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Wells Fargo & Promontory Financial Group LLC Foreclosure Audit (OCC) WFB-EL-00000001 - CRA Fund Intl Class 036: Insurance; financial affairs; monetary affairs; real estate affairs. Active first use commerce August 1999; BONY Parent: PROMONTORY INTERFINANCIAL NETWORK LLC 'DATA PROCESSING SERVICER' RSSDID 3183315

Wells Fargo & Promontory Financial Group LLC Foreclosure Audit (OCC) WFB-EL-00000001 - CRA Fund Intl Class 036: Insurance; financial affairs; monetary affairs; real estate affairs. Active first use commerce August 1999; BONY Parent: PROMONTORY INTERFINANCIAL NETWORK LLC 'DATA PROCESSING SERVICER' RSSDID 3183315

Ratings: (0)|Views: 283|Likes:
Published by Mary Cochrane
Promontory is 40% owned by The Bank of New York Mellon Corporation and is an affiliate of Promontory Financial Group, a major provider of regulatory
Independent Community Bankers of America (ICBA):BNY Mellon, provides issuance, custody, settlement, and recordkeeping services for the Promontory Network. Promontory has formed a cooperative alliance with the Independent Community Bankers of America (ICBA) to help community banks attract and retain large deposits, as well as better serve their most valued customers through Promontory's services: ICSSM, the Insured Cash Sweep® service; and CDARS®, the Certificate of Deposit Account Registry Service®. ICBA aggregates the power of its members to provide a voice for community banking interests in Washington, and resources to enhance community bank education, marketability and profitability options that help them compete in an ever-changing marketplace.

EAGLEBANK ACQUIRED SECURITY INTERETST OF 13/MARKS INCORPORATED INTO 'CREDIT FACILITY' BETWEEN LENDERS/BORROWERS AND INCLUDE: PROMONTORY INTERNETWORK FINANCIAL for which BONY Parent under Federal Reserve System (FFIEC.GOV) oversight. Details provided.
OCC Foreclosure Audit by Promontory Financial GROUP LLC as Wells Fargo Link:
http://www.scribd.com/doc/112872493/OCC-Foreclosure-Audit-Promontory-Financial-Group-LLC-as-Wells-Fargo-CDARS-Review-WFB-EL-00000001-CRA-Fund-Intl-Class-036-Insurance-financial-aff

FFIEC.GOV LINK PROMONTORY INTERFINANCIAL NETWORK LLC PARENT BANK OF NEW YORK MELLON
CAN CHANGE 'ORGANIZATION DATE' AND CTRL+F TO FIND...PROMONTORY AND FOLLOW $to/from$...
http://www.ffiec.gov/nicpubweb/nicweb/OrgHierarchySearchForm.aspx?parID_RSSD=3183315&parDT_END=99991231

BONY Parent: PROMONTORY INTERFINANCIAL NETWORK LLC 'DATA PROCESSING SERVICER' RSSDID 3183315
Data Processing Servicer
Entities primarily engaged in providing infrastructure for hosting or data processing services. These establishments may provide specialized hosting activities, such as web hosting, streaming services or application hosting, provide application service provisioning, or may provide general time-share mainframe facilities to clients. Data processing establishments provide complete processing and specialized reports from data supplied by clients or provide automated data processing and data entry services.

BONY: Community Development Bankers Association (CDBA): Promontory formed an alliance with the Community Development Bankers Association (CDBA) to enable socially-motivated investors and bank seeking Community Reinvestment Credit to invest safely in America's underserved and most impoverished communities simply by making deposits through Community Development Banks. CDBA is the national membership trade association of the community development banking industry and all members are certified by the U.S. Department of Treasury as Community Development Financial Institutions.

Sarah Bloom Raskin was appointed Maryland Commissioner of the Office of Financial Regulation in August of 2007. Previously Sarah Bloom Raskin served as managing director of Promontory Financial Group where she worked with banks and other financial institutions on regulatory, governance, ethics, consumer, and other issues. In addition, she served as counsel to the United States Senate Committee on Banking, Housing, and Urban Affairs where she worked on banking and consumer protection issues.

