WAKE UP AMERICA YOU HAVE BEEN SCAMMED!
http://www.ferndale.wednet.edu/drupal/sites/default/files/APAEffectsofHomelessness.pdf
SCAM 1: Push loose credit, including credit cards to the young 18 year olds as soon as they hit 18. Give out use me now pay me latter funds for education. Tell the people all is great and dig themselves deep into dept. Push liar loans, refinancing, and predatory loans on all homeowners. Harm the economy so homeowners refinance attempting to save their houses, and businesses, giving homeowners concealed predatory loans with the intent to default and steal the homes.
SCAM 2: While doing scam one, set politicians and judges in place to deregulate good law protecting the consumers and block justice, block due process.
GLASS STEAGALL ACT http://en.wikipedia.org/wiki/Glass%E2%80%93Steagall_Act
DEREGULATION OF THE GLASS STEAGALL ACT! http://wiki.answers.com/Q/Who_Deregulated_the_Glass-Steagall_Act
http://www.foreclosurehamlet.org/profiles/blogs/video-and-transcript-of-a-washington-judge-taking-the-fifth-and This judge boasting he is an advocate for the banks.
http://api.ning.com/files/xuMwKMTkGS1HUngBQqcIHi1h5CottkzqisQokVyZb6ZkQcnD0vHzrAUT-f1Xa0huEcXhmf*QBRbgibz4jH5ZLuk2ZjVb3Z8q/VerbatimReportofProceedings.pdf
THE BANKS SET UP THE HOMEOWNERS WITH FORECLOSURE TRUSTEES LIKE RECONTRUST AND NW TRUSTEES THAT ARE SUPPOSED TO BY CPA LAW AND DEED OF TRUST LAW TO BE FAIR DEALING WITH BOTH LENDER AND BORROWER THAT ARE EITHER SOLELY OWNED BY THE BANKS LIKE RECONTRUST, OR WORKING FOR THE BANKS AND CONSULTING WITH BANK LAWYERS LIKE NW TRUSTEE’S. USING NW TRUSTEE EMPLOYEES THAT SHOULD KNOW BETTER TO PRODUCE FALSE AFFIDAVITS ON THE COUNTY RECORDS AND USE IN THE COURT SYSTEM COMMITTING FRAUD UPON THE COURT. http://www.foreclosurehamlet.org/profiles/blogs/deposition-jeff-stenman-northwest-trustee-services
AND THE CLINCHER JEFF STENMAN EMPLOYEE WORKING FOR NW TRUSTEES, APPEARS TO ADMIT NW TRUSTEES WORKS FOR THE BANKS AND CONSULT WITH BANK LAWYER FIRMS, AND HAS A BANK LAWYER FIRM IN HOUSE NOW.
Washington is a show me the note state but the judges block the homeowner from demands to show us the note! Humbug us that we took out a loan we have to pay it to anyone including a fraud.
Washington is a “show me the note” state. Koppler v. Bugge, 168 Wash. 182, 184-85, 11 P.2d 236 (1932). See also Elene-Arp v. Fed. Home Fin. Agency, 2013 U.S. Dist. LEXIS 65358 at 11(W.D. Wa. 2013); Beaton v. JPMorgan Chase Bank N.A., 2013 U.S. Dist. LEXIS 42806 at *16 (W.D. Wa.2013); Knecht v. Fid. Nat’l Title Ins. Co., 2013 U.S. Dist. LEXIS 38814 at *01-11 (2013); Washington’s Supreme Court mandated that anyone paying a purported holder of a mortgage has a “duty” to demand, “show me the note” or suffer the consequences if that claimant is bogus. This policy emerged when fraudulent securitized mortgages were freely sold prior to 1929, and the devastating effects thereof were discovered in the early 1930’s. The Washington Supreme Court ruled:
It appears most of the federal judges in Washington and multiple states are biased, telling us if you took out a loan you owe it to anyone, someone, you are guilty without due process, and can be left owing it to the real party if they show up, but you must pay anyone including a fraud, even though we have a duty to demand proof of who the real party is, even though the deed of trust tells us we have a duty to protect our title, therefore we will be guilty of owing the real party or another fraud if we are challenged again. A process worse than what is allowed for a murderer a drug dealer or a sex offender. We are guilty without due process. The courts block the borrowers from their demands to show the authentic note by forcing the borrowers to accept a declaration of lost note affidavit. Counterfiets of millions of notes allonges and affidavits by David Stern and Lorraine Brown, and the concealed transcript [In the 2007 (pre-crisis) certified Texas Supreme Court transcript of the “Meeting on Foreclosure Rules”, Michael Barrett (now deceased), of the Texas foreclosure-mill Barrett-Burke, Castle, Daffin & Frappier, admits that the mandated paperwork required to lawfully execute a foreclosure simply does not exist in 90% of the cases:]
NO VICTIMS? WHAT THE ..
