The canard that the National Association of Mortgage Field Services (NAMFS) gives a damn about Minority Females or Labor is best viewed by the simple and salient fact that the NAMFS Board of Directors has always been white! Simply ask Eric Miller, NAMFS Executive Director, the last time he even shook hands with a black woman and offered her the opportunity to be on the NAMFS Board of Directors. It would be a lie if he stated he ever had — or ever will. You see, that is how things are when you receive a salary which consumes over SEVENTY FIVE PERCENT of all NAMFS Member dues. Minorities are the hired help and they had best learn their place. Fact of the matter is that hating Minority Females is the least of Eric Miller’s worries.
Over the past week, Foreclosurepedia has begun to expose the racist greed which has been eating away at the Miller Regime. Dating all the way back to 2003 when John Ward, NAMFS Founder, began conspiring with Richard E Dunne, a policy gun runner at the US Department of Housing and Urban Development (HUD). Ward and Dunne met with a half dozen other NAMFS and non NAMFS members at HUD HQ in Washington, DC. During that meeting, only three people voiced concerns about how Ward and Dunne were operating. Those three were Richard Law, founder of the Society of Field Inspectors (SOFI), Dan Buczek, founder of Buczek Enterprises, and John Cahill.
The problem with HUD Regulations is that they are both unenforceable and have absolutely zero oversight. HUD, by in large, oversees its multibillion dollar Management and Marketing program with what is commonly referred to as the HUD Mortgagee Letter (ML). The ML, with respect to what is paid, has never changed in nearly 40 years. In fact, Foreclosurepedia reached out to Keith Clay, Acting Government Technical Representative (GTR) for the Mortgagee Contract Manager (MCM) Contract, at the National Servicing Center (NSC) in Oklahoma City, for guidance. After several days, Clay replied,
Unfortunately I would not be the appropriate party to answer your question. In order to get your question answered by the appropriate party I would suggest you utilize the FOIA process, that way once HUD gets your request it will be officially logged in and tracked in insure the appropriate party can answer your question in a timely manner.
Ironic, as Clay was cited as precisely the appropriate party to answer the questions. Foreclosurepedia followed Clay’s instructions and filed a Freedom of Information Act (FOIA) Request yesterday. Before we get into that, though, I think that it is important to discuss HUD’s seemingly unwillingness to be forthright with the American Public. The questions I presented to Clay were not complex; the questions did not pose ethical dilemmas for anyone other than those whom oversaw the wholesale sell out of both Minority Females and Labor in conjunction with the US Taxpayer. And if, in fact, Secretary Ben Carson is honest in his desire to do the work of the American People; if Making America Great Again is a priority for the Trump Administration, what is wrong with collecting billions of dollars owed to HUD by those whom have Gamed the System? The only people with anything to lose are those whom either defrauded HUD or profited from the defraudment including those paid to look the other way. Is Clay one of those? I do not know. What I do know is that Ryan McDoulett and Richard Rice, whom both work for Information Systems and Networks Corporation (ISN), seem to be reviewing everything other than where HUD pass through and over-allowable monies actually go.
Information Systems and Networks Corp. (ISN) is responsible for reviewing over-allowables, extensions, surchargeable damages and claim information. They are there to make sure that mortgagees preserve and protect the property as well as follow the regulations set out by HUD.
For years, HUD has been on the receiving end of that which NAMFS Members were dishing out. And ISN is a Member of NAMFS. The question that presents is whether or not ISN will step to the plate and truly do their job as the Mortgagee Compliance Manager (MCM). Since Ward and Dunne met in Washington, DC, in 2003, the wheels of racketeering and kickbacks had been firmly cemented by both NAMFS and HUD. You know, if you ignore all the pomp and circumstance surrounding ISN’s most darkest days and their obtaining of the HUD MCM Contract, the reality is that everyone only pursues that which Gore Vidal spoke about — Power. And even more on point, one has to ask, where do the lines of Association end and responsibility to US Government Contracting begin?
The canary in the financial coal mine at HUD is whether or not HUD Secretary Ben Carson has the fortitude to target HUD’s very own Prime Vendors on FHA insured, pre-conveyance foreclosures. Common sense would say yes. The reality, though, may be far more complicated if firms like Mortgage Contracting Services (MCS) has anything to say about it.
These were the questions presented under the Freedom of Information Act (FOIA) Request submitted to Keith Clay and ultimately Secretary Ben Carson,
Does the Copeland Act applies to FHA insured, pre conveyance activities meaning Labor. [In that], is it legal for a HUD Prime Vendor, or anyone else, to force a mandatory discounting of the HUD pass through price in order to receive work upon FHA insured, pre conveyance foreclosed assets. If the Copeland Act does not apply, is Discounting legal as a mandatory part of a contract between Prime Vendor and Subcontractor.
