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(D.E. 154) JPMC's Final Consumer Relief Report-California Agreement, US V BoA 12-00361
(D.E. 154) JPMC's Final Consumer Relief Report-California Agreement, US V BoA 12-00361
)
UNITED STATES OF AMERICA, et. al., )
)
Plaintiffs,
)
v. )
Civil Action No. 12-00361 (RMC)
)
BANK OF AMERICA CORP., et. al., )
)
Defendants. )
)
April 4, 2012 (“Judgment”) and as Monitor pursuant to the February 9, 2012 agreement between
the Attorney General of the State of California (“Attorney General”) and Bank of America
Corporation, J.P. Morgan Chase & Co. and Wells Fargo & Company (“California Agreement”),
respectfully files with the United States District Court for the District of Columbia (“Court”) this
Final California Consumer Relief Report (“Report”) regarding the satisfaction by J.P. Morgan
Chase & Co., as of February 28, 2013, of its Consumer Relief Requirements under the California
Agreement, as such obligations are set forth with more particularity in Exhibit A to the
California Agreement and Exhibits D and D-1 to the Judgment. This Report is filed pursuant to
Exhibit A to the California Agreement. The California Agreement is Exhibit A to the Notice of
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Submission of Additional Settlement Agreements filed with the Court on March 13, 2012 (Case
I. Definitions
This section defines words or terms that are used throughout this Report. Words and
terms used and defined elsewhere in this Report will have the meanings given to them in the
Sections of this Report where defined. Any capitalized terms used and not defined in this Report
will have the meanings given them in the California Agreement, the Judgment or the Exhibits
attached thereto, as applicable. For convenience, a copy of the California Agreement, without
the signature pages of the Parties and including only Exhibit A, is attached to this Report as
Attachment 1; and the Judgment, without the signature pages of the Parties and including only
In this Report:
i) Actual Credit Amount has the meaning given the term in Section III.E.2. of this
Report;
ii) Attorney General means the Attorney General of the State of California;
iii) California Agreement Testing Period will have the meaning given to the term in
Section II.E. of this Report and is the period from March 1, 2012, through February 28, 2013;
iv) Consumer Relief has the meaning given to the term in Section II.A. of this Report
and consists of any principal reduction on first or second liens (including reductions through loan
the extent that such activity would qualify for credit under Exhibits D and D-1 to the Judgment;
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amount of Consumer Relief credit earned, which report is given to the IRG and is the basis on
Consumer Relief as set forth in the California Agreement, including Exhibit A to the California
Agreement and Exhibits D and D-1 to the Judgment, unless the term is used in connection with
the Judgment, then Consumer Relief Requirements means and is limited to Servicer’s obligations
in reference to providing relief to consumers in the amounts and consisting of the transaction
types set out in the Judgment, including Exhibits D and D-1 to the Judgment;
vii) Court means the United States District Court for the District of Columbia;
xii) Final National Consumer Relief Report means the Final Consumer Relief Report
I filed with the Court on March 18, 2014, pursuant to the Judgment, regarding Servicer’s
creditable consumer relief activities under the Judgment from January 1, 2013, through April 15,
2013, and its satisfaction of its Consumer Relief Requirements under the Judgment;
xiii) First Testing Period is the period from March 1, 2012, through December 31,
2012;
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xiv) Hardest Hit California Counties means the twelve California counties with the
highest annualized foreclosure rate in the previous calendar year, as measured by Notice of
Default filings and identified by the Attorney General’s designated state monitor. For all times
relevant to this Report, the Hardest Hit California Counties are Contra Costa County, Kern
County, Madera County, Riverside County, Sacramento County, San Benito County, San
Bernardino County, San Joaquin County, Solano County, Stanislaus County, Sutter County and
Yuba County;
xv) Interim National Consumer Relief Report means the Interim Consumer Relief
Report I filed with the Court on October 16, 2013, pursuant to the Judgment, regarding
Servicer’s creditable consumer relief activities under the Judgment through December 31, 2012;
xvi) Internal Review Group or IRG means an internal quality control group established
xviii) Monitor means and is a reference to the person appointed under the California
Agreement and the Judgment to oversee, among other obligations, Servicer’s satisfaction of the
Consumer Relief Requirements, and the Monitor is Joseph A. Smith, Jr., who will be referred to
xx) Participating Servicer means one of the Servicers that is a party to the Judgment
xxi) Primary Professional Firm or PPF means BDO Consulting, a division of BDO
USA, LLP;
xxii) Professionals means the Primary Professional Firm and any other accountants,
consultants, attorneys and other professional persons, together with their respective firms, I
engage from time to time to represent or assist me in carrying out my duties under the Judgment
xxiii) Reported Credit Amount has the meaning given to the term in Section III.E.2. of
this Report;
xxiv) Satisfaction Review means a review conducted by the IRG to determine Servicer’s
xxv) Second Testing Period is the period from January 1, 2013, through April 15,
2013;
xxvi) Servicer for the purpose of this Report means J.P. Morgan Chase & Co. when
referring to or used in context with the California Agreement and J.P. Morgan Chase Bank, N.A.
