Case 1:15-cv-00293-LTS-RWL Document 424-70 Filed 09/30/19 Page 1 of 5

EXHIBIT 70
 Case 1:15-cv-00293-LTS-RWL Document 424-70 Filed 09/30/19 Page 2 of 5
DOJ Extinguishment Program Proposal

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July, 2012
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 DOJ Extinguishment Program - Charge Off Portfolio context & overview
Program Charter: The purpose of this program, in accordance to the language specified by the
Department of Justice, is to provide relief to borrowers who are in hardship or maybe facing

Case 1:15-cv-00293-LTS-RWL Document 424-70 Filed 09/30/19 Page 3 of 5

one. In addition, it provides important new protections for our country's military men and
women and individuals who have suffered as a result of a natural disaster.

Program Objective, Recovery Portfolio: MB recovery has been tasked with identifying DOJ
credit amounts in the amount of $397MM. This assumes:
• 10% credit for every dollar forgiven.
• 25% additional credit (12. 5% total credit) for all dollars forgiven by end-of-year 2012.
• To accomplish this task, $3B in second lien balances need be identified for forgiveness.

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0 ■ Loans were primary selected based on aging collectability performance. Arguably, those with the
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on ■ Loans were rank ordered using a variety offactors that included aging, balance size and
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.> probability of payment.
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■ Each bin contains an estimated lifetime recoveries sum that was used to determine the impacts
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CCI ■ Each bin provides borrowers with a significant "mortgage relief" opportunity in addition to
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on providing the firm with a means to mitigate future losses on second liens behind Chase senior
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liens.
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Page 1

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 DOJ 2nd Lien Exit Strategy: Waterfall Criteria
Preferred Scenario:
Aged Portfolio Units Total UPB

Case 1:15-cv-00293-LTS-RWL Document 424-70 Filed 09/30/19 Page 4 of 5

<~~
FEMA/ Soldiers / Sailors / Includes all FEMA, SCRA and Probate accounts
Core Probate Returns 93 $ 5,653,705 more than 2 years since claim filed

Group 1st Lien AFP RCV/ 2nd Lien

RCV 780 $ 38,370,019
<~ Includes all charged off 2nd liens behind a
Chase first lien charge off (AFP) loan

Base
f---<
Stacks/ >=1 yrs C_O/
Balance > $50,000 4901 $ 506,522,752
<~ Includes all charged off 2nd liens >=1 year
since C/O behind an active Chase 1st lien

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Group
Active/ c_o <= Dec'09 I
Balance > $75,000 / Non High balance charge off accounts greater than
8685 $ 1,291,337,758
BK 3 years> $75,000
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Q) I ► BK Ch 7 Discharged /
Offif- c_o <= Dec'0S I Active 2815 $ 229,049,085 All bankruptcy accounts currently being
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Bankruptcy
Group
BK Ch 7 Discharged /
c_o betwn Jan-Dec'09/
Balance> $100,000 /
Active
2073 $ 351,963,169 <- serviced by an outside vendor
Includes two separate segments of discharged
chapter 7 charge-off's based on age and
balance

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Plug-in
Probate/ >=2 yrs
WWR
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361 $ 20,321,941 I
< Includes all active probate claims greater than
two years from C/O

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Group Non-Active Queue
11,329 $ 644,541,049 I
< Includes all loans in non-active queues that
continue to maintain an active 2nd lien
• Customer refusals to pay
• hWaMu non-converted loans
• Aged agency returns
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$ 2,900,000,000

~ Balance
$ 187,759,478

CHASE O Exclusions: 1. MLS Listed 2. C/0 in last 6 Months 3 .Accounts paying in last 1 year Page 2

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 Estimated Lifetime Recovery Dollars

Case 1:15-cv-00293-LTS-RWL Document 424-70 Filed 09/30/19 Page 5 of 5

Core Group 1st Lien AFP RCV/ 2nd Lien RCV 780 $38,370,019 0.71% $270,509

Base Group Active / C_O <= Dec'09 / Balance> $75,000 I Non BK 8,685 $1,291,337,758 0.19% $2,456,931

BIK Group Bl< Ch 7 Discharged I C_O betwn Jan-.Dec'09/ Balance> $100,000 / Active 2,073 $351,963,169 0.11% $380,948

Pllug in Group 'Non .Active· Queue 11,.329 $644,541,049 0.05% $322,.271

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==:::J • Low degree of confidence due to lack of historical data for this segment

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on Using data from historical performance of the above segments, it is estimated that the lifetime
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Page 3

Confidential Treatment Requested by JPMC JPMC-MRS-00024328