This is an Example of how it works: ” Safeguard Properties gets an Order from MidFirst. They kick it over to, say, MCS. When they do this there is a built in 20% (or lower wholesale discount for institutional firms) discount. MCS then sends the order out to John Doe with another 20% discount. So, that $100 HUD is reimbursing the bank for as a pass through is now $60.”
Second, is it legal to charge back a Contractor for services HUD has paid for, retain that money, and not reimburse HUD the funds which were charged back? This is with respect to FHA insured, foreclosed properties in pre-conveyance status. There has been a pattern and practice, for years, of this activity and Mr Craig Karnes, Atlanta HUD, has verified a case I sent him last month. In most of the cases, HUD’s Prime Vendors will wait two and three years and then begin the process of charging back Contractors upon homes which have already sold.
Third, there has been a pattern and practice to obtain bids for services performed upon FHA insured, pre-conveyance foreclosed properties. This pattern and practice allowed for financial institutions and HUD Prime Vendors to shop bids around and submit the highest price to HUD while having a different Contractor perform the bid at a lower price. Richard E Dunne stated in a 2003 Meeting at HUD HQ in Washington DC, that this was “good business.” So, is it legal for a HUD Prime Vendor to purposefully submit a higher bid to HUD when it gets it done for far less and not submit the cost savings to HUD?
Fourth, does the Service Contract Act (SCA) payscale apply to subcontractors performing either pre or post conveyance services upon FHA Insured, foreclosed properties?
Fifth, if any of the aforementioned paragraphs are deemed to be illegal, would those funds due to HUD and kept by the Prime Vendor(s) and their Subcontractor(s) be cognizable under the False Claims Act? Finally, does Labor have the legal right to organize a Union, in accordance with the National Labor Relations Board (NLRB) guidelines, for services rendered to any HUD Prime Vendor or their Subcontractors.
Above and beyond the fact that Keith Clay’s refusal to answer questions are not consumer centric, many are beginning to question why HUD is refusing to enforce pay rates under the Service Contract Act (SCA). It is a full court press, you see. And it is the fifth question, put forth to HUD in the aforementioned FOIA Request, that should strike fear to the very core of NAMFS. Oh, it is not the Independent Contractors I am looking to organize. It is the W2 personnel whom are being onboarded by the HUD Management and Marketing (M&M) Field Service Manager (FSM) 3.10 Contract that I am looking at. Not simply those in the field, but those in the offices, as well. As Foreclosurepedia has demonstrated, on multiple occasions, Eric Miller and his all white NAMFS Board of Directors, have done nothing other than place those within Mortgage Field Services Industry in harm’s way. In fact, it required a partnership with the Society of Field Inspectors (SOFI) and Foreclosurepedia to actually advise the Secretary of Housing and Urban Development (HUD), Ben Carson, precisely what the problems were with the NAMFS belief that an all access policy was bad news.
Whether the US Department of Housing and Urban Development (HUD) wants to do anything meaningful, with respect to the billions of dollars in fraud committed against itself by its very own Prime Vendors, is unknown. In fact, when Kelly Brown, the Relator in a Qui Tam Whistleblower suit filed in Brown v Five Brothers, US Bank et al., is anyone’s guess. In fact, Brown and his lawyers found it amazing when US Assistant Attorney Valorie Smith stated that HUD did not care about the money it was owed. Moreover, those whom were pertinent to the investigation by the Department of Justice — those whom actually ran the M&M Contract — were never interviewed.
US Assistant Attorney Valorie Smith, New Jersey, appeared to have an agenda when she stacked the deck against the Relator in Brown v Five Brothers, et al. As the Brown case became a thorn in the side of Smith; as we are told that US Bank requested full disclosure of what was in the pipeline and immunity from such, the wholesale sell out of Kelly Brown began long before the wheels of his plane ever touched down to discuss the case. The fact of the matter is that Smith appears to have been assisted in the sell out by Brown’s very own attorneys, Shepherd, Finkelman, Miller and Shah LLP (SFMS). Did I forget to mention that Assistant US Attorney Smith’s law firm formerly represented US Bank? Or that both Smith and SFMS knew intimate details which allowed for ongoing security compromising of the US Department of Housing and Urban Development’s computer data system referred to as the P260?
And when it comes to chargebacks which HUD has already researched that they did not initiate, you have to hand it to National Field Representatives (NFR) in how they explain they are powerless and lay the entire blame upon Wells Fargo,
What we get from WF are spreadsheets containing hundreds of records/data with either a bill back or adjustment, which we then research and dispute or agree with if warranted. There is no specific individual document, like a HUD Demand letter specific to an loan, that we could send. We have never had this request before and these spreadsheets can not be sent to the rep as there is nothing listed that tells the rep which record is theirs, as the spreadsheets do not contain addresses or our unique account numbers, they only contain invoice number and loan numbers and lots of other data specific to WF and NFR. Also there is nothing that shows, to the rep, that it came from WF as it comes to us in an email as an Excel document attachment.