when referring to or used in context with the Judgment or consumer relief thereunder, unless its
usage indicates or requires otherwise, and Servicers for the purpose of the Settlement and this
Report means the following: (i) J.P. Morgan Chase Bank, N.A.; (ii) Ocwen Loan Servicing, LLC
and Green Tree Servicing LLC, successors by assignment to Residential Capital, LLC and
GMAC Mortgage, LLC; (iii) Bank of America, N.A; (iv) CitiMortgage, Inc.; and (v) Wells
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xxvii) Settlement means the Judgment and four other consent judgments filed with the
Court in Case 1:12-cv-00361-RMC that settled mortgage loan servicing claims of the type
xxviii) System of Record or SOR means Servicer’s business records pertaining primarily
xxix) Testing Population has the meaning given to the term in Section III.E.1. of this
Report;
xxx) Work Papers means the documentation of the test work and assessments by the
IRG with regard to Servicer’s satisfaction of the Consumer Relief Requirements, which
documentation is required to be sufficient for the PPF to substantiate and confirm the accuracy
xxxi) Work Plan means the work plan established by agreement between Servicer and
II. Introduction
Under the terms of the California Agreement, Servicer is required to provide mortgage
loan relief in the form of principal reductions on first or second liens through loan modifications,
short sales and deeds-in-lieu of foreclosure to certain distressed borrowers. To qualify for credit,
the mortgage loan relief is required to satisfy the eligibility requirements of one of the following
forms of consumer relief set out in Exhibits D and D-1 (“Consumer Relief”):
1Exhibit D, ¶ 1; Exhibit D-1, ¶ 1. Creditable First Lien Mortgage Modifications include: Standard Principal
Reduction Modifications (Exhibit D-1, ¶ 1.i); Forbearance Conversions (Exhibit D-1, ¶ 1.ii); Conditional
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conducted confirmatory due diligence, I concluded that Servicer had satisfied its Consumer
Relief Requirements under the Judgment. This Report addresses Servicer’s satisfaction of its
obligation to provide Consumer Relief to California borrowers under the California Agreement.
Forgiveness Modifications (Exhibit D, ¶ 1.i); 180 DPD Modifications (Exhibit D, ¶ 1.f); FHA Principal Reductions
(Exhibit D, ¶ 1.j (i)); and Government Modifications (Exhibit D, ¶ 1.j (ii)).
2 Exhibit D, ¶ 2; Exhibit D-1, ¶ 2. Creditable Second Lien Portfolio Modifications include proprietary (non-MHA)
second lien principal reductions, also known as “2.b Modifications” (Exhibit D, ¶ 2.b); second lien principal
reductions based upon a completed non-HAMP first lien modification by a Participating Servicer in the Settlement,
also known as “2.c Modifications” (Exhibit D, ¶ 2.c); second lien modifications conducted through the Making
Home Affordable Program (including 2MP), the FHA Short Refinance Second Lien Program (FHA2LP) or the HFA
Hardest Hit Fund (or any other appropriate governmental program), also known as “2.d Modifications” or “second
lien government modifications” (Exhibit D, ¶ 2.d); and second lien extinguishments to support the future ability of
individuals to become homeowners, also known as “2.e Extinguishments” (Exhibit D, ¶ 2.e).
