Update 2 On The Make Money With a Side Hustle Project. Nationstar counterclaimed seeking the same, and the matter proceeded to a bench trial. Nationstar is one of the nation's largest mortgage servicers and the largest non-bank mortgage servicer in the United States. After I proved that they lied about the loan modification agreement they changed the story that the VA mortgage I have was not assumable because it was only in my husbands name who died March 21, 2019. Nationstar Mortgage to Pay 1.7 M for Failure to Report Accurate Loan Data, Reverse Mortgages why Seniors Lose Their Home, CFPB Takes Action Against Wells Fargo and Chase for Illegal Morgage Kickbacks, Mortgage Closing Scams: How to Protect Your Money. So I started the bankruptcy proces. The trial court entered summary judgment in favor of the Defendant on most claims, and Theyve refused my my payments consistently. WHY IN GODS NAME CAN YOU NOT PAY THESE PEOPLE with a debit/credit card payment or like any instant payment. Nationstar allegedly failed to timely disburse borrowers tax payments from their escrow accounts and failed to properly conduct escrow analyses for borrowers during their Chapter 13 bankruptcy proceedings. The $91 million Nationstar Mortgage settlement resolves allegations of mortgage servicing misconduct and . they told me i would qualify for harp, but i have to be late on one payment, so i did that, made 2 payments the following month, then they told me i would not qualify for either hamp or harp. That was supposedly to get them to have to except my payments. . The proposed judgment also includes reporting and recordkeeping requirements. Why does a wealthy and powerful company find it necessary to prey on the least able to protect themselves? Thomas v. Nationstar Mortgage, LLC 2:2022cv00088 | US District Court for the Southern District of Mississippi | Justia Thomas v. Nationstar Mortgage, LLC RSS Track this Docket Docket Report This docket was last retrieved on August 30, 2022. 7-8. Like I tried to say where do I need to DRIVE to go pay this. How do I sign up for this lawsuit? 20. attorney's fees and costs against Nationstar Mortgage, LLC. i was with aurora first wtih an interest only loan then sold to nationstar then sold to mr cooper and now just changed to rushmore loan services. I have had Mr. Cooper for 1 year and have been working on a streamline refinance with them since November to remove mortgage insurance and get a lower rate. I want to be added to Class Action Lawsuit, I believe my mortgage account is incorrect Their response on 12/4/20 was that they issued a check on the same day as my inquiry 11/30/20. The Bureau alleges that Nationstar violated multiple Federal consumer financial laws, causing substantial harm to the borrowers whose mortgage loans it serviced, including distressed homeowners. Nation Mortgage LLC et al Filing 34 JUDGMENT OF DISMISSAL WITH PREJUDICE by Judge George H Wu: The Court hereby DISMISSES all claims against Nationstar Mortgage LLC, Anthony H (Tony) Barone, and Christine Odom with prejudice. In 2006, Mrs. Renfroe refinanced her mortgage with Wilmington Finance, Inc. at a fixed rate of 7.75 percent for a 30-year term, with monthly payments of $998.68. Joseph v Nationstar Mortgage, LLC. on my property when this started, now with all their fees they have it up to 149,000 + whatever they want to add on. You request a short sale but are told to send information back by scanning NEVER (Mr Cooper) provided a fax# or mailing address all the while to say they never received it but go behind your back to foreclose on your property or if youre in bankruptcy lied to courts to say you didnt pay and bankruptcy courts dont care. SALEM, Ore. (KTVZ) -- Oregon Attorney General Ellen Rosenblum announced Monday that mortgage servicer Nationstar will pay $86.3 million to settle allegations that the company violated consumer. from being Transferred from Nation Star to Mr. Copper. Nationstar broke that trust by engaging in unfair and deceptive practices prohibited by the Consumer Financial Protection Act of 2010, as well as violations of the Real Estate Settlement Procedures Act and the Homeowners Protection Act, said CFPB Director Kathleen L. Kraninger. Cooper wouldnt work with her to refinance or even reply to requests for help. I do want to join this class action. The Consumer Financial Protection Bureau (CFPB) is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives. That prohibition applies during the life of a mortgage loan and applies to an assignee and a servicer of the mortgage loan, as well as to the originator of the loan. NATIONSTAR MORTGAGE LLC, Defendant-Appellee . W2020-01148-COA-R3-CV _____ This case involves a controversy surrounding certain real property located in Memphis. (Yes, a win for the lawyers but I dont have my house because I had to deal with a shady company how does a pittance remedy that? Case Overview. The District Court subsequently entered judgment against Joseph on the claims