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February 11, 2011


Comptroller of the Currency Customer Assistance Group

1301 McKinney Street, Suite 3450 Houston, TX 77010-9050

Re: Case ti0d11111f I

U.S. Bank National Association

a. It was fabricated and robo-signed by an employee of Orion Financial Services (also located in Texas) - See attached article.

b. The assignor identified in this assignment IS NOT the original lender on our NOTEf Of course, CitiMortgage Inc., CitiFinancial Mortgage Company, Inc., CPCA Trust 1, Acqura Financial Services, Vantium Capital

To Whom it May Concern:

In accordance with your letter dated January 31, 2011, I am sending you this' letter. because U,S, Bank National Association, Citimortgage and Acqura Loan Services (A division of Vantium Capital Inc.) failed to address any of my issues and concerns as set forth in my letter to them dated January 18, 2011 (for which I have proof Acqura Loan Services received) and instead, fabricated and recorded yet another fraudulent document with the San Diego County Recorder on February 7, 2011 (attached),

It is important to note that CPCA Trust 1 (formed in Delaware on June 27, 2008) never had valid ownership of our loan and has no standing to transfer our loan from one Delaware shell trust company formed by Castle Peak Capital Advisors to another - in this case Castle Peak 2010-1 Loan Trust (formed 'in Delaware on June 28, 2010). The latter trust was formed exactly two years after the formation of CPCA Trust 1, I do not know Delaware corporate law, but I wonder if there was a reason for that? Do assets have to be placed in trusts within a certain time period after the date they are formed? This may be yet another aspect of the fraud being perpetuated by these criminals.

1. I continue to assert that the assignment from CitiMortgage Inc" successor by reason of merger to CitiFinancial Mortgage Company, Inc. to CPCA Trust 1 recorded in San Diego County on June t t, 2010 is a fraudulent document based on the following:

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Comptroller of the Currency February 11, 2011

lnc., U~S. Bank National Association and Orion Financial Services have no idea who ilthe'c'riglnal hok{~rbf our NOTE because they do not have our original note and DO NOT OWN OUR NOTEI

c. In addition, recent news articles confirm that Citigroup recently settled several fraud cases across the nation that are tied to Orion Financial Services, Inc. (the same entity that fabricated, robo-signed and recorded the June 11, 2010 assignment of my mortgage)- See attached article.

d. Recent news articles confirm that Acqura Financial Services, on behalf of .

Wells Fargo & Co., filed a foreclosure complaint on a person more than a year after U.S. Bancorp filed a complaint ON THE SAME PERSONI Both U.S. Bancorp and Acqura Financial Services are identified as TRUSTEES for investors in two separate mortgage pools ... obviously the loan could not be held by both at the same time. Acqura only withdrew the lawsuit it filed on behalf Of Wells Fargo after being asked about the dueling foreclosures! Note the quote from Mr. Ron Bendalin, general counsel for Vantium Capital, which owns Acqura Loan Services: ".... [T]he trust should have replaced the plaintiff in the first case." My interpretation of that response is "we should have fabricated and recorded a fraudulent assignment first." Who knows how many of these duplicate foreclosure claims Acqura Financial Servcies, A Vantlurn Capital lnc., is making on behalf of other financial instituations - including CitiMortgage and U.S. Bankl

2. The assignment recently recorded on February 7, 2011 is very suspect for the following reasons:

a. The assignment was filed electronically by the Mortgage Electronic Reg·istration Service (MERS). I do not think I need to go into detail on why this is a problem since there has been enough valid information and court decisions that indicate MERS is not a reliable source of mortgage information, and indeed, the perpetrator of widespread mortgage fraud across the nation.

b. The assignment is allegedly signed by Steve Allison of CPCA Trust 1.

Steve Allison is with Castle Peak Capital Advisors, LLC which is located at 12 South Sixth Street, Suite 950, Minneapolis, MN 55402, Phone: 612.376.1570. His bio from Castle Peak Capital Advisors LLC, indicates that Mr. Allison is responsible for the Due Diligence, Servicing and Asset Surveillance:

"Mr. Allison has 29 years of experience within the mortgage banking sector, with a particular emphasis in portfolio acquisitions, loan servicing and risk

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Comptroller of the Currency February 11, 2011

management. Mr. Allison was previously with GMACResCap where held positions Including Vice President of Master Servicing and most recently. Managing Director of Institutional and Distressed Mortgage Transaction Management, Acquisitions and Loan Operations. Mr. Allison formerly served as Director of Servicer Management for the Federal Home Loan Mortgage Corporation and also held management positions at Talman Home Mortgage and Draper and Kramer Incorporated."

