I have spent the better part of two decades honing to a razor’s edge a very unique set of skills. Before I came to cover the Mortgage Field Services Industry, I helped change other issues in Europe. Before that, I was actively involved in both the WTO Protests in Seattle in 1999 and later in Occupy Wall Street. One thing which I learned was that criminal network systems; organizational hierarchy, is generally the same no matter what the subject matter or personnel involved. Never, though, have I encountered the level of deceit; the pure and unadulterated criminality, as I have within the Mortgage Field Services Industry. Additionally, never have I met as many people infected with cowardice as I have while covering the stories I have over the past four years or so. Before this war is over; before #OpNAMFS has come to a conclusion, I will ensure that all guilty parties are publicly recognized for their actions in the same manner as Don McPherson has been over on ZoomInfo. McPherson is cited as being a Member of the Board of Governors of the National Association of Mortgage Field Services (NAMFS). I hope that they can hear me now!
Last week, Foreclosurepedia was contacted by a high level Wells Fargo official. Wells Fargo reached out based upon my inquiry about the legality of Wells Fargo demanding only Aspen Grove Solutions be used for Background Checks and that Wells Fargo Prime Vendors were demanding the same. It additionally dealt with the veracity of Press Releases which Aspen Grove Solutions, Pruvan and the National Association of Mortgage Field Services (NAMFS) have made stating that Background Checks in the Mortgage Field Services Industry are mandated by legislation and are currently implemented by the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC).
To state that Counsel for Wells Fargo disagreed is to put it mildly. Foreclosurepedia and Wells Fargo, though, agreed that out of a preponderance of caution, it would be both unwise and premature to openly quote the conversation; the party involved by name; and that there would be further discussions forthcoming in the very near future.
It is well and good that Wells Fargo appears to be taking these Sherman Act violation allegations seriously. CFPB recommended blanket Complaints by all parties aggrieved. That is somewhere in the neighborhood of 100,000 if you take Sterling Backcheck’s figures at face value. Foreclosurepedia is not optimistic that future discussions will not be circular in nature; that a priori, there will not be a perception by Wells Fargo that they are pater familias. Second, as the discussions transpired with one bound to a Canon of Ethics, Foreclosurepedia believes that quid quo pro lasts only long enough to clean up Sean C Ryan and retract the Press Releases. To intimate that this type of shuttle diplomacy, vis-a-vis my Publication as the communications conduit, is reminiscent of the Cold War is to put it mildly.
What is even more concerning is that I just got off the phone with Sterling Backcheck’s PR Representative, Mickey Mandelbaum, earlier today. While Mandelbaum is listed as the contact person at Sterling with respect to the Mortgage Field Services sector, he and I bullshit not, did not even know what Mortgage Field Services were. I had called to find out whether or not Sterling was actively processing any Members of Labor for Wells Fargo services. Mandelbaum’s answer was that I need to talk to another lady, but he wasn’t allowed to give me her contact information.
Paul Palmer of Pruvan and Ed Buckley of Aspen Grove Solutions issued a Joint Press Release stating CFPB implemented regulations requiring Background Checks in the Mortgage Field Services Industry. This is false. Aspen Grove Solutions bumped it up a notch by stating that the Background Checks are required to be:
… [in] compliance with the various regulatory guidelines, including those established by the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB).
What neither party wants; what Management and its Portfolio Holders cannot afford in the midst of an Election Cycle, is a lightning rod wherein regulators have the ability to descend with a veritable army of actuaries on fishing expeditions. That will happen; Altisource will attest to the fact that the Civil Investigative Directives (CID) are both costly and burdensome. Go no further than Foreclosurepedia’s article on Altisource having a NINETY ONE PERCENT DROP in Q1FY2015.
And before I forget, Hummel will go. Joe Hummel, employed by Integrated Solutions; Joe Hummel whom has been convicted of heinous financial crimes which were eventually reduced from felonies to a slap on the wrist; Hummel whom bilked his former partner for tens of thousands of dollars to pay the restitution and never repaid it, will go. Joe Hummel will be removed from participating in the Mortgage Field Services Industry — period. Eric Miller will follow.
Mortgage Contracting Services (MCS) led the charge on pushing Aspen Grove Solutions upon the tens of thousands of unsuspecting and innocent men and women of Labor — at around seventy bucks a pop yearly. Whether or not Wells Fargo realized this, which their Senior Vice President denies, is rather immaterial as required auditing would have revealed the scheme. With MCS controlling the bulk of Wells Fargo Work Orders, the former Lender Processing Services (LPS), now known as ServiceLink, spearheaded the vast majority of the remaining assets in what we call a mop up operation. Confused? Here, let me break it down for you,
The concept of If You Build It They Will Come is complete and utter bullshit. The Second Coming of Christ, if you so have the luxury to believe in religion which I do not as I am an Agnostic, is an event which will require a studio audience and foley artists to pump in the appearance of crowds lauding in joy. Benny Hinn and Oral Roberts used to do it quite well. Why? Well, you see in this Industry no one obeys the legal requirements of compliance with the Service Contract Act (SCA), Davis – Bacon, or the Fair Labor Standards Act (FLSA) all of which are currently being litigated against Industry firms in New York.
