Poofness – 2-12-12 – Hope You’re Ready For This

Greetings and Salutations;

Remember the term, ‘indentured servant’? Just a little higher than a slave basically, a serf. You have faced the same issues, trying to pay off debt, while the house shuffles the deck in it’s favor. It’s really a fake freedom. As long as, one remains indebted to the ‘man’(plutocrats), limits to that freedom are inherent. Listen to the politicians this season and watch them massage words to alter your vision of what they are really saying. ‘Vote for me, I’ll set you free’. Now, the scary part is at your door, real freedom. After a series of tactical moves behind the curtain, the dark cabals have been subjugated. Light makes right, evil always loses. Whatever actions are taken that ultimately results in less freedom or power to the people, a counter measure automatically is birthed. The universe is about balance and that effects daily life.

There is no more ‘grey’ areas, step forward in confidence, your back is covered. No more negotiations with they who would pick your pockets. They are receiving ‘edicts’ and will suffer the consequences for breaking them. They won’t be able to tie up the courts with endless crap….BAR attorneys will not be allowed into the new courts of justice. The smart judges are already getting their ‘common law’ chops up to work in the new system, under a bonafide constitutional system. All we await is the ‘announcements’ to make it all public.

Time  to be adults, take what you want and help others not as fortunate as you. There’s nothing hard about this and you will be helped in your decision making process. No one is throwing you into deep water without life saving devices.  Hold this thought, everything around you is alive, act like you know. Respect life. Get in the flow of it and all will be easy going forward. Thank the St. Germain folks for holding a focus over 3 centuries, never backing off their mission despite the wars and alot of other things which took place, the vagaries of time.

Since the beginning of pulling all this together in america, the idea of prosperity programs for regular people have become somewhat of an urban legend. The cabal was intent on keeping it that way, too. They have used every measure at their disposal to divert, stop, or make folks crazy even thinking about the possibilities. 

Some have even went in an opposite direction and swear to god, it was all a scam in the first place. That way they did not have to think about it. ‘Ah, the grapes are sour anyway’. The world is bigger than your back yard or your politicians. You will see what I mean very shortly, as some of the ‘sacred cows’ are destroyed or sent to the dustbins of history. While these folks keep saying bernanke is printing, look into your pocket or wallet and see if you can find a recently printed fed res note. Things are not as the media or even the politicians state it. The proof is with you. I can find nothing newer than 2009, how about you?

The master said the ‘Kingdom of god is within you’, well try acting like you may be worth something rather than the piece of crap, preached in your ear. Maybe you need to rethink what that kingdom really is, sans someone else’s idea of what that means. We have a lot of the walking wounded out here, who don’t even know they have been mentally abused. Time has come to change the world. Ask questions of the person at the bank, they represent the 5 star trust. Instructions are very simple, 3rd grade level. If you can read and follow along, you’ll be fine. There are some details I’m not privy too, but the big picture was always very clear. That has not altered save time may have sped up a bit causing other things to be at your table faster.

Stay loose, world change is here, listen and observe. Don’t believe everything you hear, and only 50% of what you see. You will now start using the rest of your senses and brain. Call it a reset.
“Change your mind and your butt will follow.”

Must say, now you will have peace, Whitney Houston. That voice has now gone from the planet. Great lights seem to leave the planet early, she’s certainly has gone to rock and roll heaven.
With the assault on women rights going on in D.C. now, ladies listen to this song.
You All have personal decision to make.

Love and Kisses;
Poofness

White Hats Report #35 - January 27, 2012

Romney Camp Dung-Founded:  No Integrity, No Ethics, No Honor

This article is one of a series exposing theft, deceit, tax evasion, and bribery of public officials. It questions a Presidential candidate who would associate with such people, much less take money from them. This money is then hidden offshore to evade taxes in a conspiracy with ruthless criminals, all knowing the true Beneficial Owner of the funds was being cheated of his income at every turn. These actions bring consequences.  Knowledge is power.

