Case 1:15-cv-00293-LTS-RWL Document 427-16 Filed 09/30/19 Page 1 of 3

EXHIBIT 16
 Case 1:15-cv-00293-LTS-RWL Document 427-16 Filed 09/30/19 Page 2 of 3

CHASEO

CERTIFICATION OF LIEN RELEASE

Relating to Recovery One Charged-Off Loans
under the ational Mortgage Settlement ( MS)

L Patrick M. Boyle, being an authorized agent for JPMorgan Chase, N.A. (JPMC), certify that
the following statements are true and correct to the best of my knowledge:

I. J am a Vice President and a Collections Manager in Mortgage Banking at JPMC and have
primary responsibility for the line of busines that band I , among other things, the
management of charged-off loans, which are housed on JPMC ' s Recovery One Platform .

2. Effective April 1, 2014, the NMS Monitor required JPMC to begin testing all 33 MS
metrics with respect to the loans residing on the Recovery One Platform.

3. As of April 1, 2014, JPMC incorporated its open-ended HELOC on the Recovery One
Platform into the MS metrics testing, with the following exclu ions:

a. ln relation to Metrics 1, 3, 5, 6. 7, 16, 26. and 27, .TPMC does not initiate or refer
to foreclosure loans that are on it Recovery On Platform.

b. 1n relation to Metrics 14 and 32, the metrics' scope only appJie to first lien loans.

c. InrelationtoMetrics2, 13, 19,20,21.24 30 and31.JPMCdoesnotconduct

loan modification for loans that are on it Recovery One Platform.

d. In relation to Metrics 8, 9, and 11 , JPMC does not assess either default-related

fees or late fees post-charge off for loans that are on its Recovery One Platform.

e. In relation to Metrics 28 and 29, JPMC does not place wind or hazard in urance
for loans that arc on its Recovery One Platform.

f. In relation to Metric 33, for loans that are on it Recovery One Platform, JPMC
provides a letter to the borrower shortly after the loan is charged-off and boarded
to the Recovery One Platform that pecifies the full balan.ce that is owed.

4. For the remaining Reco ery One loans, JPMC initiated a proje t ("Lien Release Project")
to (i) resolve questions relating to JPM 's current ownership interest in the lien and its
right to service the loan. and (ii) where appropriate, to release the secw·ity interest for
first and second lien closed-end, charged-off loans that had not been brought into testing.
JPMC invested considerable resources. including the u e of CoreLogic, a vendor
commonly used in the industry, to a sist with it lien validation efforts.

5. As of October 31 , 20 l 4, the closed-end, charged-off first and second lien loans on the
Recovery One Platfonn have been resolved through the Lien Release Project, with the
limited exception of the following loans:

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CON Fl DENTIAL

CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00368707

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a. Pending Service Transfer - 360 loans that the investor has directed Chase
explicitly not to release and transfer the servicing to NationStar. These loans
have been coded for service transfer placed in a gmented queue, and no
servicing activity that is tested by the metric is ongoing on these loans.

b. Litigation - 3 loans that are in acti litigation where JPMC-s coun el ha not
approved the release of the lien because of disruption to the resolution of the case;
13 loans in active litigation where cotmscl approved the loans to be sent through
the Lien Release Project for resolution.

c. 2MP Lien Match - 3 loans that will be lien releas d either as a 2MP match
should the customer not opt-out of the pending 2MP offer. or as a re ult of the
Lien Release Project, at the expiration of the 2MP offer.

d. Short Sale - 41 loans where there is an accepted shm1 sale purchase agreement,
where releasing the lien would potentially disrupt the dosure of the short sale,
cause the customer to not receive financial incentives, and/or suffer tax
consequences as a result of the release. Of these 41 loans. should a short sale
contract be rescinded or the sale not proceed to closing, the loan will be released
via the Lien Release Project.

6. This certification is based, in part, on my review of relevant .JPMC business records,

including (a) reports on the relevant nwnber of first lien and second lien loans in
Recovery One, the system of record housing charged-off loan : (b) updated reports over
time showing the lien release status of those loans; (c) information and/or documentation
about activities that JPMC performs or doe not perform on loans held on its Recovery
One Platform; and (d) other relevant information and/or documentation.

Dated: October 31, 2014

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CON Fl DENTIAL

CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00368708