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________________________________________________________________________________________________________________________________
Special Operations Division (925) 957-8604
900 Ward Street, Fourth Floor Fax (925) 646-4683
P.O. Box 670
Martinez, California 94553
MEMORANDUM
TO: Contra Costa County Board of Supervisors
FROM: Mark Peterson, District Attorney
DATE: 5/8/12
RE: “Bay Area Moratorium” Allegations at 3/27/12 Board of Supervisors meeting
BACKGROUND:
San Francisco
In early February 2012, Phil Ting of the Office of the Assessor-Recorder of San
Francisco released a 21 page report which analyzed 382 San Francisco residential mortgage loan
transactions which ultimately resulted in foreclosures. The report concluded that California’s
non-judicial foreclosure process had significant problems.
The report found many technical civil violations involving foreclosure transactions,
including property transfer documents which were not filed on time. Of particular interest to the
Office of the District Attorney, the report alleged that 82% of the 382 loans contained
“suspicious activities” possibly involving a) strangers to the deed of trust purporting to be
beneficiaries, b) back-dating documents, and c) incorrectly executed documents.
On April 2, 2012, the SF Board of Supervisors held a hearing to determine whether to
pass a moratorium ordinance to suspend all foreclosure activities in San Francisco. Phil Ting
presented his findings, as described above. Many other speakers spoke on this issue. Of
particular interest, Senior District Attorney June Cravett of the SF DA Office spoke to the Board
wherein she said that the audit did not provide any assistance whatsoever to law enforcement.
Further, the audit did not turn over any cases to investigate. Apparently, Mr. Ting’s audit did not
save any documents, save any names of victims, nor did it assist law enforcement in any way.
Hence, not one case was referred to the San Francisco DA Office.
Contra Costa County DDA Ken McCormick personally reviewed the entire four hour SF
Board of Supervisor hearing, and it appears that the moratorium ordinance passed but there were
no details about how the Board was going to enforce the moratorium. It appears that the
moratorium ordinance was merely symbolic.
Nationwide
On February 8, 2012, 50 state Attorney Generals settled a $25 billion dollar claim against
five leading bank mortgage servicers (BofA/CountryWide, JPMorganChase/WaMu,
WellsFargo/Wachovia, Citibank, and Ally/GMAC.) The investigation and settlement resulted
from revelations of widespread use of “robo-signed” affadavits in foreclosure proceedings across
the country. Major mortgage servicing banks acknowledged that individuals had been signing
thousands of foreclosure affadavits without reviewing the validity or accuracy of the sworn
statements. The settlement provides $17 billion for principle reduction, facilitation to short
sales, waiving deficiency balances, etc.
Individuals who lost their homes to foreclosure to these mortgage companies from 2008
to 2011 are expected to receive restitution ranging from $1,500 to $2,000. Those who are still in
the home, and delinquent on their loans, might be eligible for a principle write-down of $20,000
or more.
The settlement does not prevent criminal investigations.
Contra Costa County
1. Foreclosure Activity
Contra Costa County, as found elsewhere, has suffered a large number of foreclosures
which resulted in the filing of a Trustee’s Deed Upon Sale (final document in the
foreclosure process resulting in the transfer of ownership):
a) 4,189 in 2007
b) 11,679 in 2008
c) 8,360 in 2009
d) 7,562 in 2010
e) 6,869 in 2011
f) 938 in 2012 (thru 2/12)
2. Office of District Attorney Expertise
Contra Costa DDA Ken W. McCormick has been a recognized leader in combating
foreclosure fraud. He has been a guest speaker at the following events: California
District Attorney Association on the subject of foreclosure scams; guest lecturer on
foreclosure crimes at the 6/14/08 ‘Congressional Foreclosure Prevention Workshop’;
guest lecturer at the 15th Annual ‘Fair Housing Laws & Litigation Conference’ on
2/14/08 on foreclosure remedies; and guest speaker on 10/20/10 on foreclosure recovery
at Federal Reserve Bank of San Francisco. DDA McCormick is also a member of the
Federal Trade Commission’s ‘Northern California Foreclosure Fraud Task Force’ since
12/6/07.
3. Foreclosure Advisory Letter
In 2006, DDA McCormick created the District Attorney “Foreclosure Advisory Letter” to
be sent to anyone who receives a “Notice of Default” (the first notice to a homeowner
that they may lose their residence to foreclosure). Since 2006, this simple bi-lingual
letter informs homeowners that they need to be wary of foreclosure scams and they
should promptly contact free HUD certified counselors (ie ‘Pacific Community’ in
Pittsburg and ‘Community Housing Devlopment Corp. of North Richmond’) for financial
advice. The letter also refers individuals to the CCC Bar Association if they seek civil
recourse against the lender. To date, the District Attorney’s Office has mailed out over
73,574 Foreclosure Advisory Letters to citizens of Contra Costa County. (Counties from
all over the state have copied the model of the Contra Costa County ‘Foreclosure
Advisory Letter’.)