against those two defendants. I was charger more money for my home an I had forced-placed insurance, on the home, at that time, an no adjuster came out. If you find yourself in a financial situation that you cant correct on your own, please Call Diane Drain as soon as possible. Continually fined and it is meaningless to them. We provide affordable payment plans. The complaint contends that Nationstar Mortgage would then initiate attempts to collect on the deficiencies without getting the required permission from the bankruptcy court. Here are some of the common mortgage servicer mistakes to look out for: misapplied mortgage payments overcharging the buyer mistakenly force placing insurance improperly initiating a foreclosure dual tracking improper loan modifications failure to pay taxes and insurance from the escrow account I have called and called and no answers. WHAT HAPPENS AT THE END OF A COVID-19 FORECLOSURE FORBEARANCE? Attorneys general from all 50 states and the District of Columbia and bank regulators from 53 jurisdictions covering 48 states and Puerto Rico, the Virgin Islands, and the District of Columbia settled with Nationstar the same day and their settlements are reflected in separate actions, concurrently filed in the United States District Court for the District of Columbia. And changed my 30 year note to a forty year note. I believe i qualify for many Law suits againest them. memorandum decision on specialized loan servicing, llc's motion for summary judgment . As part of the consent order, Nationstar will pay consumers nearly $90 million to resolve past actions, and will also pay in excess of $6.5 million in civil . The settlement came after a multi-year investigation which involved the efforts of the CFPB and state bank regulators. Ive always thought that if BoA had not sold my mortgage to this shady company (after my co-signers credit went south) then I WOULD STILL HAVE MY HOUSE! We had a strong partnership with our state counterparts in this case and I thank them for all their support in this case., This settlement demonstrates the crucial role of state financial services regulators in ensuring that homeowners are protected as they obtain and pay down their mortgagesespecially homeowners who may be struggling with making their payments, said Illinois Department of Financial and Professional Regulation Secretary Deborah Hagan. So now really couldnt afford payment. Nationstar Mortgage, LLC UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON UPDATE: In March 2019 the Parties reached an agreement to settle the matter. The district court granted summary judgment to Nationstar on some but not allof Dorvil's claims. Click Accept if you consent. What Are Your Spending Habits? drug injury lawsuits and product liability lawsuits. I finally found a job and called them and they told me it was gone mighty fast so they had to be busy selling while I was in bankruptcy. Who do the claimants turn to? How Do I Get Out of Debt Quickly? 8. Contacted them on 11/30/2020 since property taxes were still showing as outstanding and no check listed as issued on Mr. Coopers website. Nationstar, the fourth-largest mortgage servicer in the U.S., is set to pay $91 million to settle claims brought by the Consumer Financial Protection Bureau and state attorneys general alleging . This field is for validation purposes and should be left unchanged. I have proof of my bank statement that this was accepted on October 2, 2021 and also the statement from Mr. Cooper who subsequently applied the trial payment amount and added to money that was in a suspended account to make a mortgage payment for October. This resolution demonstrates that a commitment to government coordination provides a path to efficient, effective, and comprehensive outcomes for both consumers and for Mr. Cooper, who will be held to the highest operational standards as it continues to provide mortgage services across the nation.. Any information you obtain from this website should not be construed as legal advice, nor as grounds for forming an attorney-client relationship. NEED HELP STILL. My mortgage was due on the 1st of Oct, on the 19th they sent a man over to my house to take pictures for forclosure and charged me for the service that the man provided. Judgment and Order with Nationstar (the "CFPB Consent Judgment"); WHEREAS, Defendant, by its attorneys, has consented to entry of this Consent Judgment . MORTGAGE SERVICING ERROR. My father passed away from covid on Aug. 28 2022. We will update you on newsroom updates. My intention is to put you back in control of your life The mortgage agreement required compliance with all applicable state and federal laws. (MD JS-6, Case Terminated). They are also part of a larger government effort, which also includes assistance from the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) and the United States Trustee Program, to address Nationstars alleged unlawful mortgage loan servicing practices. In or about June 