Without SCA, Davis – Bacon and FLSA enforcement, that means no one gets to ever have time off. Period. Oh, you died? We are going to attach your Estate and lien it for the back billing of that which you owe!
No Member of Labor would have voluntarily contributed to the multi million dollar corporate welfare scheme of an Irish Foreign National Firm for Background Checks at prices nearly SIXTY TIMES THOSE OF EQUALLY SITUATED FIRMS! Did I forget to mention that Aspen Grove Solutions has begun to reward the NAMFS Board of Directors for their assistance with 6 figure incomes? Yeah, we’ll get to that later and whom has been employed recently.
Coming back full circle, the fact of the matter is that the Prime Vendors of Wells Fargo, operating in concert, using electronic means, crossing state lines have perpetrated the largest and most epic fraud in the history of the Mortgage Field Services Industry. Ironically, the only National Order Mill whom refused to be a part of this scheme is Safeguard Properties (SGP). My hat is off to Robert Klein for telling the Micks to suck his dick earlier this year at the NAMFS Leadership Summit in Texas.
Jim Taylor is Senior Vice President of Property Preservation for Home Lending Servicing at Wells Fargo Home Mortgage. Taylor earned his Master of Science in Management from the Krannert Graduate School of Management at Purdue University concurrently with Master of Business Administration from Ecole Superieure de Commerce de Rouen, and a Bachelor of Science from the University of Washington. Taylor is also an alumni of the Seven Dwarfs of the Banking Sector, Bank of America where he worked for ReconTrust Company. Taylor cut his teeth as Head of Real Estate Investment Banking at Wachovia Corporation.
Taylor was the point man for Wells Fargo’s soiree into the seedy, netherworld of racketeering in the Mortgage Field Services Industry. I mean it wasn’t like Wells Fargo wasn’t familiar with Dark Pools and shit, but those were extremely complex mathematical algorithms with shadowy programmers named Yuri and Vlad whom were paid in BitCoin. Whether Taylor was acting at the behest of Wells Fargo with respect to the monopolization of background checks; whether Wells Fargo knew that fear mongering was used to terrify Labor to bow down and take it in the ass; or whether Taylor went rogue, is up for debate. What is not up for debate is that beginning in late 2012, Miller and Alfredo concocted their plot to create an Industrywide Background Check Program; that the Program would be placed under one roof and that NAMFS and NAMFS alone would control the process.
So, while Taylor, Alfredo, Miller and Sean C Ryan began cranking up the infrastructure — that’s a dirty little secret Sean C Ryan doesn’t want out that he lied to HousingWire stating Aspen Grove Solutions had been around since 1997 — of website building, they knew time was short to ram enough fear and propaganda down Labor’s throats to agree to getting fucked in the ass, yet again.
By spring of 2013 the groundwork had been laid to heard the innocent men and women of Labor through a cattle shoot much like Nazi Germany did with the Jews in WWII. It was ingenious. The first part of the plan was to clean up Aspen Grove INC in the same manner which Monsanto Chemical cleaned itself up after the filings of Agent Orange began during the Vietnam conflict. What I mean by this is that Aspen Grove INC had far too many skeletons to safely parade out in the open, so they reincarnated Aspen Grove INC as Aspen Grove Solutions.
Enter Ann Thompson. Ann Thompson is a Senior Analyst in the Office of Supervision Policy at CFPB. Thompson was just getting her office arranged when the Rat Pack came a calling. Thompson was already a media acolyte in that she was spearheading the compliance portion and had a good handle on what audits were all about. So, it seemed logical that surely Thompson would agree that Background Checks were needed all the way around. Surely, a universal, one-stop-shop would make perfect sense, right?!
You can’t hate the mental giants; the MMF Trio, of the Rat Pack — Miller, Alfredo and Taylor — for being ignorant. Hell, the definition of the Office of Supervision Policy sounds pretty important and after all, aren’t all Washington Bureaucrats always wanting a handout?! Here is how Thompson described OSP in a Google Job Opening back in early 2013,
The Office of Supervision Policy (OSP) is organized by product or service market, and each product or service team is responsible for policy relating to supervision of both banks and nonbanks. The product teams are responsible for ensuring exams in banks and nonbanks are addressing key policy priorities and resolving issues consistently and effectively. OSP is also responsible for Supervision’s rulemaking and for connecting Supervision’s findings to the policy work of the rest of the Bureau, and vice versa.
