Saturday, March 18, 2017

Accepting Payments for Loan Modification Support Causes of Action

LEGAL NEWSLETTER

In the recent Ninth District U.S. Court of Appeals decision in Oskoui v. JP Morgan Chase Bank, the appellate court allowed Plaintiff Mahin Oskoui to proceed with her cause of action for breach of contract based upon evidence that:
-Oskoui properly requested and submitted the necessary information for Chase to evaluate her loan modification request under the federal program Making Home Affordable Program ("HAMP") and its own Chase Modification Program ("CHAMP");
-Chase concluded that Oskoui was ineligible for a loan modification for three separate reasons;
-Chase failed to disclose to Oskoui this information or its determination that she was ineligible for a HAMP or CHAMP loan modification;
-Chase continued to accept mortgage payments that Oskoui was induced to make based upon letters from Chase;
-Chase then informed Oskoui that she was ineligible for only one of the reasons,
-Chase continued to induce Oskoui to make additional payments that eventually totaled over $33,000, while it stated to Oskoui that it was exploring unexplained "other alternatives"; and
-Chase had knowledge of Oskoui's advancing age and precarious finances.

The Court of Appeals decided that these facts established a prima facie case (meaning that all of the necessary elements were established for each cause of action, subject to any defenses) of deceptive practices under California's Unfair Competition Law ("UCL"), as set forth in Business & Professions Code § 17200. 

Earlier, federal Judge George Wu found that Oskoui had presented the Court with a viable claim under California law for a fraudulent and unfair business practice, relying on the rule that a business practice is fraudulent under the UCL if members of the public are likely to be deceived.  As stated by Judge Wu, "If what Plaintiff alleges is true - that Chase's left hand sought payments from Plaintiff pursuant to a plan designed to give her an opportunity to modify her loan while, notwithstanding Plaintiff's payment in accordance with that plan, Chase's right hand continued all along with foreclosure proceedings and both hands should have known from the start that Plaintiff's loan would not be eligible for modification in any event - the Court can conceive of such allegations stating a section 17200 claim."

The facts appear similar to many other borrowers faced with financial disaster by the Great Recession. In 1990, Oskoui, a registered nurse, purchased her single-family home for $250,000.  After her home appraised for $1,250,000 in 2007 (the height of the "housing bubble"), she refinanced with a new loan from Washington Mutual Bank ("WaMu").  As a result of massive loan defaults and the severe national economic recession, WaMu was closed in September 2008, and its assets were transferred to Chase.

In November 2008, Oskoui missed a loan payment, and she applied for a loan modification to WaMu, not realizing it's demise.  Chase responded with a letter offering Oskoui a "Trial Plan Agreement".  Chase did not inform Oskoui of the requirements of a borrower or of a loan under the applicable modification rules.  The letter did advise Oskoui that "[i]f you comply with all terms of this Agreement, we'll consider a permanent workout solution for your loan once the Trial Plan has been completed."  The appellate court found the letter supported a breach of contract claim as it constituted a clear promise of an offer of a permanent modification if the borrower complied with its conditions.

Oskoui fully complied with the Agreement's payment term by timely paying Chase $9,840.15.  Thereafter, Chase informed Oskoui she did not qualify "at this time" for a modification under either HAMP or CHAMP because her income was insufficient for the amount of credit she requested.  Chase did not disclose to Oskoui that she was ineligible for the two additional reasons of (1) the unpaid principal balance on the loan of $833,000 exceeded the amount allowed by HAMP guidelines, and (2) the loan failed to satisfy the CHAMP net present value test ("NPV").  Internally, a Chase employee named "CHANG" determined in November 2009 that Oskoui's application should be rejected because "denied - income insufficient and did not pass the npv calc [i.e., NPV calculation] test."

However, Chase did not inform Oskoui that she was not eligible for the loan modification, and instead, told her that "we may be able to offer other alternatives to help avoid the negative impact" of foreclosure and a deficiency judgment (i.e., a judgment against Oskoui for the difference in the amount of the unpaid principal and the amount received by Chase at the foreclosure sale). Chase did not inform Oskoui what its "other alternatives" were or what Oskoui would need to demonstrate to qualify for them.

Oskoui submitted in January 2010 another application for a loan modification, without realizing that Chase has already determined that she was not eligible.  Chase responded with a letter dated March 1, 2010 ("March 1 Letter") stating that Chase "wants to help you stay in your home", and confirmed receipt and review of her "verification of income documentation."  Included with the March 1 Letter were three payment coupons and three return envelopes, each coupon in the amount of $2,988.49, and specifying they were due on April 1, May 1, and June 1, 2010.  The March 1 Letter also stated on the first page: "After successful completion of the Trial Period Plan, CHASE will send you a Modification Agreement for your signature which will modify the Loan as necessary to reflect this new payment amount." (Emphasis added.)  The March 1 Letter did not disclose Chase's concerns about her income.

The next day, Chase sent Oskoui a letter dated March 2, 2017 ("March 2 Letter"), telling her for the first time that she was not eligible for a federal HAMP modification "because the current unpaid principal balance on your Loan is higher than the program limit . . . ." The March 2 Letter did not disclose the fatal NPV test, but stated that Chase was "happy" to tell Oskoui that she "may be eligible for other modification programs", and that Chase may be able to offer "other alternatives" to stave off "the negative impact" of a possible foreclosure.  Because Chase had left the door open to relief and even urged Oskoui to make the additional payments, Oskoui made, and Chase accepted, an additional seven months payments.

Meanwhile, Chase proceeded with the foreclosure process, setting the trustee's sale on November 18, 2010.  Amazingly, Chase allegedly sent another letter dated November 1, 2010, encouraging Oskoui to continue to seek a loan modification.  By this time, Oskoui had paid Chase $33,738.00, with no results over two years.  By a letter dated January 4, 2011, Chase informed Oskoui that her application was denied, stating that it was unable to offer her a modification under HAMP or CHAMP "because you did not provide us with the documents we requested."

Based upon these allegations of fact, the Appellate Court agreed with Judge Wu's analysis, and found they "plainly demonstrate a viable UCL claim."  It found that the published HAMP Guidelines disqualified Oskoui, and Chase had the relevant information and could have made that "simple determination within a matter of minutes".  But instead of determining eligibility before asking for money, "a logical protocol called for by HAMP as of January 28, 2010", Chase requested more payments.  Even after Chase contradicted the March 1 Letter with the March 2 Letter, it did not inform her of her precarious situation, and accepted payments for seven additional months.

Describing Chase's conduct as "Kafkaesque" due to intent or corporate ineptitude, the appellate court held that "Chase knew that she was a 68 year old nurse in serious economic and personal distress, yet it strung her along for two years, kept moving the finish line, accepted her money, and then brushed her aside.  During this process, Oskoui made numerous frustrating attempts in person and by other means to seek guidance from Chase, only to be turned away." 


Fortunately for Oskoui, a federal judge and a federal appellate court have given Oskoui an opportunity to present her case at trial.

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