So, the question comes to mind .... did Mr. Allison fly/drive from Minneapolis, Minnesota to Irving Texas to sign a pile of fraudulent assignments prepared by Acqura Loan Services? Did he really personally appear and sign documents in front of notary Ms. Lauren Hardy? Is he really personally known to Ms. Lauren Hardy? Or is it more likely that Mr. Allison did not fly/drive to Texas and that this assignment is robo-signed by an employee of Acqura Loan Services and that Ms. Lauren Hardy has broken the notary laws of the state of Texas? This can easily be investigated based on travel documents, etc.

3. And last, but certainly not least. ... Acqura Financial Services, a Vantium Capital Inc. entity, still has not provided any evidence that it has any standing or agreement with CPCA Trust 1, Castle Peak 2010-1 Loan Trust or U.S. Bank Trust, National Association to service this loan, let alone fabricate, notarize or record any assignments I have been requesting this documentation from them since November 2010, and the only responses I get back include newly fabricated fraudulent documents as provided to you in my previous correspondence.

I appreciate the attention you are giving this matter and look forward to hearing from you.


Assignment Recorded on June 11, 2010 Assigm:nent Recorded on February 7, 2011

co: Acqura Loan Services (Via Certified Mail - Return Receipt Requested)

Recording Requested by: Orion Financial Group. Inc.

DOC# 1111111111111111111111



FEES: 12.00






c/o Orion Financial Croup, Inc. ~1 2860 Exchange Blvd. II 100

Southlake, TX 76092 \ \


'«) j'~

Jr' rJI (Y 8416

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( '. Assignment of.Deed.ofTrust·· Send AnyNoti~s'1'o Assignee,

For Valuable: Consideration, the undenigned, CITIMORTGAG~, INC. SUCCESSOR BY REASON OF MERCER TO .

CITIFINANCJAL MORtGAGE COMPANY, INC. 4050 RECENT BLVD, MAIL STOP N2A·112,IRVING, TX 15{)63 (Anlgnor) by these presenlS does uslgn and set over, without recourse, to CPCA TRUST I 12 South Sixth Street, SuUe 9S0,

Minneapolis, MN 55402 (Assignet) the described deed of'trust.tcgether with certain note{s) described with all interest, rill liens, any rights due or to become due thereon, executed by HUSBAND AND WIFE AS COUMMUNITV PROPERTY to CITIHNANCIAL MORTGAGE COMPANY, LLC. Said deed of trust Dated: 312512006 is

recorded in the State or CAl County of San Diego on 4/Iltl006. Document J I £311 AMOUNT: S 149.U6,SO Property

Address: LA JOLLA, CA •

IN WITNESS WHEREOF. the: undersigned corporation has caused this inS(ruJT1enl to be executed as a sealed instrument by its proper

officer. Execuled . Y 10,2010



~~_""~~.fl'!tt.. J, flORIS

" 'I Notl"" Pub,,,, SI'I. of T,.II"

. \{~ Mv Commll.lon bpI, ..

.:'!!!illl OalDbe, 21. 201 ~

CA San Diego


It gets better look who is the mysterious D.M.

WILEMAN, signing

,.. T .' • .'., •

all these

assignments as Vice President of CitiMortgage

Mike Wileman - Linkedln


Mike Wileman

President & CEO at Orion Financial Group, Inc.

Region de Dallas/Fort Worth

Current • Managing Member at Dvine Credit Services Association, LLC

• President & CEO at Orion Financial Group, Inc.

Past • Region Manager at Citigroup

• Senior Vice President at Associates Financial Services

Education • Ohio University

Recommendations 1 recommendation

Connections 251 connections

Industry Externalisationldelocalisation

Mike Wileman's Summary

Senior Executive with 20+ years direct P&L responsibility in mortgage or mortgage related industry. Successful in corporate environment and as a small business owner. Strong project manager and communication skills. Experienced in:

· Human Resource Management

· Public / Media Relations

· Branding I Advertising

· Managing Start-Up Operations

· Public Speaking

· Developing Compensation Plans

· Business Plan Development and Presentation

Mike Wileman's Specialties:

Process management; consulting; small business owner and melti-state management.