3 Exhibit D, ¶ 4; Exhibit D-1, ¶ 4. Creditable loss mitigation transaction types in the context of Short Sales and
Deeds-in-Lieu include payments made to an unrelated second lien holder for release of a second lien in connection
with a completed Short Sale or Deed-in-Lieu (Exhibit D-1, ¶ 4.i.); acceptance of a short sale, forgiveness of a
deficiency and release of lien on a first lien loan or second lien loan (including extinguishment of an owned second
lien) in connection with a successful short sale or deed-in-lieu (Exhibit D, ¶ 4.b and c; Exhibit D-1, ¶ 4.ii, iii and iv);
and extinguishment of an owned second lien to facilitate a short sale or deed-in-lieu successfully conducted by a
Participating Servicer (Exhibit D, ¶ 4.d; Exhibit D-1, ¶ 4.iv).
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As reflected in Exhibits D and D-1, each of the forms of Consumer Relief has unique
eligibility criteria and modification requirements. In order for Servicer to receive credit with
respect to Consumer Relief activities on any mortgage loan, these eligibility criteria and
modification requirements must be satisfied with respect to such mortgage loan and such
satisfaction has to be validated by me in accordance with Exhibits D and D-1 and the California
Agreement. For each dollar of creditable principal reduction, Servicer will receive one dollar in
credit.
Under the California Agreement, Servicer may receive additional credit against its
Consumer Relief Requirements for principal reduction in the form of First Lien Mortgage
Modifications completed on or after March 1, 2012 and implemented on or before February 28,
2013. For those First Lien Mortgage Modifications completed in relation to residential properties
located in the Hardest Hit California Counties, this additional credit is in the amount of 25% of
the actual credits earned on the foregoing activities. For those First Lien Mortgage
Modifications that are in relation to other California counties, the additional credit is 15% of the
actual credits earned on those modifications.4 In contrast to the foregoing incentive for
promptness, Servicer will incur a penalty of 50% of its unmet Consumer Relief Requirements,
subject to a maximum amount of $200 million, if it does not meet all of its Consumer Relief
Requirements within three years of March 1, 2012. That penalty will increase to 65% of its
unmet Consumer Relief Requirements, subject to a maximum payment of $200 million, in cases
in which Servicer also has failed to complete 75% of its total Consumer Relief Requirements
within two years of March 1, 2012. If Servicer fails to meet its Consumer Relief Requirements
4 Exhibit A.
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under both the California Agreement and the Judgment, it will pay to the Attorney General an
amount equal to the greater of (a) the amount owed to the Attorney General under the California
Agreement; or (b) the amount owed to the Attorney General under paragraph 10(d) of Exhibit D.5
With respect to the requirements applicable to the forms of Consumer Relief and the
transaction types within each form, on an aggregate basis, at least 85% of credit that Servicer
earns as a result of First Lien Mortgage Modifications and 75% of the credit that Servicer earns
as a result of first lien Short Sales and Deeds-in-Lieu must be in relation to mortgage loans that
have an unpaid principal balance before capitalization at or below the highest GSE conforming
Finally, with respect to the requirements applicable to the forms of Consumer Relief on
the basis of transaction types, there are differences in eligibility for transaction types within each
of the forms of Consumer Relief; there are also differences in eligibility requirements among the
various forms of Consumer Relief. These differences were explained in detail in Section II.B.4
The California Agreement requires that I determine whether Servicer has satisfied the
Consumer Relief Requirements in accordance with the authorities provided in the California
5 Exhibit A. Servicer satisfied its Consumer Relief Requirements under both the California Agreement and the
Judgment within time periods that avoid the imposition of any of the penalties set out in Exhibit A or Exhibit D, ¶¶
10.c, d.
6 Exhibit A.
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On October 14, 2013, after completing a Satisfaction Review, the IRG submitted to me
an IRG Assertion concerning the amount of Consumer Relief credit that Servicer had claimed to
have earned in relation to loans secured by residential properties located in California from
March 1, 2012, through February 28, 2013 (“California Agreement Testing Period”). Servicer
has requested that, in addition to reporting on the IRG Assertion, I review its crediting activity
for the California Agreement Testing Period, validate that the amount of credit claimed in the
IRG Assertion is accurate and in accordance with Exhibit A to the California Agreement and
Exhibits D and D-1 to the Judgment, and certify that it has fully satisfied its Consumer Relief
A. Overview
The process utilized for validating Servicer’s satisfaction of its Consumer Relief
Requirements under the California Agreement followed the same process that the IRG and I,
Requirements under the Judgment. In following that process, the IRG performed a Satisfaction
Review after Servicer asserted that it had satisfied its Consumer Relief Requirements.7 Once it
completed a Satisfaction Review, the IRG reported the results of that work to me through an IRG
Assertion. When I received the IRG Assertion, with my Primary Professional Firm, I undertook
necessary confirmatory due diligence and validation of Servicer’s claimed Consumer Relief
credits as reflected in the IRG Assertion. As noted above in Section II.E, this Report pertains to
my findings regarding an IRG Assertion covering the California Agreement Testing Period.
