VAN BRUNT v. WELLS FARGO BANK, N.A.

CourtDistrict Court, D. New Jersey
DecidedSeptember 21, 2022
Docket3:19-cv-00170
StatusUnknown

This text of VAN BRUNT v. WELLS FARGO BANK, N.A. (VAN BRUNT v. WELLS FARGO BANK, N.A.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VAN BRUNT v. WELLS FARGO BANK, N.A., (D.N.J. 2022).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

DAWN VAN BRUNT,

Plaintiff, Civil Action No. 19-170 (ZNQ) (TJB)

v. OPINION

WELLS FARGO BANK, N.A.,

Defendant.

QURAISHI, District Judge THIS MATTER comes before the Court upon a Motion to Dismiss the Second Amended Complaint (“the Motion”) by Defendant Wells Fargo Bank, N.A. (“Defendant”) pursuant to Fed. R. Civ. P. 12(b)(6) and 9(b). (ECF No. 61.) Defendant filed a Brief in Support of its motion. (Moving Br., ECF No. 61-1). Plaintiff Dawn Van Brunt (“Plaintiff”) opposed the motion. (Opp’n Br., ECF No. 62.) Defendant filed a reply. (Reply Br., ECF No. 63.) The Court has carefully considered the parties’ submissions and decides the Motion without oral argument pursuant to Federal Rule of Civil Procedure1 78 and Local Civil Rule 78.1. For the reasons set forth below, the Court will GRANT the Motion.

1 For the sake of brevity, all references herein to “Rule” will be to the Federal Rules of Civil Procedure. I. FACTUAL BACKGROUND 2 Plaintiff was the owner of residential real property, commonly known as 4101 Dairy Court, Freehold, NJ (“the Property”) which she occupied as her primary residence until the Sheriff removed Plaintiff and occupying residents from the property. (Second Am. Compl. ¶ 1, ECF No.

48). From approximately July 12, 2007 to July 11, 2017, Defendant was the servicer of a note executed by Plaintiff and of a mortgage on the property securing such note (collectively, “the Loan”), insured by the Federal Housing Authority (the “FHA”). (Id. ¶ 2.) Defendant is the nation’s largest provider of residential mortgages, servicing home mortgage loans nationwide. (Id. ¶ 9.) Defendant utilizes uniform and standard loan servicing, modification, and foreclosure practices nationwide, mostly reliant upon automated processes, systems, and tools. (Id. ¶ 13). Wells Fargo is a pre-approved lender who qualifies for FHA mortgage insurance and must comply with the Department of Housing and Urban Development (“HUD”) regulations. (Id. ¶ 18). In 2008, the government began the Troubles Asset Relief Program (“TARP”). (Id. ¶ 20.) Defendant received about $25 billion in TARP funds. (Id. ¶ 21.) In return, Wells Fargo is required

to comply with certain regulations. (Id. ¶¶ 21–23). Additionally, Wells Fargo is required to review defaulted loans for modification eligibility prior to proceeding with a foreclosure action. (Id. ¶ 24). Wells Fargo is required to offer all eligible-defaulted borrowers a loan modification. (Id.) Wells Fargo is required to take a number of specific and non-discretionary steps to determine a consumer’s eligibility for modification. (Id.) If the borrower is approved and the modified loan would be more profitable than the non-modified loan, Defendant is required to offer a trial period plan modification. (Id.)