2016, while Ms. Choi was still living in the home she purchased, Defendant purchased Plaintiff's mortgage loan from Nationstar's Predecessor-in-Interest. Defendants filed their appearance and answer including an affirmative defense and counterclaims on January 1, 2017. settlement administrator or your attorney for any updates regarding Please add me to the list. Complaint | Consent Judgment. Providing credit unions with the best federal advocacy, education and compliance assistance in the industry. Think about it! I need to be part of this class action law suite because I was mentally tortured in the past and present. If entered by the court, Nationstar would be required to immediately set aside about $15.6 million to pay borrowers it has not remediated prior to the orders effective date and to certify that it has already paid approximately $57.5 million in redress to other borrowers affected by the conduct alleged in the complaint. Todays action is the culmination of a multi-year effort working with our state partners to investigate Nationstars failings, which resulted in substantial consumer harm. that reports on class action lawsuits, class action settlements, I have been told the most ridiculous things about how the paperwork is not sent in properly. Thank you. Nationstar agreed not to oppose class counsel's fee request up to $1,300,000. NEW YORK - New York Attorney General Letitia James has joined 50 other attorneys general and other federal and state agencies to deliver an $86.3 million agreement including $79.2 million in restitution for homeowners with Nationstar Mortgage LLC for its multiple servicing errors since 2011. Specifically, the complaint alleges that Nationstar Mortgage, the third-largest mortgage servicer in the U.S., violated the law by improperly increasing permanently modified monthly loan payments, wrongfully foreclosing on mortgages, failing to honor loan modification agreements, and mismanaging escrow accounts. How to Get Out of Debt Without Getting Scammed and What to Do if You Have Been, The Beach Misses You: A Financial Fable For Happiness And Internal Peace, Get Out of Debt Guy Podcast - Reader Questions - AMEX Arrrgh, Getting Out of Debt and Making Lots of Extra Money is Easy When You Do This One FREE Thing, Is Your Debt Relief Company a Scam and How to Make an Extra $800 a Month to Make Ends Meet. Additionally, the Attorneys General allege in their complaint that the mortgage servicer violated state consumer protection laws which prohibit unfair practices and deceptive acts, as well as the Consumer Financial Protection Act of 2010. My ex called them to get info on me and my mortgage to use against me in my divorce and they released all the info they wanted to, release to him even though I have signed all documents to NOT release info. To read the proposed stipulated judgement and order click here. This happend before the pandemic was announced but big bussiness saw china and I believe did this hoping to get over on many>>>>Unfortunatley this lawsuit only probably covers a fraction of the people the have ROBBED. To this day I cant access my mortgage and I get NO statements. Where Can I Get a Loan to Buy an Adult Movie Theater? The consent judgment resolves allegations that Nationstar, which does business as "Mr. Cooper," violated consumer protection laws during its servicing of mortgage loans. HARRISBURG Attorney General Josh Shapiro, as part of a multistate effort, today announced that his office obtained an $86.3 million settlement from Nationstar Mortgage, the country's fourth-largest mortgage servicer. Nationstar Mortgage agreed to settle an action commenced by the Consumer Financial Protection Bureau for $91 million to resolve allegations surrounding mortgage servicing misconduct and deceptive practices that resulted in financial harm to borrowers. Make sure to check out their reviews.*. SACRAMENTO - California Attorney General Xavier Becerra today joined a 50-state settlement against Nationstar Mortgage (Nationstar), which does business as Mr. Cooper, resolving allegations that the mortgage servicer engaged in unlawful practices in the wake of the 2008 financial crisis. Need a lawyer handling this class action lawsuit with nationstar, THEY TOOK MY HOUSE AND 80 ACES I FOUGHT WITH EVERY DIME I HAD LEFT. I want to be added to the class action law suite like all the allegations others have experienced them myself. They send people out to my property taking pictures all the time and everytime they charge 2,000 to 8,000 in fees. Filing for bankruptcy can be a stressful life event, and selecting the right attorney can add to this stress. I have spoken to them on the phone over and over again with no help. 1291. I have hired an attorney just to talk to them and help me with the modification papers. The complaint states that the company serviced nearly two million loans in 2014 and currently services loans for three million borrowers with a total of roughly $500 billion in unpaid