7 Exhibit E, ¶ C.7.
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Also, as noted above, at Servicer’s request, this Report includes my determination regarding
Servicer’s satisfaction of its Consumer Relief Requirements under the California Agreement.
In order to better accomplish the processes outlined in Section III.A above, Servicer and I
agreed upon a Work Plan and Sampling Framework that, among other things, set out the testing
methods, procedures and methodologies that are to be used relative to confirmatory due diligence
and validation of Servicer’s claimed Consumer Relief under the California Agreement, including
Exhibit A to the California Agreement and Exhibits D and D-1 to the Judgment. As
contemplated in, and in furtherance of, the Work Plan and Sampling Framework, Servicer and I
also agreed upon Testing Definition Templates that outline the testing methods and process
flows to be utilized to assess whether, and the extent to which, the credits Servicer would be
claiming for its Consumer Relief activities were earned credits, that is, credits that could be
applied toward satisfaction of Servicer’s Consumer Relief Requirements under the California
Agreement. The testing methods and process flows are described in detail in Section III.B. of the
Interim National Consumer Relief Report, and as set out in that Section, they entail the
examination and testing by each of the IRG and the PPF of creditable activities, together with
calculations based on the results of those examinations. In addition, it includes both in-person
and web-based meetings by the PPF with the IRG and the PPF’s unfettered access to the IRG
and the IRG’s Work Papers during the PPF’s confirmatory due diligence and validation of
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C. Servicer’s Assertions
In Servicer’s Consumer Relief Report submitted to the IRG, Servicer claimed that, for the
California Agreement Testing Period, it was entitled to claim credit in the amount of
$4,083,440,614 pursuant to Exhibit A to the California Agreement and Exhibits D and D-1 to the
Judgment. Approximately 46% of the credit was a result of relief afforded to borrowers on loans
in Servicer’s mortgage loan portfolio that are held for investment; and the remainder was a result
of relief afforded to borrowers on loans that Servicer was servicing for other investors.
Approximately 30% of Servicer’s claimed credit was through First Lien Mortgage
Modifications. Short Sales and Deeds-in-Lieu made up approximately 53% of Servicer’s claimed
credit. Second Lien Portfolio Modifications made up 17% of Servicer’s claimed credit. In
addition, $366,397,185, or 30%, of the credit that Servicer claimed for First Lien Mortgage
Modifications was the result of the modification of 2,164 loans secured by residential properties
located in the Hardest Hit California Counties. A breakdown of the Consumer Relief credit,
Table 1
Type of Relief Loan Count Claimed Credit Amount
First Lien Mortgage Modifications 7,687 $1,221,178,458
Principal Forgiveness 325 $54,763,473
Forbearance Conversions 2,804 $294,078,464
Conditional Forgiveness 190 $21,439,233
180 DPD Modifications 1,142 $253,500,602
Government Modifications 3,226 $597,396,686
Second Lien Portfolio Modifications 7,299 $713,213,586
2.b Modifications 521 $28,985,130
2.c Modifications 32 $634,521
2.d Modifications 1,003 $71,704,795
2.e Modifications 5,743 $611,889,140
Short Sales/Deeds-in-Lieu 13,787 $2,149,048,570
Total Consumer Relief Programs 28,773 $4,083,440,614
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After submitting its IRG Assertion on October 14, 2013, the IRG reported to me the
i) the Consumer Relief asserted by Servicer for the California Agreement Testing
Period was based upon completed transactions that were correctly reported by Servicer;
ii) Servicer had correctly credited such Consumer Relief activities, so that the
iii) the claimed Consumer Relief correctly reflected the requirements, conditions and
limitations, as set forth in Exhibit A to the California Agreement and Exhibits D and D-1 to the
Judgment; and
iv) Servicer had fully satisfied its Consumer Relief Requirements as set forth in
According to the IRG’s report to me, its Satisfaction Review was based upon a detailed
review of Servicer’s relevant records and on statistical sampling to a 99% confidence level.8 The
report of the IRG with regard to its Satisfaction Review was accompanied by the IRG’s Work
Servicer’s Consumer Relief Report as to the amount of Consumer Relief credit earned first
involved the IRG creating three statistically valid samples from all mortgage loans receiving
8 Confidence level is a measure of the reliability of the outcome of a sample. A confidence level of 99% in
performing a test on a sample means there is a probability of at least 99% that the outcome from the testing of the
sample is representative of the outcome that would be obtained if the testing had been performed on the entire
population.