We expose three key names of consequence today. Mitt Romney, Dr. Michael Herzog and Paul Guenette are now challenged to publicly explain why they ruthlessly cheated an American national causing loss of important projects, tax revenue and the denial of hope and dignity to many Katrina victims. These far flung results would have resulted from pre-approved projects which were to have been done if not for the deceit of the above mentioned three.  The Falcone Group was planning high value work, which was needlessly delayed with pain and suffering for many; real consequences occasioned for real people, so many innocent citizens affected by the ruthless conspiring greed of others.

Mitt Romney is a Presidential candidate bidding for the honor of holding the highest office in the land. And yet, behind the scenes, he associates and trades with two men whose criminal pasts merit public awareness and scrutiny. We will present a sectional exposure of each.  Mr. Edward Falcone was asked to allocate part of his Bank Trading Program profits to help Romney during his previous campaign. It was there that he and Herzog became connected.  This is how Romney repays his supporters.

Paul Guenette, a Canadian resident, has a small home in Ethelbert, Manitoba. He and Dr. Michael Herzog have a combined history of global arrests, charges and venomous fraudulent activities. A discrete inquiry to Canadian authorities led to helpful guidance that he is both under heavy surveillance by the Canadian Police and under an airport watch, indicating he may have already fled and may in fact be hiding out with Herzog in Germany or possibly in Spain. He and Herzog were closed down in Switzerland by security authorities with a Bank they jointly owned (ICB Bank). Guenette and Herzog were also arrested in Germany for attempting to pass fake credit Letters for cash via Commerzbank in Frankfurt, Germany. The German Police are monitoring Herzog closely and will no doubt increase activity on receipt of this. There are outstanding warrants on Herzog in Israel, and by respecting Canadian investigations and law, it is pertinent not to declare more or hinder clear and serious investigations involving Guenette. Herzog has made allegations that he and Ackermann were assured of safety as a result of bribes made to a named Senior Interpol Officer, details of which Mr. Falcone is willing to submit to investigating officers.

How much should we release that does not harm international enforcement agency diligence or pending actions is precisely the dilemma. Herzog and Guenette have a deep relationship with Romney and money transfers he received, some of which will be exampled meriting public challenge. The files held are extensive. This is a small overview of a vast library of investigative reports and accounts used.

Romney is declaring his personal wealth holdings, which simply do not equate to money he has received from Herzog and Guenette. Records exist showing in excess of 900 million dollars taken offshore. This raises questions as to the validity and truthfulness of his IRS declarations, or perhaps in Mitt Romney’s mind, tax is only for the “little people.“ Does he merit the highest office in the land?

A vast amount of detailed and highly incriminating evidence is in our hands and has been lodged with appropriate global authorities. In such, we have to ensure we do not compromise criminal investigations now proceeding. The case we raise releases facts never before published, facts you deserve to know and question.

During the third week of October 2006, Michael Herzog, working against a bank trading platform contract he had been allocated by senior US political parties, signed in conjunction with Edward Falcone, and for the benefit of Edward Falcone, drew down $500M from a further Falcone account for Trading by Herzog. That was over and above the account set up for the use of Josef Ackermann of Deutsche Bank, which primarily funded CIA accounts, exiting via banks such as Barclays London. This had been previously started with a first initial amount of $350M and rapidly leveraged by Ackermann and fast track traded up in value. A credit line was arranged by Josef Ackermann of Deutsche Bank with the Bank of Austria. That was traded well into July 2008 by Ackermann. Vast profits were earned.