principal loan balances. When this all started, my husband passed away, I hired an attorney to do probate and theyve chosen to ignore probate findings. . You can learn more about Steve, NATIONSTAR MORTGAGE - CFPB Complaint ID 2552967, NATIONSTAR MORTGAGE - CFPB Complaint ID 3094982, Click to email a link to a friend (Opens in new window), Click to share on Facebook (Opens in new window), Click to share on Twitter (Opens in new window), Click to share on LinkedIn (Opens in new window), Click to share on Tumblr (Opens in new window), Click to share on Pinterest (Opens in new window), Litigation Practice Group Lawsuit by Business Partner All Service Financial We Want Our Money, HomeAdvisor and Angi to Pay Up To $7.2 Million and Stop Deceptively Marketing its Leads for Home Improvement Projects. . You folks are the BEST OF THE BEST in Arizona. This company was a nightmare to work with. The proposed judgment and order, which the court entered on December 8, 2020, requires Nationstar to pay approximately $73 million in redress to more than 40,000 harmed borrowers. Consiquently we lost our home. The Consumer Financial Protection Bureau (CFPB) has filed a complaint and proposed a stipulated judgment and order against Nationstar Mortgage LLC, which does business as Mr. Cooper. State Attorneys General will take action against any lending company that breaks the law and treats borrowers unfairly." . CONSUMERS WISHING TO FILE A COMPLAINT AGAINST A MORTGAGE BANKER OR A LICENSED MORTGAGE BANKER RESIDENTIAL MORTGAGE LOAN ORIGINATOR SHOULD COMPLETE AND SEND A COMPLAINT FORM TO THE TEXAS DEPARTMENT OF SAVINGS AND MORTGAGE LENDING, 2601 NORTH LAMAR, SUITE 201, AUSTIN, TEXAS 78705. 1601-1667f . My dad saved me, I had all the money in bank tried to make the payment they said wait until the 1st and make them all at once then i call on the first and they say im in forclosure. I was in so much distress at the time and felt pressured to sign the modification and request it be signed by October 1, 2022. Change Your Mindset. The Bureaus action is part of a coordinated effort between the Bureau, a multistate group of state attorneys general, and state bank regulators. Nationstar Mortgage Agrees to $91M Settlement with the CFPB, Real Estate Settlement Procedures Act (RESPA), Social Security Disability application & appeal claim review, Abbott baby formula recall lawsuit investigation, Essential: Remember your cookie permission setting, Essential: Gather information you input into a contact forms, newsletter and other forms across all pages, Essential: Keep track of what you input in a shopping cart, Essential: Authenticate that you are logged into your user account, Essential: Remember language version you selected, Functionality: Remember social media settings, Functionality: Remember selected region and country, Analytics: Keep track of your visited pages and interaction taken, Analytics: Keep track about your location and region based on your IP number, Analytics: Keep track of the time spent on each page, Analytics: Increase the data quality of the statistics functions, Advertising: Tailor information and advertising to your interests based on e.g. A proposed class action alleges Nationstar Mortgage LLCaka Mr. Cooperhas intentionally mishandled California borrowers' foreclosure-related loan modification requests in an apparent effort to prevent the individuals from pursuing loss prevention options. What Happens at the End of a COVID Mortgage Forbearance? Your email address will not be published. The proposed judgment and order, if entered by the court, would require Nationstar to pay approximately $73 million in redress to more than 40,000 harmed borrowers. Though Class Members are not yet able to file claims, information about the case including the class action complaint and settlement agreement is available on the site. 119. On December 7, 2020, the Commissioner of the North Dakota Department of Financial Institutions joined other state and federal agencies in issuing a settlement agreement and consent order against Nationstar Mortgage LLC, d/b/a Mr. Cooper. he agreed to make the payment and I would start in May. Nationstar serviced Warner's home loan and was the first mortgagee on his homeowners Insurance Policy insured by State Farm. Terms and Conditions. I cant say enough good things about Diane. State Attorneys General will take action against any lending company that breaks the law and treats borrowers unfairly." . and how the errors were resolved; Correct any errors and communicate the resolution to borrowers; and. On December 7, 2020, the Consumer Financial Protection Bureau (CFPB) filed a complaint and proposed stipulated judgment and order against Nationstar Mortgage, LLC, doing business as Mr. Cooper. Money Personality Quiz and Test. A copy of the . My question given all the complaints all over the internet why are they still allowed to be in business? My only regret is that I didnt find Diane sooner. This is after my