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Consumer Relief for which Servicer sought credit under the California Agreement. Each of these
samples contained loans from one of three separate and distinct categories, each of which was
treated as a testing population (“Testing Population”). These Testing Populations were: (i) First
conversions, conditional forgiveness, 180 DPD modifications and government modifications; (ii)
Second Lien Portfolio Modifications,10 including second lien standard principal reduction
modifications, 2.c modifications, second lien government modifications and second lien
principal extinguishments; and, (iii) Short Sales and Deeds-in-Lieu.11 The IRG selected the loans
that were included in these samples in two stages: First, the IRG selected from each Testing
Population all loans secured by California residential properties that had been tested by the IRG
as part of a satisfaction review conducted pursuant to the Judgment. Next, the IRG randomly
selected a number of additional loans from the remainder of the Testing Population sufficient to
ensure that the sample size was statistically valid. The additional loans for each of these Testing
Populations were selected utilizing an Excel-based Sample Size Calculator. In determining the
sample size, the IRG, in accordance with the Work Plan, utilized a 99% confidence level (one-
tailed), 2.5% estimated error rate and 2% margin of error approach. The total number of loans in
each Testing Population and the number of loans tested by the IRG, which number was equal to
the number the Servicer and I had contemplated when developing the Work Plan, are set forth in
Table 2, below:
9 Exhibit D, ¶ 1.
10 Exhibit D, ¶ 2.
11 Exhibit D, ¶ 4.
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Table 2
Number
Total of
Number of Loans Reported Loans Total Reported
in Credit Credit in IRG Credit Amount
Testing Population Population Amount Sample in IRG Sample
First Lien Mortgage
Modifications 7,687 $1,221,178,458 318 $48,817,355
Short Sales/Deeds-in-
Lieu 13,787 $2,149,048,570 324 $51,012,627
Reported Credit Amount, a breakdown of the number of loans that had been tested as part of
satisfaction reviews conducted pursuant to the Judgment and those additional loans tested only as
Table 3
Number of Reported Credit
California Reported Credit Number of Amount of
Loans IRG Amount of Loans Loans IRG Loans IRG
Tested IRG Tested Tested Pursuant Tested Pursuant
Pursuant to the Pursuant to the to the California to the California
Testing Population Judgment Judgment Agreement Only Agreement Only
First Lien Mortgage
Modifications 153 $24,033,489 165 $24,783,866
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2. Approach to Testing Loans. For each of the loans in the samples drawn
from the three Testing Populations, the IRG conducted an independent review to determine
whether the loan was eligible for credit and the amount of credit reported by Servicer was
calculated correctly. The IRG executed this review pursuant to and in accordance with the
Testing Definition Templates and related test plans for each of the three Testing Populations by
accessing from Servicer’s System of Record the various data inputs required to undertake the
eligibility determination and credit calculation for each loan. The IRG’s process for testing is set
After verifying the eligibility and recalculating credit for all loans in the sample for each
Testing Population, the IRG calculated the sum of the recalculated credits for the sample for each
Testing Population (“Actual Credit Amount”) and compared that amount against the amount of
credit claimed by Servicer for the sample of the respective Testing Population (“Reported Credit
Amount”). According to the Work Plan, if the Actual Credit Amount equals the Reported Credit
Amount or if the Reported Credit Amount is not more than 2.0% greater or less than the Actual
Credit Amount for any of the three Testing Populations, the Reported Credit Amount will be
deemed correct and Servicer’s Consumer Relief Report will be deemed to have passed the
Satisfaction Review and will be certified by the IRG to me. If, however, the IRG determined that
the Reported Credit Amount for any of the three Testing Populations exceeded the Actual Credit
Amount by more than 2.0%, the IRG would inform Servicer, which would then be required to
perform an analysis of the data of all loans in the Testing Population from which the sample had
been drawn, identify and correct any errors and provide an updated Consumer Relief Report to
the IRG. The IRG would then select a new sample and test the applicable Testing Population or
Testing Populations against the updated report in accordance with the process set forth above. If
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the IRG determined that the Actual Credit Amount was greater than the Reported Credit Amount
by more than 2.0% for a particular Testing Population, Servicer had the option of either (i) taking
credit for the amount it initially reported to the IRG or (ii) correcting any underreporting of
Consumer Relief credit and resubmitting the entire population of loans to the IRG for further