On August 1, 2007, Ackermann and George Bush Sr., working in conjunction with Herzog, Romney and Greenspan, exchanged communications agreeing not to pay Falcone, and to trade it for yet another year. While Herzog had been ready to pay Mr. Falcone, he and Ackermann allege the communication to block payment came from Bush Sr. who wanted to continue trading it. Herzog continued receiving his own profit payments along with the other criminal participants. Also, substantial CIA profits were being accrued without Congressional awareness or oversight. The following year, another program was traded with Herzog and others fronting it, while substantial profits were continuously accrued. Hundreds of billions of dollars were earned through their continuing greed. All of this was hidden from the trusting true beneficiary who got nothing! A series of high value multi-billion dollar Bank CHIPs were created from profits both in Falcone’s name and for his beneficial interests.  However, those were also mass used, fraudulently signed off for trading via other parties, and Falcone was again ruthlessly and criminally circumvented. A criminal pack of political  thieves extorted his funds. On September 26, 2005, Deutsche Bank Chairman and CEO Josef Ackermann admitted to his Deutsche Bank coordinator, Juergen Schafer, that trading had been engaged by his commitment holder without informing Mr. Falcone. Records linking Paul Fauque, Nathan the Trader, and a series of beneficiaries are all on file as the investigation proceeds.

These profits accrued by Herzog were personally shared by George Bush Sr., George Bush Jr., Romney, Greenspan, Paulson, Herzog, Ackermann and Guenette in conjunction with other political associates and Bank Traders. Some associates earned between 2% and 4% of the profits which were side-lined into a labyrinth of offshore pseudo Trusts. The actual list of all beneficiaries is known, with accounts recorded and ready for Global recovery action. It has been lodged already with the FBI, Homeland Security, The US Federal Reserve, NSA, and also with the CIA – the largest beneficiary of profit allocations from Ackermann’s operation. This is America’s dilemma. With key appointments accepting political patronage, those compromised parties are too often carefully placed in key agency or government roles to maintain the status quo and to protect and block corruption inquiries.

Major Banks they used for these trades included Credit Lines leveraged up by the Bank of England, Bank of Austria and trading via Barclays, HSBC, CSFB (who used their Spanish division), RBS London, Deutsche Bank, ABN Germany, Commerzbank, Frankfurt Germany, and a network of exit banks used by Bush Sr., Romney, Herzog and Guenette, all who ordered profits to be moved into Caracas then on to the Caribbean and even into South Africa. Herzog exited profits via San Marino for onward distribution.  Large Profits were made and substantial taxes avoided, yet Mr. Falcone always expressed a commitment to pay his taxes due.  On receipt of the huge debt long overdue to him, he will declare his income, fully discharge his taxes and move to fund US infrastructure projects.

Herzog operated initially behind a series of fronts including Alliance Stars in Israel. He also defaulted on others, and hid behind his wife Gudrun Funkenweh whose accounts are now frozen. He used Oxi Mining and Trade LLC in the Isle of Man to hide profits, and also Frank Furstenberg behind a Berlin attorney trust.

This raises the issue of Mitt Romney, a man purporting to be Presidential material.  He and his fundraiser in Florida were pre-advised months ago that they might be culpable to repay all funds raised given this serious screening issue.  How can he become a Presidential nominee when the Falcone issue is not resolved? Will he and his fundraiser ethically return funds they have raised should he withdraw as this escalates?

Some 2 years ago the CIA, the Bushes and Falcone had negotiated a settlement deal.  Yet again, that was reneged on.  This is escalating into what could become a serious global embarrassment for the United States. The Falcone camp is focused and determined to get their money, whatever it takes. This is about justice. It’s about the projects, people and jobs needlessly lost.

There are other agendas also being seriously monitored. President Obama’s bank accounts are constantly watched by the retained Falcone investigators who note two amounts having been recently moved. Jeb Bush appears as a signatory on numerous offshore accounts, both singularly and linked with Bush Sr., for substantial amounts having no IRS history or true source of funds that are able to withstand forensic investigation.

The issue is Mitt Romney, he who would be President, and the company he keeps. Specifically, it is his sense of moral justice regarding his own tax integrity and regarding Ed Falcone.