husband died and was having to deal with them constantly. Please help me. Mr. Cooper, also known as Nationstar Mortgage, is facing a class action lawsuit lodged by a North Carolina resident for allegedly making several unauthorized withdrawals from her bank account and failing to adequately investigate or fix the issue. Never going to happen they are cruel had to have Freddie Mac actually call do the mod people because there was always one paper they didnt have I stayed on phone with woman to make sure she got my email she said she did they then in two weeks told me they still hadnt received it and now was over time limit and would have to start at beginning. Mortgage servicers are entrusted with handling significant financial transactions for millions of Americans, including struggling homeowners. Somehow my loan ended up with nationstar. The Honest and Unvarnished Truth. The are the worst, slimmest, corrupt mortgage company on this planet. Plaintiffs filed their Third Amended Complaint on May 7, 2020. According to the lawsuit, in 2012, the companythen operating as Nationstarbegan purchasing mortgage servicing portfolios from competitors, which allowed it to quickly grow into the nation's largest non-bank . Specifically, the Bureau alleges that between January 2012 and January 1, 2016, in numerous instances Nationstar failed to identify loans on its systems that had pending loss-mitigation applications or trial-modification plans, and as a result failed to honor borrowers loan modification agreements. Attorney Advertising. The clerk was loud in speech, becoming and becoming upset with my questions in regards to lowering my rates. 2 Case: 15-11383 Date Filed: 04/28/2016 Page: 3 of 3 . The way she handled my not typical circumstances was amazing. I have signed the papers 6 times and theyve lied and said they werent signed properly, they came in late, they werent formatted properly (which they were the ones that sent us the forms.) My loan was transferred to them 3/4/19 and so far I had them fail to pay home owners insurance from escrow in July 2019 so it lapsed and I paid it myself as well as with property taxes being paid at the last minute. They held my payment pending for 15 days some months trying to wait for my bank account to hit negative from another random bill. I hope someone will contact me before I get pushed over the edge again. Pia McAdams, a class member, objected to the settlement, arguing that the It would also require Nationstar to pay a $1.5 million civil penalty to the Bureau. I tried to get a loan mod, i emailed, faxed, us mailed, the paperwork, approx 10 each, the claim they never received it. Mrs. Renfroe alleges that after this transfer, her monthly payments increased . Nationstar allegedly failed to timely disburse borrowers tax payments from their escrow accounts and failed to properly conduct escrow analyses for borrowers during their Chapter 13 bankruptcy proceedings. 131. I cant deal with this anymore! In response, Dorvil admitted default and . administrator or law firm. On Friday, March 29, 2019, Estavillo Law Group, PC appeared in Contra Costa County Superior Court, before Hon. I just got a loan modification from Mr Cooper who has doubled my property taxes. SENT THE INFORMATION THEY ASKED OVER AND OVER KEEP SAYING I DIDNT SEND IT. A proposed class action alleges Nationstar Mortgage has withdrawn without authorization "enormous sums" of money from borrowers' bank accounts by way of scores of improper debit requests that the company should have been able to identify. According to the complaint Nationstar : (1) failed to identify thousands of loans with existing in-flight modifications and, as a result, failed to recognize some transferred loans with pending loss mitigation applications or trial modification plans, or failed to identify and honor other borrowers loan modification agreements; (2) foreclosed on borrowers to whom it had promised foreclosure holds while they applied for loss mitigation relief; (3) improperly increased, CFPB and State Attorneys General Settle with Nationstar, aka Mr. Cooper, accused of unfair and deceptive practices, Consumer Financial Protection Bureau (Bureau). The Bureaus and States proposed judgments and orders, if entered by the court, will yield nearly $85 million in recoveries for consumers to date and over $6 million more in fees and penalties. Nationstar is the country's fourth-largest mortgage servicer. I am a disabled vet like, im on a fixed income and Ive had no problems paying my bills for 10 years. In other instances, as stated in the complaint, borrowers met the criteria for permanent modifications of their mortgages but the company increased payments wrongfully, resulting in foreclosure on some borrowers. If you are a California resident who has had a dispute in the last year with one of these banks over billing, past due payments, foreclosure or interest rates, you may be eligible to join a free class action lawsuit investigation: document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Top Class Actions is a Proud Member of the American Bar Association, Various Trademarks held by their respective owners. This website is not intended for viewing or usage by European Union citizens. 