Mi ke Wi leman's Experience

Managing Member

Dvine Credit Services Association, LLC (Services aux consommateurs industry) octobre 2008 - Present (2 years 5 months)

A sales organization partnering with National Credit Federation to provide a membership based service focusing on the restoration of consumer's credit.

President & CEO

Orion Financial Group, Inc. (Externa'isatiorsdelocalisation industry) juillet 2001 - Present (9 years 8 months)

I of3

2111/2011 12:56 PM

Mike Wileman - Linkedln

Orion Financial Group, Inc., based in Southlake, Texas, specializes in lien release, assignment and document retrieval services for the mortgage industry, covering ~very recording office in the U.S. Through the company's proprietary document management software, OocPro!®, it can generate county-specific documents with all appropriate recording fees - virtually eliminating rejections. High volume or low volume, the company's pledge is to provide peak performance in document services with speed, integrity and professionalism. For more information, please visit the company's web site at www.orionfgLcom.

Region Manager


(Services financiers industry) 2000 - 2001 (1 year)

Senior Vlce President Associates Financial Services (Services financiers industry) 1994 - 2001 (7 years)

Mike Wileman's Education

Ohio University

BSC , Organizational Communications, 1979 - 1984

Activities and Societies: 4 years Golf

Additional Information

Mike WiJeman1s Interests:

consumer finance, business development, speaking, golf, travel Mike Wileman's Groups:

Mortgage Professional's World Wide (MPWW)

Banking Connects

au Alumni (6,000+ members)

The Sales Association

BPO Executives

Real Estate innovation (Entrepreneurs, Investors, Lenders, Services Providers)

Financial Services Consortium

Commercial Real Estate Connections

Finance Industry Professionals Worldwide NYC Real Estate

Real Estate Open Networkers - BPO - Business Process Outsourcing

Consumer Finance Professionals


211112011 12:56 PM

Mike Wileman - LinkedIn

Shared Services & BPO Network Real Estate Lawyer Network

The Real Estate Networking Group SuperCFO

A Better Business Experience. Financial Services Career CenterTM Real Estate Tax Group

Annual Mortgage Servicing Conference Bold Real Estate Group

Texas Young Professionals

Caribbean Real Estate Network

PPIP - Public-Private Investment Program - Legacy Loan Program Real Estate Network of Professionals - Powered by Finance Club

Commercial Real Estate Finance Green Real Estate

The Chief Executive Officer (TGL) Adelman Realty Group

The Safes Association-Dallas Chapter Real Estate Agent Legal Network

Philadelphia Area Mortgage Brokers & Lenders Protect your investment and avoid litigation! Accountant-Lawyer Alliance (ALA)


Buying & Selllng Distressed Mortgage Portfolios - Commercial & Residential Mortgage Repurchase Rebuttal Experts



2/l 1I201 1 12:56 PM



TO YOU ?????



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FEB 07 J 2011 8:00 AM



FEES: 21.0D

When recorded mail to:


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Acqura Loan Services 7880 Bent Branch Dr. Suite 150

Irving, TX 75063

Space above thIs line for recorders use

APN: d I I 2. ct· .

TS#:Q3 •

IJder_#: 100638542-CA-MAI O),hono No, 1-866-679-8377

Assignment of Deed of Trust

For value received, the undersigned corporation hereby grants, assigns, and transfers to

Castle Peak 2010-1 Loan Trust, by U.S. Bank Trust. National AssQClatlon, not In Its Individual capacity but solely as Owner Trustee

All beneficial interest and all rights accrued or to accrue under that certain Deed of Trust dated 3125/2006 executed by ROBERT I HUSBAND AND WIFE AS COUMMUNITY PROPERTY, as Trustor(s) to VERDUGO TRUSTEE SERVICE CORPORATION, as Trustee and recorded as Instrument No. 'Wee" 7 61. on 4111/2008 of Official Records, In the office of the County Recorder of SAN DIEGO County, CA. (hat secures the underlyIng promissory note.