Background Checks have been ongoing in this Industry since the 1960s and the reality is that the US Government provides them FOR FREE if you apply for a Dun & Bradstreet Number for your System for Award Management (SAM). SAM, which grants access to the Federal Business Opportunities (FBO) — that is the same FBO that the US Department of Housing and Urban Development (HUD) solicits and awards bids through, ensures you are a BUSINESS; your Social Security Number is real, Date of Birth, Criminal Record — everything. AND IT IS FREE! The DUNS Number is the same fucking thing AND FAR MORE POWERFUL AND TRANSPARENT than the Aspen Grove Solutions’ ABC#.
Miller and Alfredo broke off from Taylor to begin to set the stage for a product that was never needed to begin with. They knew time was short and all dissension would have to be quashed immediately. Launching a full scale assault they commissioned a NAMFS Background Check Committee and gave them absolutely nothing to do. Fact of the matter is that after only meeting in person once, which was the day Taylor instructed them to vote Aspen Grove Solutions in as the Awardee, they were lambs led to the slaughter. As the Chairman of the Committee and others would later reflect, there really wasn’t any need for the Committee to begin with.
Public Relations was never really a strong suit for NAMFS. And PR was something that NAMFS and Aspen Grove Solutions needed because without the impression that CFPB had created regulations necessitating the largest money grab from Labor in the history of the Industry, everything would fall apart. In fact, NAMFS had never been questioned at all before Foreclosurepedia arrived. The Rat Pack gave it the good ‘ol NAMFS two step shuffle, though. While spinning up the Rubber Stamp Committee, the Rat Pack tried their best to catch Thompson slipping; all the Rat Pack needed was one slip to link CFPB to the new and improved Background Check program. In fact, throughout the Spring of 2013 and culminating in the Fall at the National Property Preservation Conference (NPPC) held in Chicago they hammered their message hoping Thompson would bite. She never did. The NPPC was hosted by Safeguard Properties (SGP) on 08 NOV 13. The NAMFS Background Check Committee had already rubber stamped the Aspen Grove Solutions scheme and had been disbanded. NPPC was the final chance that the Rat Pack would have to flip Thompson. As in most things that Eric Miller does, it was an abysmal failure. They hammered and hammered away from multiple angles to no avail.
Problem was that CFPB wanted no part of being anti Labor. In fact, Thompson had been goaded multiple times to state CFPB regulated the Mortgage Field Services Industry. She knew she could not. CFPB stated as much to me with respect to the lies about regulations existing and encouraged Complaints to be filed by the nearly 100,000 Members of Labor impacted. More on point, though, Wells Fargo stated the same. Wells Fargo went even further, though, as we will discuss later in this Series.
What we know for certain is that Aspen Grove Solutions (AGS) existed nowhere on the face of the earth before January, 2013. AGS was spun up in Maryland on 15 JAN 13 at 1507EDT according to the State of Maryland’s Department of Assessments and Taxation. AGS was born in Ireland on 13 FEB 13 according to Oifig um Chlárú Cuideachtaí — The Companies Registration Office in Dublin. We know for certain that at that same period of time NAMFS Executive Director Eric Miller along with then NAMFS President Deanna Alfredo were involved in back room discussions with Americans and Irishmen alike. We know that NAMFS exercised nearly complete command and control over the entire process. Today, NAMFS is the ONLY Gatekeeper with specificity to whom may or may not conduct Background Checks in the Industry vis-a-vis their rubber stamping of the protocols.
Thompson was the ultimate undoing of the scheme. Without Thompson behind the NAMFS Initiative; without somewhere to hang their criminal hats and be able to state that a CFPB Official had discussed regulations demanding such, they all knew it would not bode well. Fact of the matter was that Thompson was simply a strumpet on a lonely string — Thompson was a career bureaucrat and had no intentions of committing Beltway Suicide. So, what did Eric Miller do? He did what any good criminal does, he doubled down — again.
The reality is that there is no law, rule or regulation which governs a mandatory background check for Labor in the Industry. I should know as I have read all 2319 pages of Dodd Frank.
In pertinent part, 12 CFR Part 1026 (Regulation Z) Subpart E §1026.36(f) et seq. but @ §1026.36(f)(3)(i)(A) and perhaps §1026.36(f)(3)(i)(B) through §1026.36(f)(3)(ii)(B) are the only areas wherein Background Checks (and Credit Checks which National Field Network has demanded and then submitted to Equifax with the Contractor listed as an Employee) are even discussed.
Miller, Alfredo and Taylor had determined there would only be ONE OPTION for a Background Check Provider which, in and of itself, violated the Sherman Act pertaining to monopolization. By controlling the process the NAMFS Board of Directors could ensure the placement of strategic personnel within Aspen Grove Solutions both as a Good ‘ol Boy Network; the wink and a nod effect, and additionally to ensure complete command and control over confidential information with respect to Labor — this reenactment comes to mind!
Tomorrow, we begin to discuss the Propaganda Campaign which was synchronised across all NAMFS Board of Directors whom represented their oligarch employers.