Herzog has threatened to open his books on all deals done with Bush, exposing the entire history of their activity together if he is forced to pay back the Falcone funds.  Might Congress demand this? During Mr. Falcone’s visit to London, he met with key, influential people. The Lords discussed with him the independent facilities of the World Court in The Hague and its ability to force through his case to achieve a vast settlement avoiding the corrupt US Judiciary. He was offered introductions to senior government officials able to appraise his case and, if approved, to treat all the trading as a contested issue with conspiracy and fraud overtones. That could, if successful, allow worldwide recovery of the entire amount as proceeds of crime. A large number of the people trading his funds have now been identified, as have their Trusts and Foundations. Each will face tax investigations with stringent penalties.  Senior Ministers are now reviewing the Falcone case. Huge embarrassment and shame will follow with full media exposure for their crimes.  Moves are now developing to freeze their worldwide accounts as part of a UK Task Force Tax Recovery operation, irrespective of their political standing.

A good General never leaves his men behind.  In the same spirit of integrity and new stewardship at the Agency, a leader of such integrity would never leave his key Investor behind. It needs to be made RIGHT and NOW. This blemish has to be removed.  Integrity, Trust and Honor must be restored to the Office of The President to The United States of America.

We are at the conclusion of this report and we felt a recap in the form of questions for Mitt was appropriate.  In the 2008 General Elections, you were the #1 candidate to run with John McCain for the top spot in the United States.  You found out hours before that Sarah Palin was going to be the running mate on the Republican ticket due to your inability to pass McCain’s vetting process.  The reason was the money you stole with your associates Michael Herzog and Paul Guenette.  For your further education from non-White Hat sources, please consider the following information purportedly from the McCain Camp.

 The White Hats Report

WHITE HATS REPORT #29 September 25, 2011 -

Obama, Bush and the true, Sordid State of Our Cabal Controlled Union.

It has been a little bit of time since we last posted an article. Although we have volumes to report, we do not have the time to author stories of more scandals, it’s just more of the same and vastly larger than reported in the past. We promise we will. In reality, we have been working with world leaders, numerous security agencies and the legitimate or clean guys in the banking industry to bring the Global Settlement to a conclusion. We have certainly seen the results of the Dark Cabal's work for nearly fifty plus years, the depth of the tentacles’ of the Bush Clan in all aspects of the banking industry. What is more interesting is the picture that is developing around the secret organizations that support the new version of the World War II German Reich. Seems like some of the old guard are still hanging around in very clandestine, quiet places and are at the helm of the banking Cabal including the Bush’s.

This is an amazing world we are living in. Every American and every person in the free world should be stepping up to the plate and questioning every aspect of our representatives and their intentions. We support the total removal of incumbents from our leadership and a process for the thorough vetting of candidates on a state by state basis prior to their ability to hold office on a Federal basis. We no longer can have the extremely poor leadership that has been commonplace for these many past decades.

America is the shining star of freedom in the world and we can no longer afford to elect the types of people that will be intimidated by or want to only cooperate for profit with the secret under body of the world. We need people that will put their lives on the line to root out the individuals and groups that have divisive plans to control the world through manipulation of the political process, the financial markets and the main stream media. It is up to the American public, our clean world leaders and the people of the world to literally force the tough questions and push the bastards out of office. It is up to the common folks to wake up and spread the word to their neighbors to show what 308 million Americans can do. We can report all day long, but if YOU won’t act or even question then it is all for naught and you will continue to suffer for your lack of action. We hope that YOU are not waiting for us to do all of the work. We do the heavy lifting, however many hands (minds and voices) will complete the task and improve the world we live in.

During the last few weeks as Washington, D.C. was on vacation, The White Hats have been working diligently behind the scenes with intelligence sources to expose the dark cabal. We have been holding in reserve supporting evidence, which portray the depth of corruption and complicity of the Beltway Federal establishment, still controlled by George H.W. Bush Sr. Our Constitutional values are still being dismantled and replaced by the dictates of a criminal Cabal, a pretend president and his illegal administration. Homeland Security has failed to recognize that our greatest enemy is already within. This enemy is the greatest threat to the liberties and freedoms we love as Americans: a failing president controlled by a dark cabal conspiring to profiteer from their insatiable greed. The world knows what is unfolding as Israel has now sold 46% of its US Treasuries and Russia has sold 95% of its own US Treasury holdings.

