Bank of America is Captain of the Mod Fraud Squad

Most of my job consisted of speaking on the telephone with homeowners who were calling regarding a loan modification that they had applied for as part of HAMP.

I regularly reviewed the HAMP requirements and procedures on the US Treasury Department website.  I did this on my own as BoA provided no training or information regarding HAMP and I wanted to know what I was talking about to homeowners calling in.  Most, if not all of my colleagues and supervisors did not have suitable training, education, or experience in modifying mortgages, and certainly not regarding HAMP requirements or procedures.

Based on what I observed, BoA was trying to prevent as many homeowners as possible from obtaining permanent HAMP loan modifications while leading the public and the government to believe it was making efforts to comply with HAMP.   It was well known among managers and many employees that the overriding goal was to extend as few HAMP loan modifications to homeowners as possible.

The information we received in group meetings [ed. with supervisors] was to string homeowners along with no intention of providing permanent modifications.  We were instructed to inform every homeowner who called in that their file was “under review”-even where the computer system showed that the file had not been accessed in months or when the homeowner had been rejected for a modification.

My colleagues and I were instructed to inform homeowners that modification documents were not received on time, not received at all, or that documents were missing, even when, in fact, all documents were received in full and on time.

One tactic Bank of America used to delay the modification process involved telling homeowners who applied for a HAMP modification or who were in a Trial Period Plan to resubmit financial information each time they called to inquire about a pending modification.  BoA then treated any change in financial information as justification for considering the homeowner to have restarted the HAMP process.  Even a small change to financial informaion will cause BoA to restart the application process under the pretext of changed financial information.

When BoA purchased loans from other servicers, including when it bought the servicer itself–as it did with Wilshire Credit, BoA forced the homeowners to restart the modification process.  When a homeowner called regarding a modification started with another servicer, my co-workers and I were instructed to say that BoA had no record of the modification or of the payments the homeowner already made under the modification.  We were instructed to make this statement even when BoA’s system showed the homeowners’ modification and previous payments, and even when the system showed that the homeowner had completed the trial process with the previous servicer and should have received a permanent modification.

Even after a homeowner signed and returned modification (both trial modifications and permanent modifications), BoA’s system continued to show the loan as delinquent to credit reporting agencies, and pursued foreclosure.  I saw multiple instances of people who had lost their homes to foreclosure despite having fulfilled all of the requirements of their Trial Period Plans. 

She says that managers pushed production goals on the loan level employees:

Employees were awarded incentives such as $25 in cash, or as [sic] a restaurant gift card based on the number of accounts they could close in a given day or week – meaning how many applications for loan modifications they could decline.  

I personally witnessed employees and managers close loan accounts based on information that was obviously wrong.  This included closing accounts, and declining loan modifications based on the homeowner’s failure to provide certain documents or information when, in fact, it was apparent from the loan file and from the electronic system of record (electronic databases including AS400, HomeSaver, HomeBase, and others) that the homeowner had provided the very information claimed to be missing.

We received written evalations known as “scorecards” on a weekly basis via email.  These scorecards evaluated employees based on criteria including the number of customer calls they took each day, the number of minutes they spent on each call, and whether they gave the homeowner too much information.  Employees received negative evaluations and negative comments if they spent too much time on the phone with a particular homeowner in an effort to answer their questions or if they gave what Bank of America considered to be too much information about the modification process. 

Declaration of Theresa Terrelonge.