T5 #: CA-10-39640S-AB Page 2


State of: "'"'<>t-lt\ County of: Th \. \ 0... ~ ) 9/1_0\- :-\"'ll

0'\tiC,=-::-__""-~~~-).:.7'-:--C--1 wh . . to be the person{s)

whose name(s) Islare subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies). and that by his/her/theIr slgnature(s) on the instrument the person{s), or the entity upon behalf or which the person(s) acted, executed the Instrument.

I certify under PENAL TV OF PERJURY under the laws of the State of \'e.\L 1).') that the

foregoIng paragraph Is true and correct. [ .

-it i ,Sf11(\{)l1l\..tl1 f\) n~ 1DV)'V

WITNESS my hand and official seal, (Seal) Y-

6?1NM ;\JlJj)1M <:' r> ~ -y

} SS.

LAUREN HA~OY NOllry Puhlic. Sll" 01 T.llu MV Commission hpir,.

Octobel 17.2012

Citigroup Settles Fraud Cases Tied to Texas Mortgage Assigner - Bloomberg

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Citigroup Settles Fraud Cases Tied to Texas Mortgage Assigner

Or Dnnul (iril1ill aud Dtlkill Cmnpl\cll· Fch x. 201 J

Citigroup 111c'J the third-largest U.S. bankJ settled or lost at least five claims in 2010 brought by borrowers who accused the bank of filing fraudulent mortgage documents provided by a Texas firm.

In the most recent settlement in December, a bankrupt homeowner in Wappingers Falls, New York, challenged Citigroup's use of a mortgage "assignment," which shows the transfer of ownership of a mortgage. It was signed by an employee at Orion Financial Groy]> Inc~ .. a Southlake, Texas, firm that provides document services ~o lenders.

The document was «of fraudulent nature and questionable origin," the borrower's attorney, Linda Tirelli, wrote in an August objection to the bank's claim at U.S. Bankruptcy Court in New York. Citigroup created and filed the assignment after proceedings began because it otherwise couldn't prove its right to collect the debt, she wrote in an e-mail. The bank denied the allegations and didn't admit liability in the settlement.

Attorneys general in 50 states are investigating the industry's use of mortgage assignments as part of a wider probe into faulty foreclosure methods, according to Geoff Greenwood, a spokesman for Iowa attorney general Tom Miller. Last month, a Massachusetts court ruled that two foreclosures by Wells Fargo & Co. and U.S. Bancorp were invalid because assignments presented in those cases failed to prove the chain of ownership of the mortgage, sending financial stocks down.

Connect the Dots

Bankruptcy judges are "appropriately skeptical" when mortgage servicers claim to have assignments, said Keith Lundin, a U.S. Bankruptcy Court judge in Nashville, Tennessee, in an interview.

"They've got to show me more than their swearing that they have the right," he said. "They're going to have to connect up the dots back to the note and the security agreement, which would be the mortgage." 11-02-08/citigroup-settles-as-banknlpt -homeowne., 2/812011

Citigroup Settles Fraud Cases Tied to Texas Mortgage Assigner - Bloomberg.

Page 2 of4

Harold Lewis, an executive with ~he CitiMortgage subsidiary, told Congress in November that the bank reorganized foreclosure operations last February, helping it avoid the faulty affidavit-signing practices that forced peers such as JPMorgan Chase & Co. to temporarily halt home seizures last year.

Citigroup paid almost $82,000 in opponents' legal costs when settling challenges to four bankruptcy claims that used Orion letters in 2010, according to agreements filed with federal bankruptcy courts in New York and Arkansas. The bank reduced interest rates on the remaining debt by an average of 49 percent, while cutting the outstanding mortgage balance in three cases by a combined $55,000, the filings show.

Raising Questions

"It doesn't strike me as something that lenders do every day of the week," said Melissa Jacoby, a bankruptcy law professor at the .lIujyetmof North Carolina in Chapel Hill, referring to the size of the concessions. "It does raise some questions about the practices."

A spokesman for Citigroup, Mark Rodgers, said it doesn't comment on individual cases. The company continues to use Orion for assignment letters, he said. While borrowers have disputed the bank's use of assignments, they haven't accused Orion of wrongdoing.

"We don't create fraudulent documents," said Orion Chief Executive Officer Mike Wileman. His firm's documents show which company may hold the note and can be based on information from the bank, he said. «Sometimes the evidence is circumstantial," he wrote in an e-mail.