NFR receives, via email, spreadsheets demanding chargebacks and/or adjustments. While some are researched, the reality is that NFR does not get into pitched battles with Wells Fargo and, in fact, is complicit with the shakedowns. There are no legal documents, such as a HUD Demand Letter. In fact, the only thing that Minority Females or Labor are presented with is the good faith of yet another National Association of Mortgage Field Services (NAMFS) Offender Member that NFR is entitled to take any money they see fit, regardless of the timeframe and from what unique and independent contract that they want.
And while we are talking about the atrocities currently being committed by those NAMFS Members supportive of the Miller Regime, many are asking precisely what Purdy Enterprise, Alpine Companies, and other HUD M&M FSM 3.10 Contract Awardees will pay Minority Females and Labor. All have refused to answer. The #MitchDavidson monopolization is in full gear and in light of the fact that Foreclosurepedia exclusively broke the story that HUD will require all new locks on post conveyance properties, it should come as no surprise that #TeamPurdy is going to force those costs upon Minority Females and Labor.
At least one company has proactively engaged HUD to find out precisely where the costs will lie. Guard Asset Management (GAM) a NAMFS Member and a Member of the International Association of Field Service Technicians (IAFST) stated they reached out to HUD to inquire as to whether or not HUD will absorb this new cost. GAM did confirm that they would not allow Minority Females and Labor to shoulder the burden. To date, GAM appears to be the only HUD M&M FSM Awardee willing to put Minority Females and Labor first and above profits.
Look, when NAMFS Members do nothing but hire the same felons whom perpetrated the fraud causing the 2008 Crisis, nothing is going to change. As we showed previously, felons are working in these NAMFS Member firms. Take a look at how Five Brothers hired the Queen of Robosigning as their Compliance Manager,
That is reassuring, though, to others like Amy Edgil and Erla Shaw — the same Erla Carter Shaw whom was Executive Vice President, at Taylor, Bean and Whitaker. The same Erla Carter Shaw whose proliferation of signatures are legend in robo signing circles. Carter-Shaw, whose boss, Lee Farkas, defrauded $2.9 Billion dollars and was convicted on 19 April 2011, and profiled on American Greed. Five Brothers Compliance Director, Erla Carter Shaw had this to say about Farkas,
Dear Judge Brinkema,
I have known Lee Farkas for the last 10 years. Mr. Farkas has been my employer since 2000. He has also been my mentor and sounding board. During this time I have found Mr. Farkas to be a kind and generous person. I have seen him worked tirelessly on community projects for the town of Ocala. One such project is every year since working for TB&W he has personally stand on the street corner ringing the bell for the Salvation Army and has raised thousands of dollars. He also encouraged his employees and instilled them with the same generosity. Every year for Thanksgiving and Christmas, the employees would contribute tons of food to be distributed among the poor of Ocala. Mr. Farkas was also very concerned in regards to the treatment of TB&W customers. He always stressed the fact that the customers must be treated with respect at all times and would continuously send emails to employees to remind them of their customer service.
So, we have a convicted drug addict as the Five Brothers Operations Director and the Queen of Robosigning in control of Compliance at Five Brothers. Why is it that Secretary Ben Carson believes this is ok?! And how is it that the mandatory Aspen Grove Solutions (AGS) Background Checks ordered by Eric Miller and NAMFS, have never addressed these problems?! Moreover, the question presents, why would Secretary Ben Carson not want to pursue hundreds of millions of dollars which have been stolen from HUD and US Taxpayers in a time when HUD’s budget is being slashed by nearly $7 Billion? President Obama established the interagency Financial Fraud Enforcement Task Force to wage an aggressive, coordinated and proactive effort to investigate and prosecute financial crimes. The task force includes representatives from a broad range of federal agencies, regulatory authorities, inspectors general and state and local law enforcement who, working together, bring to bear a powerful array of criminal and civil enforcement resources. The task force is working to improve efforts across the federal executive branch, and with state and local partners, to investigate and prosecute significant financial crimes, ensure just and effective punishment for those who perpetrate financial crimes, combat discrimination in the lending and financial markets, and recover proceeds for victims of financial crimes. In the instant case, it would appear that, at minimum, HUD is a victim. Truth be known, Minority Females and Labor are the ultimate unseen victims.
Tomorrow, we begin to take a close look at how the Drive By Media, like the Huffington Post and ProPublica, turn blind eyes in order to fulfill their wink and a nod promises to Corporate America.