Link: Promontory Financial For: Intl Class 035 Business consulting services & Intl Class 036: Financial management and investment banking services Intl Class 036...Filing 4/25/2006 using mark - did not secure publication but using

The applicant, Promontory Mark, LLC, a LIMITED LIABILITY COMPANY organized under the laws of
Delaware, residing at Suite 617, 1201 Pennsylvania Avenue, N.W., Washington, District of Columbia,
United States, 20004, requests registration of the trademark/service mark identified above in the United
States Patent and Trademark Office on the P
Promontory is 40% owned by The Bank of New York Mellon Corporation and is an affiliate of Promontory Financial Group, a major provider of regulatory
Independent Community Bankers of America (ICBA):BNY Mellon, provides issuance, custody, settlement, and recordkeeping services for the Promontory Network. Promontory has formed a cooperative alliance with the Independent Community Bankers of America (ICBA) to help community banks attract and retain large deposits, as well as better serve their most valued customers through Promontory's services: ICSSM, the Insured Cash Sweep® service; and CDARS®, the Certificate of Deposit Account Registry Service®. ICBA aggregates the power of its members to provide a voice for community banking interests in Washington, and resources to enhance community bank education, marketability and profitability options that help them compete in an ever-changing marketplace.

EAGLEBANK ACQUIRED SECURITY INTERETST OF 13/MARKS INCORPORATED INTO 'CREDIT FACILITY' BETWEEN LENDERS/BORROWERS AND INCLUDE: PROMONTORY INTERNETWORK FINANCIAL for which BONY Parent under Federal Reserve System (FFIEC.GOV) oversight. Details provided.
OCC Foreclosure Audit by Promontory Financial GROUP LLC as Wells Fargo Link:
http://www.scribd.com/doc/112872493/OCC-Foreclosure-Audit-Promontory-Financial-Group-LLC-as-Wells-Fargo-CDARS-Review-WFB-EL-00000001-CRA-Fund-Intl-Class-036-Insurance-financial-aff

FFIEC.GOV LINK PROMONTORY INTERFINANCIAL NETWORK LLC PARENT BANK OF NEW YORK MELLON
CAN CHANGE 'ORGANIZATION DATE' AND CTRL+F TO FIND...PROMONTORY AND FOLLOW $to/from$...
http://www.ffiec.gov/nicpubweb/nicweb/OrgHierarchySearchForm.aspx?parID_RSSD=3183315&parDT_END=99991231

BONY Parent: PROMONTORY INTERFINANCIAL NETWORK LLC 'DATA PROCESSING SERVICER' RSSDID 3183315
Data Processing Servicer
Entities primarily engaged in providing infrastructure for hosting or data processing services. These establishments may provide specialized hosting activities, such as web hosting, streaming services or application hosting, provide application service provisioning, or may provide general time-share mainframe facilities to clients. Data processing establishments provide complete processing and specialized reports from data supplied by clients or provide automated data processing and data entry services.

BONY: Community Development Bankers Association (CDBA): Promontory formed an alliance with the Community Development Bankers Association (CDBA) to enable socially-motivated investors and bank seeking Community Reinvestment Credit to invest safely in America's underserved and most impoverished communities simply by making deposits through Community Development Banks. CDBA is the national membership trade association of the community development banking industry and all members are certified by the U.S. Department of Treasury as Community Development Financial Institutions.

Sarah Bloom Raskin was appointed Maryland Commissioner of the Office of Financial Regulation in August of 2007. Previously Sarah Bloom Raskin served as managing director of Promontory Financial Group where she worked with banks and other financial institutions on regulatory, governance, ethics, consumer, and other issues. In addition, she served as counsel to the United States Senate Committee on Banking, Housing, and Urban Affairs where she worked on banking and consumer protection issues.

Link: Promontory Financial For: Intl Class 035 Business consulting services & Intl Class 036: Financial management and investment banking services Intl Class 036...Filing 4/25/2006 using mark - did not secure publication but using

The applicant, Promontory Mark, LLC, a LIMITED LIABILITY COMPANY organized under the laws of
Delaware, residing at Suite 617, 1201 Pennsylvania Avenue, N.W., Washington, District of Columbia,
United States, 20004, requests registration of the trademark/service mark identified above in the United
States Patent and Trademark Office on the P

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Published by: Mary Cochrane on Nov 11, 2012
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12/04/2012

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Letter
the purpose
of
WFB-EL-00000001
 