The truth is widely known among the nations who are asking why these criminals have been allowed to perpetuate their criminal control unchecked. Bush Senior and Obama are blatantly compromising, not only America's economic recovery, but the World’s by continuing to extort and unlawfully use the Global Settlements and all of the funds they have stolen for years. They refuse to release funds which are not theirs while maximizing Bank Trading Program payments for their own offshore accounts. As recent as this week, a wire transfer of funds to Wells Fargo Bank for a true Patriotic Beneficiary was illegally stopped so they could continue their felonious activities.

Geithner was appointed to head up the US Treasury for one reason. He was appointed as the Gatekeeper to stop any independent ethical appointee from having oversight over the Federal Reserve Bank of New York, whose criminal Ponzi and racketeering activities have crippled America with debt obligations beyond anyone's imagination. Geithner fronts a cover up as a bought slave to his Master Bush. Geithner has taken combined payouts from the theft of the Falcone Bank Program funds set up by Bush Senior, which he is now seeking to hide behind discretionary Nominees fronting for him via The Royal Bank of Canada accounts in London, which we are tracking.

We know Geithner's illegal Banking as he desperately seeks to avoid our monitoring investigators.

We know about Bush Seniors, Biden’s, the Clinton’s, and Romney’s offshore accounts, which will be exposed and deny Romney the Presidency. We watch Obama's desperate attempts to hide his own accounts totaling in excess of 11 Billion Dollars. We know the full extent of the CIA Bank Program trafficking. These will be exposed and moves are in process by Falcone’s own attorneys to get all identified accounts frozen.

Both our Senate, Congress, Pentagon and all Agency leaders know fully that Obama is an illegal President, as do the Supreme Court Justices. Slowly International media is waking up and challenging the inadequacies and transgressions of Obama and his criminal Chicago support team. Visibly, the protective compliant media shell is now cracking as questions and challenges to Obama and the Bush criminal cabal are mounting. The wheels are coming off their Gravy Train.

The very role of FRB New York, Geithner's former home, is now being debated and challenged. This is their Achilles' Heel.

We outline again the clear and simple facts, which will be rigorously challenged as their empire disintegrates.


• Obama is not able to be a Lawful American President. He is a criminal Usurper.

• Obama knowingly and fraudulently tendered a FALSE Birth Certificate, that in itself is a criminal act. He is a Fraud! The whole world sees it, with exception of the US Regulators.


• Obama has been facilitated with Offshore Bank Program trading accounts and vast profits by Bush 41, using again the notorious Josef Ackermann, Chairman of Deutsche Bank. His accounts are being tracked and monitored ready to be frozen when he is eventually arraigned. Obama’s prime objective now is to maximise his illegal accounts for when he is removed from office. He wants to cut and run as a wealthy man with his fat proceeds of crime in office. It will end in tears once removed from his Chicago and Texan support umbilicals.


• Obama has knowingly and fraudulently used the ID number of a dead 19 year old Connecticut boy. Congress knows this as do all Senators. Failure to act on such a deeply humiliating criminal transgression is a Congressional disgrace raising again the integrity of this now neutered House. This raises the question of Representatives for whom because they no longer represent the American people or protect our Constitution or values.

• Obama fraudulently obtained a US passport with bogus papers. Why has no one checked this? How can Homeland Security allow a Bogus illegal to penetrate so far?

• Under what legal accord is Obama even married to a US citizen with false papers?

• Why has Obama failed to act with clear evidence that Biden, his own Vice President has taken bribes of $200M from Clinton acting for Bush Sr. It IS a Criminal offense to bribe a Public Official! It IS a Criminal offense for Biden to take the bribe and for Bush to bribe him. All of this is on record as the Edward Falcone issue proceeds now towards litigation, which has now passed the disclosure demand stages.