4. Fraud Notification Program
In cooperation with the leadership of Recorder Steve Weir, the Office of District
Attorney and Clerk/Recorder’s Office created a similar program entitled “Fraud
Notification Program.” This program requires the Recorder’s Office to send out a letter
to every homeowner whose title has been transferred to a different homeowner. The
letter asks the original homeowner whether they were aware that title to their property has
transferred to another person. If they were not aware, the original homeowner is directed
to call a newly created “fraud hotline” at the District Attorney’s Office. A DA paralegal
answers the numerous calls to ferret out the curious from the true victims of fraud, and
creates daily reports. DA Senior Inspectors are assigned to investigate allegations of
fraud.
The Office of District Attorney recently prosecuted the case of People v. Walter Roberts
which involved a 63 year old man who fraudulently transferred title from his 92 year old
father. Our office promptly arrested Mr. Roberts, and we were able to transfer title back
to the elderly victim before the suspect could drain the equity out of the $300,000
Concord home.
Contact with “Bay Area Moratorium” Organization
1. On February 22, 2012, without making an appointment, approximately 60 people from
a group called “Bay Area Moratorium” came to the lobby of the Office of the District at 900
Ward Street, Martinez demanding prosecution of robo-signers, eviction lawyers, and banks. DA
inspectors obtained their names and suggested that they send their complaints to DDA Ken
McCormick in the form of a consumer fraud complaint. Only 17 people, who signed the
attendance sheet provided by the inspectors, were from Contra Costa County. Several people
were from San Joaquin County as well as Santa Clara County.
DDA McCormick personally spoke with these individuals, gave them his business cards,
and asked them to provide detailed explanations when drafting their complaints. During these
conversations, certain individuals were photographing and videotaping DDA McCormick and
the DA inspectors present such as Paul Mulligan and Jerry Sanchez;
2. From February 24 to present, the District Attorney’s Office received a number of
consumer fraud complaints from members of Bay Area Moratorium. Some complaints involved
an explanation of their concerns, however, many did not provide any details of how they were
negatively affected by a bank or mortgage servicer.
3. On March 20, 2012, without making an appointment, approximately 30 people from
“Bay Area Moratorium” appeared again at the 900 Ward Street office. DDA McCormick was
unavailable to meet with the group at that time, and they left.
4. On March 23, 2012, DDA McCormick called and invited Rosie Alvarado to meet him
to discuss her complaint. She was joined by the leader of Bay Area Moratorium, who identified
herself as Delia Aguilar. Ms. Alvarado requested that DDA McCormick contact the police to
tell them to disregard an eviction order signed by Commissioner Lowell Richards as she believed
the order was based on a false robo-signature. DDA McCormick told her that he did not have
the authority to tell the police to disregard any court order. She told him she believed he did
have that authority. After the brief meeting, DDA McCormick wrote a letter to Rosie Alvarado
memorializing their discussion.
5. On March 23, 2012, DDA McCormick wrote letters to Leonor Bagamano, Erika Colon
and J. Pilar Navarro to ask for information as to the nature of their complaint. These individuals
provided no facts as to how they were defrauded and by whom. Essentially, their complaint was
blank but DDA McCormick was able to confirm they were real property owners in Contra Costa
County.
6. On March 23, 2012, DDA McCormick wrote a letter to Victor M. Therosa asking for
more information as his complaint was blank as well. DDA McCromick was unable to find any
real property owned by this individual in Contra Costa County.
7. On March 25, 2012, DDA McCormick called and spoke to Cynthia O’Neal who wrote
a complaint on behalf of Chaiphone Khamphanthong who is a mono-lingual Laotian. He learned
that their complaint is not one of robo-signing. Instead, she informed DDA McCormick that no
notary was present when Khamphanthong signed the Deed of Trust. She was asked to send a
statement to our office as this is a matter which can be investigated and prosecuted.
8. On March 23, 2012, DDA McCormick spoke with Lourdes Perez to discuss her
complaint which provided no details. Ultimately, she was referred her to the CCC Bar
Association to seek a free referral to a real estate attorney as it appears she has a Quiet Title civil
complaint against lender.
9. On March 27, 2012, three people from Bay Area Moratorium attended the CCC Board
of Supervisors meeting. Each person made a 3 minute public comment demanding three things:
a). That our County Recorder conduct an audit similar to what SF Recorder’s conducted, b).
That the DA Office have a meeting with Bay Area Moratorium, c) That the county issue a
“Cease and Desist Order” on all foreclosures.
