CoviNGTON & Burling llp ROBERT D.

WICK

BEIJING BRUSSELS LONDON NEW YORK I20I PENNSYLVANIA AVENUE, NW

SAN DIEGO SAN FRANCISCO SEOUL WASHINGTON, DC 20004-240I
SHANGHAI SILICON VALLEY WASHINGTON
T 202.662.5487
rwtck®cov.com

August 8,2014

BY FEDERAL EXPRESS

Joseph A. Black, Esq.

The Cullen Law Firm, PLLC
1101 30th Street, NW, Suite 300
Washington, DC 20007

Re: United States ex rel. Schneider v. J.P. Morsan Chase Bank N.A.

Dear Mr. Black:

As you know, this firm represents J.P. Morgan Chase Bank, N.A., J.P. Morgan Chase &
Co., and Chase Home Finance LLC in the above-captioned matter. We understand that you are
planning to file an amended complaint on behalf of Mr. Schneider. We wish to bring to your
attention certain facts that we hope you will consider as you go forward.

The complaint that is now on file with the court may have been intended to allege that
Chase claimed credit under the National Mortgage Settlement ("NMS") for releasing liens that it
did not own or that were ineligible for credit under the NMS. For each lien identified in the
complaint. Chase has investigated whether it claimed credit for the lien and whether it was
entitled to do so. With two exceptions, Chase did not, in fact, claim credit for the identified
liens. The two exceptions relate to liens that Chase repurchased before they were released. As a
result of the repurchases. Chase owned both of the liens for which credit was claimed.

Chase has also investigated the allegations in the complaint regarding non-compliance
with the anti-blight servicing standards in the NMS. The anti-blight requirements apply to loans
for which a decision not to foreclose occurred after implementation of the settlement in October
2012. For each of the identified loans that meet this date range, Chase has confirmed that
appropriate lien releases and notices were sent in compliance with the anti-blight standards.

Although Chase also disagrees with the remaining allegations of misconduct in the
complaint, this letter addresses only the alleged violations of the NMS for which the complaint
identifies specific liens. All such allegations are addressed in the two paragraphs above. With
respect to any other allegations in the complaint, no inference should be drawn that Chase agrees
with or acquiesces in those allegations.
CoviNGTON St Burling llp

Joseph A. Black, Esq.

August 8, 2014
Page 2

We hope you will consider this information carefully as you go about amending the
complaint.

Sincerely,

Robert W. Wick