• Geithner will be exposed by future White Hats articles waiting release for vast frauds abusing Americas allies for many $Trillions; Hegemony of the worst kind. We will soon expose the depth of the US Treasury / FRB NY Bait and Switch scams with damning evidence and bank records.


• Can David Petraeus, with his Political aspirations, afford to become tarnished at the Agency with the visible corruption he has inherited and theft of the Falcone funds? Obama promised him he would get this fiasco settled to avoid public exposure.


• Who allowed Bush to use US Government planes to fly CIA Agents around the world falsifying bank records and moving Biden’s bribery money in desperation to shelter the audit trail? How can David Dewhurst, ex CIA agent, now Lt Governor of Texas, who set up and helped defraud Falcone, expect to clear vetting for his Senate ambitions? Litigation is now imminent. This is a delicate appointment Rick Perry as Governor needs to review and distance him away from as a key Presidential contender himself.

• Donald Rumsfeld has now been stripped of immunity in the case involving torture of 2 FBI Informants in Iraq in 2006, Donald Vance and Nathan Ertel. The case is now proceeding. It will open up the systematic inhuman mass brutality and torture of prisoners in Abu Ghraib, which Rumsfeld authorised as part of the Bush murderous campaign of mass brutality now unfolding. This long overdue and merited removal of Rumsfeld's immunity sends a clear signal that crimes against humanity and American citizens will not be tolerated, no matter who the perpetrators were. Those who invoked such vile repressions will be identified and held accountable. The Rapes and Sodomy in Abu Ghraib, in many cases against teenage children, will all be exposed, and those responsible held accountable.

• Bush, Jr. dares not even travel to Canada now for fear of War Crimes arrest, nor Switzerland, where committed groups also wait to have warrants issued and detain him for a Hague tribunal. History will judge them in ignominy. Bush, Cheney, Rumsfeld and Rice are culpable of destroying the US economy, America’s global image and our face.


• As we indicated above and reported previously, Obama has been attempting to hide his stolen funds in several different areas of the world. He knows we are watching. In fact, shortly after The White Hats reported that Obama personally was working some of his stolen funds directly with Josef Ackerman of Deutsch Bank, he reacted by immediately pulling his funds out of the trading program . Please do not be fooled. Obama knows his time is limited and his only focus is to increase these stolen funds with hopes of doubling the 11 Billion before he has to leave office. His own party has become split and Obama's Chicago backers are now pulling away realizing that Obama's time is short. Fortunately, the world leaders have become awakened to the truth about Obama and he will have little chance of actually spending these ill gotten gains.

BUSTED | Bank of America, JPMorgan Chase, Wells Fargo, Citigroup and Ally Financial Federal Audits Accuse Firms Of Defrauding Taxpayers

Confidential Federal Audits Accuse Five Biggest Mortgage Firms Of Defrauding Taxpayers

WASHINGTON — A set of confidential federal audits accuse the nation’s five largest mortgage companies of defrauding taxpayers in their handling of foreclosures on homes purchased with government-backed loans, four officials briefed on the findings told The Huffington Post.

The five separate investigations were conducted by the Department of Housing and Urban Development’s inspector general and examined Bank of America, JPMorgan Chase, Wells Fargo, Citigroup and Ally Financial, the sources said.

The audits accuse the five major lenders of violating the False Claims Act, a Civil War-era law crafted as a weapon against firms that swindle the government. The audits were completed between February and March, the sources said. The internal watchdog office at HUD referred its findings to the Department of Justice, which must now decide whether to file charges.

The federal audits mark the latest fallout from the national foreclosure crisis that followed the end of a long-running housing bubble. Amid reports last year that many large lenders improperly accelerated foreclosure proceedings by failing to amass required paperwork, the federal agencies launched their own probes.

The resulting reports read like veritable indictments of major lenders, the sources said. State officials are now wielding the documents as leverage in their ongoing talks with mortgage companies aimed at forcing the firms to agree to pay fines to resolve allegations of routine violations in their handling of foreclosures.

