Leonardo Arias v. Elite Mortgage Group, Inc

108 A.3d 21, 439 N.J. Super. 273
CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 23, 2015
DocketA-4599-12T1
StatusPublished
Cited by16 cases

This text of 108 A.3d 21 (Leonardo Arias v. Elite Mortgage Group, Inc) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leonardo Arias v. Elite Mortgage Group, Inc, 108 A.3d 21, 439 N.J. Super. 273 (N.J. Ct. App. 2015).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4599-12T1

LEONARDO ARIAS and RUTH M. PADILLA, APPROVED FOR PUBLICATION Plaintiff-Appellants, January 23, 2015 v. APPELLATE DIVISION ELITE MORTGAGE GROUP, INC., RAY SALAZAR, W.M.C. MORTGAGE, CORPORATION, GE MONEY, GE CAPITAL, and DEUTSCHE BANK,

Defendants,

and

BANK OF AMERICA, N.A., s/h/a BANK OF AMERICA HOME LOANS,

Defendant-Respondent. ______________________________

Submitted December 9, 2014 – Decided January 23, 2015

Before Judges Reisner, Koblitz and Haas.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-1316-12

Joseph A. Chang, attorney for appellants (Mr. Chang, of counsel and on the brief; Jeffrey Zajac, on the brief). Reed Smith LLP, attorneys for respondent (Aaron M. Bender, of counsel and on the brief).

The opinion of the court was delivered by

REISNER, P.J.A.D.

Plaintiffs Leonardo Arias and Ruth M. Padilla1 appeal from

an April 19, 2013 order granting summary judgment in favor of

defendant Bank of America, N.A. (the bank).

To summarize, this case involves a dispute over a mortgage

securing a loan plaintiffs obtained to purchase a two-family

house.2 Plaintiffs claim that they had a contractual right to a

loan modification under the terms of the Trial Period Plan (TPP)

Agreement they signed pursuant to the federal Home Affordable

Mortgage Program (HAMP), and they assert that defendant breached

the contract. In the alternative, they contend that the bank

violated the covenant of good faith and fair dealing in denying

them the loan modification.

1 Plaintiffs, husband and wife, both signed the mortgage, but only Arias signed the note. We refer to Arias separately when discussing documents addressed only to him. 2 There is no dispute that plaintiffs live in one unit and rent out the other unit. At his deposition, Arias admitted that, even after plaintiffs entirely ceased paying the mortgage, they continued collecting between $1200 and $1800 per month from tenants. There is also no dispute that at some point plaintiffs stopped paying the taxes on the property, contrary to their obligation under the mortgage.

2 A-4599-12T1 The motion judge concluded that the TPP Agreement was not a

binding contract to modify the loan. The judge found that

plaintiffs, who are licensed real estate agents, understood that

the Agreement did not give them any such contractual right. The

judge reasoned that the bank was not required to provide

plaintiffs with a loan modification, based on its determination

that they did not qualify for one. The judge also concluded

that plaintiffs had "no viable cause of action" under the

federal HAMP guidelines, or based on the covenant of good faith

and fair dealing.

Our review of a summary judgment order is de novo, using

the same standard employed by the trial court. Gray v. Caldwell

Wood Prods., Inc., 425 N.J. Super. 496, 499-500 (App. Div.

2012). Having reviewed the record, we find there were no

material facts in dispute, and we agree with the trial judge

that defendant was entitled to judgment as a matter of law. See

Brill v. Guardian Life Ins. Co. of Am., 142 N.J. 520, 540

(1995). However, we arrive at that conclusion by a slightly

different route than the trial court.

I

Before reviewing the record and setting forth our own legal

analysis, we briefly discuss the most pertinent case law on

which the parties rely. In Wigod v. Wells Fargo Bank, N.A., 673

3 A-4599-12T1 F.3d 547 (7th Cir. 2012), the court cogently explained the

federal HAMP program, which was designed to address the

residential mortgage foreclosure crisis by encouraging lenders

to extend loan modifications to qualified mortgagors. Id. at

556-57; see Emergency Economic Stabilization Act of 2008, 12

U.S.C.A. § 5219(a)(1). The court concluded that, even though

there is no private cause of action under HAMP, a mortgagor may

nonetheless assert a common-law contract claim based on a bank's

failure to honor promises made in a HAMP Trial Period Plan

Agreement.3 The court reasoned that the terms of the TPP

Agreement must be construed as a promise by the bank that if the

debtor complies with its terms, she will be offered a loan

modification. The court thus described the TPP Agreement as

including "a unilateral offer to modify Wigod's loan conditioned

on her compliance with the stated terms of the bargain." Wigod,

supra, 673 F.3d at 562. The court reasoned that "a reasonable

person in Wigod's position would read the TPP as a definite

offer to provide a permanent modification that she could accept

so long as she satisfied the conditions." Ibid.; see also

3 HAMP provides financial incentives for mortgage servicers to assist debtors to obtain loan modifications. Wigod, supra, 673 F.3d at 556; see also Young v. Wells Fargo Bank, N.A., 717 F.3d 224, 228-29 (1st Cir. 2013). We note that defendant in the case before us acted as a loan servicer, but for simplicity, we refer to defendant as the "bank."

4 A-4599-12T1 Corvello v. Wells Fargo Bank, N.A., 728 F.3d 878, 883-85 (9th

Cir. 2013); Young, supra, 717 F.3d at 234; Bosque v. Wells Fargo

Bank, N.A., 762 F. Supp. 2d 342 (D. Mass. 2011); West v.

JPMorgan Chase Bank, N.A., 154 Cal. Rptr. 3d 285 (Ct. App.),

rev. denied, 2013 Cal. LEXIS 5801 (July 10, 2013).

The court rejected the bank's argument that there was no

consideration for a promise to grant a loan modification because

the debtor was merely making a partial payment of a debt she

already owed. Wigod, supra, 673 F.2d at 564. The court pointed

out that in entering into the TPP Agreement, the debtor agreed

to provide additional financial information and agreed to attend

debt counseling if asked to do so. Ibid.4; see Seaview

Orthopaedics v. Nat'l Healthcare Res., Inc., 366 N.J. Super.

501, 508-09 (App. Div. 2004) (discussing adequacy of

consideration). The court also rejected the bank's argument

that the TPP Agreement left to the bank's sole and unbridled

discretion whether to actually send the debtor a loan

modification agreement once she complied with her obligations

under the TPP Agreement. The court found that such an

4 In a related point concerning plaintiff's promissory estoppel claim, the court noted she had refrained from other legal options she might have pursued, including filing for bankruptcy or selling her home. Id. at 566.

5 A-4599-12T1 interpretation would render the TPP Agreement illusory. Wigod,

supra, 673 F.3d at 563.

While there are no reported New Jersey cases addressing the

contractual status of a TPP Agreement, case law suggests that an

agreement that purports to bind a debtor to make payments while

leaving the mortgage company free to give her nothing in return

might violate the New Jersey Consumer Fraud Act (CFA), N.J.S.A.

56:8-1 to -195. See Gonzalez v. Wilshire Credit Corp., 207 N.J.

557, 576-78 (2011). Gonzalez involved a different factual

scenario from the one in this case. However, in Gonzalez the

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