22. I have reported nationstar to everyone for many years and I cant believe something has not been done.they have committed so many fraudulent practices it is unbelievable.they destroyed my life. My mortgage went up and the payments went up even though I keep my payments every month on time and the same amount every month. As a retired law professor, she believes in offering everyone, not just her clients, advice about bankruptcy and Arizona foreclosure laws. As mortgage servicing may become a more scrutinized area because of the pandemic and the potential for consumer harm, credit unions may want to review the proposed judgment and the complaint to see whether their policies and procedures are designed to comply with the requirements that led to the complaint and settlement. . Save my name, email, and website in this browser for the next time I comment. please contact the press office. https://topclassactions.com/wp-admin/admin-ajax.php. Failing to identify service transferred loans in existing trial modifications or transferred loans in the middle of the modification process, resulting in borrowers receiving permanent loan modifications only after unwarranted delays or being wrongfully denied for permanent modifications; Moving forward with foreclosure and even conducting foreclosure sales after borrowers had submitted workout packages for loan modifications in response to correspondence from Nationstar allegedly representing that foreclosure would be stayed while the workout packages were being reviewed or before any appeal had run its course; Increasing permanent modification payments after the completion of a trial plan, a practice that was not permitted under the terms of modification programs being used; Failing to disburse tax payments from escrow accounts in a timely manner, resulting in unnecessary penalties; Failing to conduct annual escrow account analyses for loans subject to escrow that were in bankruptcy, leading to shortages and deficiencies that neither the bankruptcy court nor the borrowers could anticipate: Failing to cancel and terminateprivate mortgage insurance (PMI) as required by the, Implement policies, processes and controls designed to. Now to far behind to catch up. Click Change Settings if you want to tailor the use of your cookies. ; Have sufficient personnel to review and resolve consumer complaints, notices or error, etc. It is still happening with this company. Mr. Cooper, the nation's largest nonbank servicer of mortgage loans, will refund customers nearly $90 million and pay a civil penalty of more than $6.5 million to settle a lawsuit claiming it. Nationstar Mortgage, LLC No. The proposed judgment and order, which the court entered on December 8, 2020, requires Nationstar to pay approximately $73 million in redress to more than 40,000 harmed borrowers. He is joined by 49 other Attorneys General, the District of Columbia, and other state and federal agencies. I dont know what the 1058 was. STANDARD On a motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6) , all allegations of material fact must be accepted as true and construed . Subscribe to our RSS feed to get the latest content in your reader. The Bureau alleges that Nationstar violated multiple Federal consumer financial laws, causing substantial harm to the borrowers whose mortgage loans it serviced, including distressed homeowners. The $91,255,843 settlement will allot over $22 million in consumer remediation, in addition to the $62 million in remediation that was previously provided to consumer borrowers. 6 Order on Notice of Mortgage Payment Change, BK-ECF No. They drove me to suicidal ideation and I was on the phone speaking with someone from HUD that I thought could help me and she called 911 and the Sheriffs office sent a police officer and EMS to my house and took me to the Psych Ward. ; Document each error alleged in consumer complaints, notices of error, etc. They said the VA would not allow me to assume that. In Connecticut, the settlement affects 685 loans. Counts IV through XI are made against both Defendants, with the exception of Count VI which alleges violation of California's Rosenthal Act against Nationstar only. It also requires Nationstar to pay a $1.5 million civil penalty to the Bureau. According to the complaint Nationstar : (1) failed to identify thousands of loans with existing in-flight modifications and, as a result, failed to recognize some transferred loans with pending loss mitigation applications or trial modification plans, or failed to identify and honor other borrowers loan modification agreements; (2) foreclosed on borrowers to whom it had promised foreclosure holds while they applied for loss mitigation relief; (3) improperly increased