Suicides, homicides, blocked justice, clouded titles, stolen property, homeless Americans, fraud upon the court, filed fraud affidavits in county records and court rooms and NO VICTIMS?
http://www.stellionata.com/in-the-news/38-headlines/7662-120509-jpmc-v-waisome-lawrence-nardi-deposition Chase reply to Deutsche bank ;John Kemp stating the notes were never transferred from Countrywide to BOA or anyone.http://4closurefraud.org/2010/11/22/john-t-kemp-v-countrywide-home-loans-countrywide-never-transferred-notes/and more. . See Deutsche Bank V FDIC, Chase WAMU
Chase claims they are not liable due to they never purchased the notes. Deutsche claims FDIC, Chase. And WAMU never transferred the notes to the trust timely, therefore they are faulty. NO GOOD!
August 21, 2012
Confirming, under oath and in print what we already suspected: there is no schedule of mortgage loans evidencing what JPM allegedly “purchased” from the FDIC in connection with the failure of WaMu. This is from the sworn deposition testimony of Lawrence Nardi, the operations unit manager and a mortgage officer for JPM, who was previously with WaMu and was picked up by JPM after WaMu’s failure. The 330 page deposition was taken by counsel for the homeowner on May 9, 2012 in the matter of JPMorgan Chase Bank, N.A. as successor in interest to Washington Mutual Bank v. Waisome, Florida 5th Judicial Circuit Case No. 2009-CA-005717.
Here is the question and the answer:
Q: (page 57, beginning at line 19): Okay. The — are you aware of any type of schedule of loans that would have been created to represent the — either the loans that were asset loans or the loans that were serviced by WAMU? Are you — was the — do you know if there is a schedule or database of loans like that?
A: (page 58, beginning at line 1): I know that there was a schedule contemplated in certain documents related to the purchase. That schedule has never materialized in any form. We’ve looked for it in countless other cases. We’ve never been able to produce it in any previous cases. It would certainly be a wonderful thing to have, but it’s — as far as I know, it doesn’t exist, although it was — it was contemplated in the documents.
As we all know, JPM has also stated, in a Federal Court filing, that it is NOT the “successor in interest to WaMu.” However, the deposition testimony gets even better as the day went on:
Q: (beginning at page 260, line 18): Have you ever in your duties of being a loan analyst — a loan operations specialist, have you ever seen an FDIC bill of sale or a receiver’s deed or an assignment of mortgage or an allonge?
A: (page 260, beginning at line 23): For loans, I’m assuming you’re taling about the WaMu loan that was subject to the purchase here.
Q: (page 261, line 1): Right.
A: (page 261, beginning at line 2): No there is no assignments of mortgage. There’s no allonges. There’s no — in the thousands of loans that I have come into contact with that were a part of this purchase, I’ve never once seen an assignment of mortgage. There is simply not — they don’t exist. Or allonges or anything transferring ownership from WAMU to Chase, in other words. Specifically, endorsements and things like that.
So, JPM allegedly “purchased” mortgage loans from the FDIC out of the WaMu failure, but there is no schedule of what loans were purchased, no assignments, no allonges, no endorsements, nothing that transferred ownership of the loans from WaMu to Chase. However, as we all know, JPM goes around the country touting that it is the “successor in interest to WaMu” (which it has admitted in Federal Court that it is not) and relies on the amorphous “FDIC Affidavit” which, as far as what the “Affidavit” is proffered for, is directly contradicted by the sworn deposition testimony of JPM’s authorized representative WHO WAS FORMERLY WITH WAMU AND WAS PICKED UP BY JPM.
Fraud on the courts, anyone?
Jeff Barnes, Esq., www.ForeclosureDefenseNationwide.com
“Common practice to destroy notes” http://livinglies.wordpress.com/2010/10/04/fubar-mortgage-behavior-florida-banks-destroyed-notes-others-never-transferred-them/
http://stopforeclosurefraud.com/2013/08/29/kabooom-declaration-of-stehrenberger-similar-to-kelley-v-jpmc-affidavit-of-karyn-armstrong-wamu-shredded-original-notes/
http://stopforeclosurefraud.com/2013/08/28/in-the-matter-of-kelley-v-jp-morgan-chase-bank-adv-proc-10-05245-ch-11-08-55305-canb-destruction-of-collateral-files-the-affidavit-of-karyn-
HERE WE GO AGAIN! OCWEN ADMITS ON PAPER THEY DON’T KNOW WHO OWNS THE LOANS. I DO “THEY DON”T” THE LOANS ARE UNENFORCEABLE! YA THINK? http://foreclosuredefensenationwide.com/
What would happen if we all send our complaints and the abuse of the foreclosures companies manipulating fraud defaults to HUD? Showing HUD how many loans are really in (fruad) closure? Seems like the banks are hiding this from them. Is the reason your property taxes and insurances are being paid, and the reason the banks are stealing the houses to most likely quiet title them resell and never mention to HUD they were in foreclosure. WANT TO MAKE BETS ON THIS?
