The Consumer Financial Protection Bureau (CFPB) recently announced that they were going to give Consumers the opportunity to share their narratives publicly — read Complaints. As we all know, this is a double edged sword. Now, don’t get me wrong: There are appropriate times to come completely unglued in a public forum. The Consumers were thoroughly and completely fucked in the Sub Prime Crisis when everyone except they received a bailout! There are also folks whom have absolutely no business bitching as they should have never received a loan — and insert here virtually any issue pertaining to CFPB Oversight which is increasing by the hour!
The Mortgage Field Services Industry, though, is in quite the quandary. Here’s the deal: On the one hand, the National Association of Mortgage Field Services (NAMFS) has ponied the lie that Background Checks are required under Dodd – Frank. The reality is that Servicers are required to have them AND THEN THE BANKS MUST PAY FOR THEM! More on point, though, it seems each and every time that NAMFS wants to further an Agenda, they rely upon Dodd – Frank as the Holy Grail. In the instant case, though, they now have opened the door for legitimate CFPB Complaints. And the Complaints are growing. So rapidly are they growing that Foreclosurepedia set up a separate entity to assist in their drafting on behalf of Members of Labor. So feared are the CFPB Investigations that on more than one occasion, both NAMFS Members and High C Level personnel have reached out to Foreclosurepedia to quietly resolve them.
“Consumer narratives shed light on the full consumer perspective behind a complaint,” CFPB Director Richard Cordray said. “Narratives humanize the problems consumers face in the marketplace. Today’s policy will serve to empower consumers by helping them make informed decisions and helping track trends in the consumer financial market.”
While Eric Miller, the Executive Director of NAMFS may believe that stonewalling Ethics Investigations against NAMFS Members is wise, Foreclosurepedia opines that the transparent and cleansing effects of full disclosure are more appropriate. Miller’s potentially willful obstruction of Foreclosurepedia’s access to the NAMFS Income Tax Reports — Internal Revenue Service Form 990 — which triggered the filing of an IRS 13909 Complaint and Investigation, are indicative of the obfuscation ongoing within the Industry at both historic and monumental levels.
The proliferation of fraud by NAMFS Members upon both NAMFS Members and Non NAMFS Members is likened to a Bacchian Orgy in Roman Times. Modern day mafioso blush when they hear about the outright criminality which climbed all the way to the NAMFS Board of Directors in the case of Heather Berghorst, the now disgraced and former NAMFS Secretary. More shockingly, Miller and Adriana Farelo-Fernandez, NAMFS Vice President, have both refused to dismiss Berghorst and countless others from NAMFS let alone allow for Ethics Hearings to be conducted. Miller has threatened and intimidated NAMFS Members pertaining to their discussions with Foreclosurepedia engendering a climate of fear and intimidation calculated to have a chilling effect upon free speech as I see it.
What Miller and Farelo-Fernandez will be unable to do is threaten and intimidate CFPB. The reality is that the days of NAMFS are numbered. Coming on the heels of tens of thousands of dollars in losses — hundreds of thousands of dollars if you include Miller’s nearly ten thousand dollar a year pay raise — the reality is that the NAMFS IRS Form 990 for FY2014 will show nearly four years in constant losses. And Miller’s reward? Another pay raise by the NAMFS Board of Directors. In the real world, Miller would be fired and NAMFS designated financially insolvent for all intents and purposes. In the Industry? A pat on the back and cigars passed out for Farelo-Fernandez’s new child’s birth nearly 9 months to the day of last years historic Florida FAST Conference where she and Miller were in attendance. I am not intimating Miller is the father; I am merely relaying the timing for my readership to reach out and perform due diligence upon.
We also know that there is yet another NAMFS Board Member with a criminal past. It would appear that Miller and Farelo-Fernandez are not performing due diligence or, as I believe, are being bribed. This information is solid and has been verified by the proper law enforcement channels. The NAMFS Board of Directors would appear to be nothing more than All The Usual Suspects, from where I stand. The reality is that the day that NAMFS begins their Leadership Summit, a story more revolting than the Heather Berghorst debacle is going to impact the NAMFS Board of Directors. So, sit back, belt in and get ready for a historic ride!
