn’t quite it.” If MERS committed fraud, it seems to me that fraud was among the banks that were members of the system – giving the sense that loans had been reassigned electronically, despite dubious legality. Ultimately, yes, that hurts the person who assumed the mortgage… but the idea that MERS perpetrated a fraud against the homeowner strikes me as a stretch.
This is all just an impression, and I’m happy to be corrected.
I have the link to the actual lawsuit in the updated post. The first ten pages cover the meat of the case and are a pretty fast read. It should clear up your questions.
MERS has succeeded in some states clear up to the states supreme courts. Nothing will happen with the younger Biden peacocking here unless Delaware law treats mortgages and notes as one and the same. And who’s really being defrauded here? The security holders? The homeowners? Does he even have standing?
“It is still mind-boggling that the securitization industry saw it fit to run roughshod over the property records of this country to save such small amounts over money (over an entire 5000 mortgage securitization, the savings would be $350,000 which in all likelihood was ripped out in more fees rather than passed on to consumers).”
A classic case where cheap may not be inexpensive.
seems like a straight forward consumer fraud allegation to me…
“Running a mortgage registry that lacks the internal controls to ensure accuracy, while holding itself out to the courts, investors, and the public as an authoritative source of mortgage title, is an inherently deceptive trade practice, and its harm has been compounded by MERS’
role in the foreclosure process.”
go beau!
I don’t understand why “states’ rights” conservatives and libertarians aren’t more upset about MERS. It may be the way the press has treated the whole MERS mess, describing it as an attempt to “nationalize” the land recording system. That’s hogwash: it isn’t “nationalization” at all. Nationalization would mean the US government decided to do all recording. This is privatization of a core state function without state consent (except, perhaps for Minnesota).
There is probably no more basic characteristic of state sovereignty than the regulation of the rights of people to exclude others from their land, and MERS is undermining that right. The federal government has no authority at all over such basic property rights by design (see U.S. Const. Amendment X). The large banks’ creation of MERS is a blatant attempt to usurp states’ power, and many states are either blissfully ignorant of the risk, or blithely willing to allow the banks to do it.
You would think that both Ron Paul and Haley Barbour (for example) would be up in arms about this kind of extra-legal power grab, but neither have made any significant public comments about MERS. Of course, it isn’t surprising about the Barbour types; the modern Conservatives’ principles get bent, tortured, or abandoned very quickly once they are plied with massive amounts of Wall Street cash. But the Ron Paul type libertarians generally seem to have a stronger fealty to ideology and principle (that is, they can’t be bought so easily), so one would think this issue would show up prominently on their radar.
Perhaps now that the (generally Democratic) AGs are finally standing up for their citizens’ rights, the others will try to get out in front of the issue.
I think most of the public (90%) isn’t familiar with the issue.
Most of the public isn’t familiar with any issue, other than who’s the favorite to be the next American Idol.
I see another purpose for the general allegations in this suit: by alleging “MERS acts like a puppet whose strings are pulled by its members’ employees,” the AG is building a case for “piercing the corporate veil.” If a corporation fails to observe corporate formalities (such as by letting anyone who pays $25 bind it legally), then the Delaware courts may take away MERS’ corporate identity, leaving the stockholders potentially liable for MERS’ acts.
Of course, since 1999, MERS is owned by MERSCORP, which has very little in the way of assets. The next step would be to pierce MERSCORP’s corporate veil as well. At that point, you get to the deep pockets.
How does the U.S. Circuit Court of Appeals for the Ninth Circuit District on this last month factor in?
If you mean the Cervantes case, it will have very little effect on the Delaware AG suit. First, since it’s a federal case, it has no binding authority over anyone but the litigants and others involved in mortgage litigation in federal court (it would have significant persuasive authority within Arizona and the 9th Circuit). Second, Cervantes was concerned with whether MERS had the authority to act at all. There are a few instances where courts have found that MERS did not have authority to act (notably In re Agard in the NY Bankruptcy Court), but in general, MERS can be named as a nominee. Where MERS has failed is generally in how it carries out its duties. That’s pretty much the thrust of the Delaware case.
I strongly recommend anyone truly interested in the subject of MERS and its effects on chain of title to a property read this:
http://harbingerag.com/Papers/MERS%20Report%20Exhibits%20Combined.pdf
{The suit takes the interesting angle of pursuing MERS for engaging in deceptive consumer practices. Nevada’s attorney general has also used the deceptive practices argument in suing Countrywide for violation of HAMP procedures.}
It never ceases to amaze why a piece of legislation that has been on the books since 1968 has never been enforced and is not referred to in the SubPrime Scandal (which countenanced predatory lending practices).
That legislation is called the Truth in Lending Act. (See here: http://en.wikipedia.org/wiki/Truth_in_Lending_Act )
And particularly its General Disclosure Requirements (See here: http://www.fdic.gov/regulations/laws/rules/6500-1500.html#fdic6500226.5 )
It would help if a lawyer – with knowledge of TILA – respond to the question of why TILA is never mentioned as regards the SubPrime Mess …
Yves,
Jim fuller, clerk of duval county , Florida v MERS
2011 – CA – 008974
class action
filed October 31, 2011
no hat tip, please