Court Records

Rodgers declined to say how often the bank relies on Orion or other outside document providers for assignments. Records aren't electronically searchable in most of the more than 3,000 counties across the U.S. In Tcxa~ls D.nnas County, where documents are available online, Orion prepared at least 14 assignments transferring mortgages to Citigroup since the start of 2009, a search of records there shows.

In the Wappingers Falls case, Citigroup said it was owed about $390~000 from a mortgage on a property in Chapter 13 bankruptcy. The bank filed an assignment prepared by Orion to back the claim. This document claimed another lender had assigned the loan to CitiMortgage on June 24, more than three weeks after the bankruptcy began. 11 ~02~08/citigroup-settles-as-bankrupt-homeowne". 2/812011

Citigroup Settles Fraud Cases Tied to Texas Mortgage Assigner - Bloomberg

Page 3 of4

In settling the borrower's objections, the bank didn't admit wrongdoing. It paid Tirelli's $35,000 legal fees, reduced the mortgage principal by $29,000 and chopped the interest rate almost in half, to 3 percent.

"We reach settlements in cases for a variety of reasons, usually so both patties can avoid the expense of ongoing litigation," Rodgers, the bank spokesman, said in an e-mail.

Massachusetts Ruling

In Massachusetts, the state Supreme Court upheld a voiding of two 2007 foreclosures carried out by San Francisco-based Wells Fargo and Minneapolis-based U.S. Bancorp because the companies hadn't demonstrated that they held the mortgages at the time of the seizures. The banks had backed claims with 80- called blank assignments completed after foreclosure sales.

A lender such as Citigroup may settle to avoid scrutiny of its foreclosure practices during litigation, said April Charney, a senior attorney with Jacksonville Area Legal Aid in Jacksonville, Elorida, who instructs lawyers on representing consumers in foreclosure and bankruptcy cases.

"They're afraid of going through the process," she said. A risk-based analysis may focus on the question, "Do I risk going in front of the judge and getting an order that is going to beam around the whole world?" she said.

Orion is based in Southlake, Texas, a city about 30 miles northwest of Dallas. It provides "mortgage assignment, lien release and document retrieval services" to the mortgage industry, according to its website. Citigroup also uses Orion for assignments in foreclosures, Rodgers said.

Initial Loss

Citigroup is still facing claims tied to an Orion-prepared assignment in a case at U.S. Bankruptcy Court in Aberdeen, Mississippi. In that case, the judge disallowed the bank's initial claim to a property in Olive Branch, a city about 20 miles south of Memphis, Tennessee. The borrower later asked the court to force the bank to prove whether it has rights to the loan. Citigroup filed a response last month, fighting the borrowers' demands.

"We're going to have to go into litigation to determine who if anyone is owed the money and who if anyone still has a security interest," said William Fava, the borrower's attorney.

Citigroup has also filed Orion assignments in bankruptcy cases in states including Maryland and Georgia. 11-02-08/citigl'oup-settles-as-bankrupt-homeowne... 2/8/2011

Citigroup Settles Fraud Cases Tied to Texas Mortgage Assigner - Bloomberg

Page 4 of4

"Do they really have the right to enforce anything in this bankruptcy?" said Ryan Starks, an attorney for borrowers in Georgia, in an interview. "Or are they just clearing up the paperwork?"

Mortgage Business

Citigroup serviced $602 billion of mortgages in the fourth quarter of 2010 and is the fourth-largest mortgage servicer in the country, according to Inside Mortgage Finance, a trade publication.

Lewis at CitiMortgage testified to Congress in November about the bank's overhaul of foreclosure practices. The company was still reviewing 10,000 affidavits that were executed before the overhaul, and about 4,000 affidavits may not have been signed before a notary and may be resubmitted, he said.

Citigroup doesn't anticipate refiling any assignments, and hasn't had to refile any prepared by Orion, said Rodgers, the spokesman,

To contact the reporters on this story: Donal Griffin in New York at ggl'iffil11 ° (wbloombg],; Dakin Campbell in San Francisco at ~lca1l1pbellg_z@DlQQ.mJl~~

To contact the editor responsible for this story: Rick Green at rgree1l18@hloomherg,net

®2011 BLOOMBERG loP. ALL RIGHTS RESERVED, 11-02-08lcitigroup-settles-as-banbupt-homeowne... 2/8/2011