2 For purposes of this motion, the Court will take all facts alleged in the Amended Complaint as true. Kulwicki v. Dawson, 969 F.2d 1454, 1462 (3d Cir. 1992). To request a loan modification, FHA regulations require each borrower to submit various applications and forms. (Id. ¶ 25.) If the borrower is eligible for any mandatory modifications, Defendant is required to extend the trial period. (Id. ¶¶ 25, 27.) In 2010, the Office of the Comptroller of the Currency (“OCC”) discovered multiple

deficiencies and unsafe and unsound practices in Defendant’s residential mortgage servicing, modification, and foreclosure programs. (Id. ¶ 29.) The OCC determined that Defendant failed to oversee, audit, and test its foreclosure and modification tools and practices. (Id. ¶ 29.) As a result, Defendant entered into two consent orders, agreeing to form compliance committees and programs subject to the oversight of the OCC. (Id. ¶ 31.) However, Defendant failed to remedy the deficiencies and unsafe and unsound practices as identified by the OCC and failed to adopt adequate oversight programs. (Id. ¶ 32.) Defendant additionally failed to detect and/or correct systemwide servicing, modification, and foreclosure process errors. (Id. ¶ 32.) In 2015, the OCC again determined that Defendant was continually failing to adequately oversee, audit, and test its servicing, modification, and foreclosure practices for compliance. (Id.

¶ 33.) In early 2018, the OCC found that Defendant’s deficiencies and compliance failures constituted reckless and unsafe or unsound practices in violation of federal law and that Defendant failed to implement and maintain an adequate compliance risk management program. (Id. ¶ 34.) As a result, Defendant entered a consent cease and desist order with the OCC, again agreeing to adopt system-wide compliance programs and oversight. (Id. ¶ 35). The Federal Reserve also issued a consent cease and desist order in early 2018 restricting Defendant’s growth until governance, oversight, risk management, auditing, and testing, was improved. (Id. ¶ 36.) As a result of the OCC’s investigations and resulting consent orders, Defendant was on notice of serious errors, deficiencies, and unsafe and unsound practices in its loan servicing, modification, and foreclosure processes and practices from 2010 through the present. (Id. ¶ 37.) The deficiencies and unsafe and unsound practices resulted in systematic automated

calculation errors that affected borrowers. (Id. ¶ 38.) From 2010 through 2019, Defendant utilized automated mortgage loan modification underwriting tools to determine which default borrowers were qualified for a mortgage loan modification or repayment plan. (Id. ¶ 38.) By its own admissions, Defendant failed to test and audit its automated mortgage loan modification underwriting tool. (Id. ¶ 40.) As a result, Defendant wrongfully failed to approve hundreds of borrowers for appropriate mortgage loan modifications and/or repayment plants. (Id. ¶ 41.) As a result of its continued failure to implement adequate oversight, auditing, and test controls, Defendant failed to timely identify a number of automated calculation errors in its mortgage software. (Id. ¶ 42.) The OCC reported that between March of 2013 and October of 2014, an unidentified error

caused Defendant to fail to offer modifications to 184 borrowers who were entitled to modification trial period plans. (Id. ¶ 43.) As a part of Defendant’s parent company’s quarterly report, it was revealed that an automated calculation error caused Defendant to wrongfully deny loan modifications and resulted in hundreds of foreclosures of residential mortgage loans in default between April 13, 2010 and October 20, 2015. (Id. ¶ 45.) Loan modification applications under FHA loans, like Plaintiff’s, were decided using the SLoaD tool. (Id. ¶ 46.) Defendant discovered that it had wrongfully denied mortgage modifications for loans analyzed in SLoaD from 2010 until 2018. (Id. ¶ 59.) In total, Defendant wrongfully denied loan modifications to 824 borrowers and caused over 500 of them to lose their homes. (Id.) In late 2018 and early 2019, Defendant began sending form letters to customers affected by the calculation error. (Id. ¶ 60.) The letters typically included a check and informed customers

if they were not satisfied with the amount, they could consider mediation through a third-party mediator. (Id.) In 2009, Plaintiff experienced financial difficulties and defaulted on the Loan. (Id. ¶ 61.) On or about August 19, 2011, non-party The Strickland Farm Condominium Association, Inc. (the “COA”) commenced an action against Plaintiff in the Superior Court of New Jersey, Special Civil Part, captioned The Strickland Farm Condominium Association, Inc. v.

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