steps set forth above, the IRG determined that the difference between the Reported Credit
Amount and the Actual Credit Amount for each sample of the three Testing Populations was
within the 2.0% error threshold described above. These findings by Testing Population are
Table 4
IRG
Servicer Calculated Amount %
Loans Reported Credit Actual Credit Overstated/ Differen
Testing Population Sampled Amount Amount (Understated) ce
Short Sales/Deeds-in-
Lieu 324 $51,012,627 $51,174,218 ($161,591) (0.32%)
Based upon the results set forth above, the IRG certified that the amount of Consumer
Relief credit claimed by Servicer in each Testing Population was accurate and conformed to the
requirements in Exhibit A to the California Agreement and Exhibits D and D-1 to the Judgment.
This certification was evidenced in the IRG Assertion attached to this Report as Attachment 3,
Relief Report, preliminary to the PPF’s review of the IRG’s Consumer Relief testing, pursuant to
the Judgment, for the First Testing Period, I, along with the PPF and some of my other
banking operations, SOR and IRG program, and the IRG’s proposed approach for consumer
In addition, during the Second Testing Period, the PPF continued to interact with
the IRG and Servicer to gain additional information and evidence necessary to the PPF
The knowledge gained during the First Testing Period and Second Testing Period
carried forward into the testing conducted pursuant to the California Agreement and was
supplemented by the PPF, as necessary or appropriate, through continued interaction with the
testing conducted by the IRG relative to Consumer Relief crediting for the California Agreement.
This review of Consumer Relief crediting began in January 2014 and continued, with only
minimal interruption, until the filing of this Report. For each of the Testing Populations, the
principal focus of the reviews was the PPF’s testing of all loans that had not previously been
tested by the PPF as part of the testing that the PPF had done pursuant to the Judgment,
following the processes and procedures set out in the Testing Definition Templates and the
IRG’s test plans. These reviews were of the same type as those undertaken by the PPF pursuant
to the Judgment, and included access to information of the type substantially identical to that to
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which it was afforded, in performing its confirmatory work pursuant to the Judgment. With
regard to the loans that the PPF previously tested as part of its confirmatory work pursuant to the
Judgment, the PPF confirmed that each of the loans was secured by a property located in
California and, where applicable, that the property was in one of the Hardest Hit California
Counties; in all other regards, the PPF relied upon the results of its testing of these loans that it
its testing pursuant to the Judgment for the First Testing Period, although not required, the IRG
performed quarterly testing and, as a result, tested more loans than statistically required applying
the 99/2.5/2 sampling approach. Because of this, in its review of the IRG’s work for the First
Testing Period, the PPF tested only a sub-sample of the loans tested by the IRG and, therefore, as
part of its California testing, the PPF had tested the eligibility and calculated the earned credit of
loans that the IRG had tested as a part of the testing it conducted pursuant to the Judgment.
Table 5, below, sets forth, for each sample, by the number of loans and Total Reported Credit
Amount, a breakdown of the number of loans that had been tested as part of satisfaction reviews
conducted pursuant to the Judgment and those additional loans tested only as part of the
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Table 5
Reported Credit
Number of Reported Credit Number of Amount of
California Amount of Loans PPF Loans PPF
Loans PPF Loans PPF Tested Pursuant Tested Pursuant
Tested Pursuant Tested Pursuant to the California to the California
Testing Population to the Judgment to the Judgment Agreement Only Agreement Only
First Lien Mortgage
Modifications 153 $24,033,489 165 $24,783,866
Throughout its testing process, the PPF interacted extensively with the IRG to resolve issues that
arose during the testing process. Most of the issues that arose during the PPF’s testing pursuant
to the California Agreement related to the IRG’s need to provide additional or missing evidence
relating to certain loan eligibility requirements. In almost all cases, these issues were resolved
After completing the loan-level testing, the PPF determined that the IRG had correctly
validated the Consumer Relief credit amounts reported by Servicer in the three Testing
Populations. The results of the PPF’s loan-level testing are set forth in Table 6, below:
12In the Interim National Consumer Relief Report and Final National Consumer Relief Report, I discussed some of
the issues that arose during the PPF’s testing pursuant to the Judgment. See, Section III.G.3. of the Interim National
Consumer Relief Report; and Section III.F.3. of the Final National Consumer Relief Report.
