Letter to Mr. John Walsh, Acting Comptroller of the Currency, Office of the Comptroller of the Currency, The Honorable Ben S. Bernanke, Chairman, Board of Governors of the Federal Reserve System, Mr. Martin Gruenberg, Acting Chairman, Federal Deposit

Letter

Dear Acting Comptroller Walsh, Chairman Bernanke, Acting Chairman Gruenberg:

We write today to urge you to make public critical information related to
enforcement actions taken against mortgage servicers regarding their
improper foreclosure practices. this is especially important given this
week's allegations that mortgage servicers continue to engage in
widespread "robo-signing" despite your assurances that these illegal
actions would not continue. Specifically, we request that you make public
the following items related to the April 12, 2011 Consent Orders issued by
your offices:

-All "Engagement Letters" governing the mortgage servicers' contracts with
the consultants hired by the servicer to review that servicer's
foreclosure actions;
-All "Actions Plans" that mortgage servicers and third-party servicer
providers are required to provide to regulators and that will outline the
financial resources, organizational changes, measurement systems,
governance controls, and timelines that will be adopted to correct
improper foreclosure practices;
-All "Foreclosure Reviews" completed by consultants for each bank, which
will outline the results of their investigations into whether ownership of
promissory notes or mortgages were properly documented, whether
foreclosures were undertaken in accordance with state and federal law,
whether calculations under the Home Affordable Modification Program and
proprietary loan modification programs were done correctly, whether
borrowers were charged excessive or improper fees and penalties related to
delinquency, and whether any errors identified caused financial injury to
borrowers, among other items;
-Any other plans, policies, or processes submitted to your offices by
mortgage servicers or third-party servicer providers pursuant to the April
12, 2011 Consent Orders whose disclosure is important to instill public
confidence in the process and result of foreclosure reviews.

We believe it is essential that the items listed above be made available
to the general public or the public will lack confidence in both the
foreclosure review process and results. This is particularly the case
because the foreclosure reviews are being performed by consultants who are
chosen by the mortgage servicers themselves, and those consultants often
have conflicts of interest in that they are not prohibited from getting
further business from those same mortgage servicers. the information we
are requesting is therefore necessary for the public to determine the
independence of the consultants being engaged to perform the foreclosure
reviews, the accuracy of the foreclosure reviews, the adequacy of the
"Action Plans"in responding to your findings, whether servicer performance
meets the goals they have established, and whether those homeowners who
experienced harm (such as being improperly foreclosed upon or denied
mortgage modification when they should have been granted under existing
criteria) are given appropriate remedies. Based on a legal analysis by
the non-partisan Congressional Research Service, we also believe that it
is well within your regulatory discretion under existing laws to disclose
this information in the public interest. This is consistent with your
previous determination in April that release of the Interagency Review of
Foreclosure Policies and Practices, which was essentially an examination
report of foreclosure practices, was also in the public interest. We
understand concerns about not revealing mortgage servicers' proprietary
information, but also believe that some disclosure can be done on a bank
by bank basis without compromising proprietary information.

Furthermore, we believe that the full disclosure of these documents to the public is necessary given the recent reports by both the Associated Press and Reuters 0of the continued widespread practice of "robo-signing" among mortgage servicers. Both have alleged that servicers continue to file thousands of property documents that appear to be fabricated. Reuters also quoted top representatives from the mortgage servicing that the Consent Orders have "not put a stop to questionable practices." David Stevens, president of the Mortgage Bankers Association, tellingly said that some loan servicers "continue to cut corners" and "the real question is whether the servicer complied with all legal requirements."

We respectfully request that all documents be made public and sent to Congress within one week of your office receiving them from mortgage servicers or third-party servicer providers. If you have any questions about this request, please contact Amanda Fischer at (202) 225-2201 or Michael Passante at (202) 224-4744. We appreciate your swift attention to this important matter.