Supervisor Piepho indicated that she would like the elected DA and County Recorder to
respond to these public comments at a future BOS meeting.
10. On April 15, 2012, DDA McCormick wrote a letter to Miguel C. Gomez requesting
more information.
11. On April 15, 2012, DDA McCormick wrote a letter to Delia Aguilar who is the leader
of Bay Area Moratorium requesting more documents from her unlawful detainer action which
supports her theory that the eviction attorneys from Huntington Beach intended to commit ‘theft’
of her property as the eviction attorneys allegedly knew that a signature on a Trustees Deed
Upon Sale from 2008 was fraudulent.
12. On April 15, 2012, DDA McCormick wrote a letter to Jose S. Abrian who stated that
he suspects that JP MorganChase does not possess his original mortgage note based on a 2006
refinance with WaMu. Putting aside the statute of limitations, DDA McCormick informed Mr.
Abrian that this office does not have jurisdiction to determine who or who does not possess his
original mortgage note from a 2006 transaction.
Other California District Attorney’s Offices and the Attorney General Office:
In early March, DDA McCormick sent out an email to the real estate fraud prosecutors
in California to see if anyone is investigating and/or prosecuting allegations of ‘robo-signers’ on
past real estate documents. No county responded that they are investigating or prosecuting these
types of allegations.
The California Attorney’s General’s Office, via email, indicate that they have not
criminally prosecuted any ‘robo-signing’ allegations brought to their office.
At a meeting on April 18, 2012 attended by several elected Bay Area District Attorneys
and District Attorney Mark Peterson, no District Attorney indicated that their offices were
prosecuting robo-signers, or these types of allegations.
CA Pending Legislation Regarding Robo-Signers:
Right now, there is a plethora of bills dealing with foreclosures in general.
Of particular interest for Bay Area Moratorium, is AB 2425 / SB 1471 which imposes a
$10,000 civil penalty on the recordation or filing of “robo-signed” documents, defined as
documents that contain information that was not verified for accuracy by the person or persons
signing or swearing to the accuracy of the document or statement. Said bill would authorize the
Dept. of Real Estate, Dept. of Corporations, and the Department of Financial Institutions to
enforce the civil penalty against the banks respective licenses.
Furthermore, the bill would authorize a borrower to seek an injunction of a pending
trustee’s sale, if a notice of sale has been recorded and borrower reasonably believes that the
mortgagee, trustee, beneficiary, or authorized agent failed to comply with specific requirements.
Treble damages or $50,000 in statutory damages would be provided if the failure to comply is
found to be intentional or reckless or resulted from willful misconduct.
Senator DeSaulnier and Pavley authored SB 1471. Legislative history indicates that on
April 17, 2012, the author(s) canceled an impending hearing. No further public action is noted
since 4/17/12.
Crimes:
A very significant issue, of course, is whether any of the activity involving foreclosures
or real estate transactions described above involves a crime set forth by statute. A required
element in these types of crimes, is an “intent to defraud,” i.e. to benefit monetarily. Again, a
‘robo-signer’ is described as someone from the bank / mortgage servicer who signs a document
but makes no effort to verify the accuracy of the document. By this definition, the “robo-signer”
is not necessarily a forger per Penal Code Section 470, because there is no intent to defraud to
cause a loss of goods/services/money as required for forgery.
Another possible crime could be a violation of Penal Code Section 115(a) [Procuring
False Document for Filing]. There are significant problems to proving such a crime. This is
because, pursuant to CalCrim Jury Instruction Number 1945, one element of the crime which
must be proven is that the person who filed the document in a public office (eg County
Recorder’s Office) knew that the document was false or forged.
Further complicating the issue is the fact that many of the banks / mortgage services who
are accused of ‘robo-signing’ are out of state business or businesses located in Southern
California. Virtually no business of the sort described is located locally.
CONCLUSION:
According to the San Francisco audit, there appears to be a high frequency of at least
technical violations involving foreclosures in that county. Whether that is the case in Contra
Costa County is unknown. Even assuming there is that type of activity in our county, it is not
certain at all that it involves criminal activity.
Bear in mind, that many of the complainants are homeowners who are unfortunately
unable to pay their mortgages. In many instances that we were made aware of, the homeowners
had arrearages ranging from $5,000 to $67,000. Some of these individuals have already delayed
foreclosure a) by deeding partial ownerships to fictitious companies, b) by filing bankruptcies or
c) by filing lawsuits in conjunction with a Lis Pendens.
Once again, the Office of District Attorney will absolutely prosecute criminal fraud when
it is discovered and provable. At this time, it is unclear whether any criminal activity has
occurred, and also unclear whether it can be proved. We will continue to monitor the situation.