Wells Fargo
Bank,
N.A.August 31, 2011any
other
respect perform the Foreclosure Review
as
further
detailed in this letter. Promontory willconduct the Foreclosure Review entirely Independently
of
Wells Fargo, subject
to
the direction
of
the
OCC
and not Wells Fargo.
WeJls
Fargo may
not
oversee, direct,
or
supervise the engagement, but thiswill
not
preclude Wells Fargo and Promontory from working consultatively,
or
Wells
Fargo
fromcommunicating
with
Promontory
as
necessary both to identify opportunities
to
Improve the operations
of
its foreclosure processes in light
of
information rearned by Promontory through the performance
of
the Foreclosure Review, and to confirm
that
Promontory's performance
of
the Foreclosure Reviewcomplies
with
the requirements
of
the
Consent Order. Promontory will
be
subject to review andoversight by the
OCC
at all stages
of
the Foreclosure Review, will regularly brief the
OCC
on the workbeing performed,
and
will
follow
comments and directions provided
by
the
OCC.
1.
B.ACKGROUND
The Consent Order:
On
April 13, 2011, Wells
Fargo
and the
OCC
entered into the Consent Order, whichrelates to the conduct
of
Wells Fargo's mortgage servicing business. Article
VII
of
the Consent Orderrequires Wells Fargo, within 45 days
of
the date
of
the Consent Order,
to
retain
an
independentconsultant
to
review certain residential mortgage foreclosures completed
or
initiated by Wells
Fargo
incalendar years 2009 and 2010 (the "Foreclosure Review") within 120 days following the
OCC's
approval
of
the independent consultant's retention.
The
Foreclosure Review Preparation SOW:
In
anticipation
of
the Consent Order, and in accordance
with
the MSA, Wells Fargo and Promontory entered into a Statement
of
Work (the
«(Foreclosure
ReviewPreparation SOW")
that
obligated Promontory
to
perform various planning and preparation tasks toensure the smooth
and
effective conduct
ofthe
Foreclosure Review. Those tasks included thedevelopment
of
this Agreement.
2.
ORGANIZATION
OF
THIS
AGREEMENT
Section 3
of
this Agreement sets
forth
its essential terms and conditions. Section
3.a
sets forth
an
affirmative statement
of
the parties'
intentto
comply with the terms
of
the Consent Order. Section 3.bidentifies the project name. Section 3.c describes the scope and timing
of
services
to
be provided byPromontory pursuant to this Agreement. Section 3.d describes the performance period. Section
3.e
identifies work sites. Section
3.f
identifies Attachment D
as
describing the
fees
that
Promontory expects
to
charge Wells
Fargo
for
services performed under this Agreement,
as
well
as
the costs
for
which WellsFargo will reimburse Promontory. Section 3.g sets forth acceptance criteria. Sections 3.h and
3.1
Foreclosure Review Engagement Letter,
page
2
WFB-EL-00000002
 
Wells
Fargo Bank,
N.A.August
31,
2011identify project managers. Section 3.j identifies subcontractors
that
Promontory intends to
use.
Section3.k sets all other terms and conditions governing the conduct
of
this agreement.Article VII(2)
of
the Consent Order requires this Agreement
to
include four items.
The
table belowsummarizes those items and indicates the section and
page
of
this Agreement
that
responds to
each
of
them.
AGREEMENTREQUIREMENT SECTION
PAGE
Methodology
for
conducting the
File
Review
Process
Attachment A A·iExpertise and resources to
be
dedicated
to
the Foreclosure Review Attachment C
C"i
Completion
of
the Foreclosure Review within one hundred
twenty
(120) days from approval
of
this Agreement Section 3.d.ii,1 6Commitment
that
any workpapers associated
with
the ForeclosureReview
be
made available to the
acc
immediately upon request Section 3.e.vi 5Nine attachments provide important supplemental information and are integral
to
this AgreementAttachment A ("File Review
Process
and Methodology") sets forth the methodology Promontory intends
to
use
in performing the
File
Review
Process.
In accordance
with
the terms
of
the Consent Order,Attachment A includes (i) a description
of
the
information systems and documents
that
Promontory willreview, including the selection
of
criteria
for
cases
to
be
reviewed; (ii) the criteria Promontory intends toapply
in
evaluating
the
reasonableness
of
fees and penalties; (iii) other procedures necessary to
make
the required determinations (such
as
through interviews
of
employees and third parties and a
process
for
submission and review
of
borrower claims and complaints)j and (iv) Promontory's proposedsampling techniques, induding both a full description
of
the statistical
basis
for
the sampling methodschosen,
as
well
as
procedures to increase the
size
of
our sample depending on results
of
the initialsampling.Attachment B ("Complaint
Process
and Methodology") sets forth the methodology Promontory intends
to
use
in performing the Complaint
Process.
Attachment B describes
how
Promontory envisions thatForeclosure Review Engagement Letter,
page
3
WFB-EL-00000003

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