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Table 6
PPF
Loans Servicer Calculated Amount
Reviewed Reported Actual Credit Overstated/ %
Type of Relief by PPF Credit Amount Amount (Understated) Difference
Short Sales/Deeds-in-
Lieu 324 $51,012,627 $51,153,195 ($140,568) (0.27%)
For each of the samples tested, the difference between the Reported Credit Amount and
the credit amount as calculated by the PPF was within the margin of error in the Work Plan.13 In
addition, other than the PPF’s finding that there were isolated instances of Servicer and the IRG
miscalculating the amount of credit earned in relation to certain short sales as well as first and
incentives on government modifications, the PPF’s credit calculations and the IRG’s credit
calculations are substantially the same. The PPF also noticed isolated instances of the Servicer
not claiming the additional credit earned for completing First Lien Modifications on or after
March 1, 2012 and implemented on or before February 28, 2013 plus additional credit related to
First Lien Modifications completed in relation to residential properties located in the Hardest Hit
California Counties.
The PPF documented its findings in its work papers and has reported them to me. I then
undertook an in-depth review of the IRG’s Work Papers with the PPF, as well as the PPF’s work
papers. Based upon the procedures described above and in the Interim National Consumer Relief
Report and the Final National Consumer Relief Report, from the Start Date through February 28,
2013, Servicer has correctly claimed credit in the amount of $4,083,440,614 pursuant to the
California Agreement.
Modifications and Short Sales and Deeds-in-Lieu. Exhibit A requires that at least 85% of credit
that Servicer earns as a result of First Lien Mortgage Modifications and 75% of the credit that
Servicer earns as a result of first lien Short Sales and Deeds-in-Lieu must be in relation to
mortgage loans that have an unpaid principal balance before capitalization at or below the
highest GSE conforming loan limit caps as of January 1, 2010.14 The PPF analyzed the entire
population of First Lien Mortgage Modifications for which Servicer has sought credit and
determined that $1,097,468,644, or 89.87%, of the credit was in relation to loans that had an
unpaid principal balance before capitalization at or below the highest GSE conforming loan limit
caps as of January 1, 2010. The PPF also analyzed the entire population of first lien Short Sales
and Deeds-in-Lieu for which the Servicer has sought credit. As a result of this analysis, the PPF
determined that Servicer earned $2,013,437,587 in credit through first lien Short Sales and
Deeds-in-Lieu, of which $1,732,094,264, or 86.03%, was in relation to loans that had an unpaid
principal balance before capitalization at or below the highest GSE conforming loan limit caps as
of January 1, 2010.
On the basis of the information submitted to me and the work as described in this
Report, I find that the amount of Consumer Relief set out in Servicer’s Consumer Relief Report
14Exhibit D, ¶ 1.b. GSE conforming loan limit caps as of January 1, 2010 are: 1 Unit - $729,750; 2 Units - $934,200;
3 Units - $1,129,250; and 4 Units - $1,403,400.
22
Case 1:12-cv-00361-RMC Document 154 Filed 05/06/14 Page 23 of 48
for the period extending from March 1, 2012, through February 28, 2013, is correct and accurate
Based upon my findings listed above and my findings in the Interim National Consumer
Relief Report and the Final National Consumer Relief Report, I conclude that Servicer has
substantially complied with the material terms of the California Agreement and has satisfied the
required thereunder.
Prior to the filing of this Report, I have conferred with the Attorney General and Servicer
about my findings, and I have provided each with a copy of my Report. Immediately after filing
this Report, I will provide a copy of this Report to the Board of Directors of J.P. Morgan Chase
I respectfully submit this Report to the United States District Court for the District of
MONITOR
23
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