Full story here:

http://www.huffingtonpost.com/2011/05/16/foreclosure-fraud-audit-false-claims-act_n_862686.html

16 Banks to Reimburse Foreclosed Homeowners

Comptroller of the Currency

Administrator of National Banks

US Department of the Treasury                                                                        

FOR IMMEDIATE RELEASE
April 13, 2011

Contact: Robert Garsson
(202) 874-5770

OCC Takes Enforcement Action Against Eight Servicers for Unsafe and Unsound
Foreclosure Practices

WASHINGTON — The Office of the Comptroller of the Currency today announced formal enforcement ac

tions against eight national bank mortgage servicers and two third-party servicer providers Afor unsafe and unsound practices related to residential mortgage loan servicing and foreclosure processing.

The eight servicers are Bank of America, Citibank, HSBC, JPMorgan Chase, MetLife Bank, PNC, U.S. Bank, and Wells Fargo. The two service providers are Lender Processing Services (LPS) and its subsidiaries DocX, LLC, and LPD Default Solutions, Inc.; and MERSCORP and its wholly owned subsidiary, Mortgage Electronic Registration Systems, Inc. (MERS).

"These comprehensive enforcement actions, coordinated among the federal banking regulators, require major reforms in mortgage servicing operations," said acting Comptroller of the Currency John Walsh. "These reforms will not only fix the problems we found in foreclosure processing, but will also correct failures in governance and the loan modification process and address financial harm to borrowers. Our enforcement actions are intended to fix what is broken, identify and compensate borrowers who suffered financial harm, and ensure a fair and orderly mortgage servicing process going forward."

The enforcement actions require the servicers to promptly correct deficiencies in residential mortgage loan servicing and foreclosure practices that examiners identified in reviews conducted during the fourth quarter of 2010. The actions require the servicers to make significant improvements in practices for residential mortgage loan servicing and foreclosure processing, including communications with borrowers and dual-tracking, which occurs when servicers continue to pursue foreclosure during the loan modification process. The enforcement actions require the servicers to ensure that foreclosures are not pursued once a mortgage has been approved for modification and to establish a single point of contact for borrowers throughout the loan modification and foreclosure processes. In addition, the actions require servicers to establish robust oversight and controls pertaining to their third-party vendors, including outside legal counsel, that provide default management or foreclosure services.

The OCC's actions also require each servicer to engage an independent firm to conduct a multi-faceted review of foreclosure actions between January 1, 2009, and December 31, 2010. This requirement includes a comprehensive "look back" to assess whether foreclosures complied with federal and state laws, whether foreclosures occurred when grounds for foreclosure were not present, such as when loans were performing, and whether any errors, misrepresentations or other deficiencies resulted in financial injury to borrowers. The actions also require each servicer to establish a process for borrowers who believe they have been financially harmed by such deficiencies to make submissions to be considered for remediation. Each servicer must also submit a plan to remediate all financial injury to borrowers caused by any errors, misrepresentations, or other deficiencies identified in the independent consultant's findings.

The OCC based its enforcement actions on the findings of examinations conducted as part of the interagency horizontal reviews undertaken by the federal banking regulators in the fourth quarter of 2010. Examinations of these eight national bank servicers identified significant weaknesses in mortgage servicing and foreclosure governance that resulted in unsafe and unsound practices. The scope and degree of these practices differed among the servicers; however, based on the sample of files reviewed by OCC examiners, borrowers in the sample were seriously delinquent at the time of foreclosures and servicers held the notes and documents required to foreclose. A summary of the findings of the interagency reviews is available in the Interagency Review of Foreclosure Policies and Practices, which was produced by the OCC, the Board of Governors of the Federal Reserve System, and the Office of Thrift Supervision.

The enforcement actions do not preclude determinations regarding assessment of civil money penalties, which the OCC is holding in abeyance.