http://mattweidnerlaw.com/bombshell-americans-banks-may-liable-57-billion-new-foreclosure-losses/
SCAM [losing count]: Set up MERS to skirt around unmovable loans. SEE ATTORNEY PRATT FOR MERS, STATING MERS WAS SOLELY SET IN PLACE BY THE BANKS IN THE 1990’S AFTER THE SAVINGS AND LOAN CRIMES TO MOVE UNMOVABLE LOANS! Pratt Boast MERS helped to move over a million unmovable loans [WHY WERE THEY UNMOVABLE? WAS PRATT BOASTING OF A HUGE CRIME TAKEN PLACE? http://stopforeclosurefraud.com/2012/03/15/video-oral-arguments-washington-supreme-court-bain-v-bain-v-mortgage-electronic-registration-sys-et-al-and-selkowitz-v-litton-loan-servicing-lp-et-al/
AND…. the Setting up of Fannie and Freddie as a shell game to cover up the Securities Pool fraud. Fannie and Freddie with a policy in place to never except notes: http://www.msfraud.org/articles/welcome-to-fannie-and-freddies-mortgage-shell-game.pdf HOW CAN FREDDIE AND FANNIE OWN ANYTHING IF THEY DON’T HAVE THE NOTES? WHY DID THEY NOT WANT THE NOTES?
https://libertyroadmedia.wordpress.com/2013/07/11/fannie-mae-by-its-own-admission-owns-nothing/
http://deadlyclear.wordpress.com/2013/09/25/welcome-to-freddie-and-fannies-mortgage-shell-game/
http://4closurefraud.org/2013/01/12/in-wells-fargos-own-words-there-is-no-lender-in-securitization/
http://livinglies.wordpress.com/2009/03/30/how-securitization-nullifies-the-original-note-and-mortgage-the-originating-lender-is-paid-in-full/
http://victoryoverchase.blogspot.com/2013/01/there-is-no-lender-in-securitization.html
http://www.scribd.com/doc/36675721/Explanation-of-Securitization
SCRIBE -there-is-no-lender-in-securitization/
©2012 Wells Fargo Bank, N.A. All rights reserved
Conduit loan servicing: Who’s who and what’s what?
The thing most borrowers fail to realize about conduit loans is that once a loan has been securitized, they are not working with a “lender” anymore. The loans are pooled into a securitization called a Real Estate Mortgage Investment Conduit (REMIC). The REMIC is a trust and it has no lenders, only fiduciaries of the “certificate holders
Nothing has changed since 1970s Saving and Loan crimes. Just ramped up! See http://deadlyclear.files.wordpress.com/2013/04/no-e2808200-2392-resolution-trust-corporation-v.pdf
QUESTIONS TO ASK ARE If you look up GAAP accounting WILL YOU FIND some interesting information that they are going to be changing to IFRS which is a more international system and appears to be more transparent. DOES The GAAP accounting in securitization actually creates a entries on their books that the borrower loaned them money… So it doesn’t appear that through their accounting methods we actually got a loan. It is more of a paper trick?
How securitization nullifies the original note and mortgage. The Originating Lender is PAID IN FULL
SCAM 4: Fully explained in
Wall Street and the Financial Crisis: Anatomy of a Financial Collapse is a report on the financial crisis of 2007–2008 issued on April 13, 2011 by the United States Senate Permanent Subcommittee on Investigations. The 639 page report was issued under the chairmanship of Senators Carl Levin and Tom Coburn, and is colloquially known as the Levin-Coburn Report. After conducting “over 150 interviews and depositions, consulting with dozens of government, academic, and private sector experts” found that “the crisis was not a natural disaster, but the result of high risk, complex financial products, undisclosed conflicts of interest; and the failure of regulators, the credit rating agencies, and the market itself to rein in the excesses of Wall Street.” [1] In an interview, Senator Levin noted that “The overwhelming evidence is that those institutions deceived their clients and deceived the public, and they were aided and abetted by deferential regulators and credit ratings agencies who had conflicts of interest.”[2] By the end of their two-year investigation, the staff amassed 56 million pages of memos, documents, prospectuses and e-mails.[3] The report, which contains 2,800 footnotes and references thousands of internal documents [4] focused on four major areas of concern regarding the failure of the financial system: high risk mortgage lending, failure of regulators to stop such practices, inflated credit ratings, and abuses of the system by investment banks. The Report also issued several recommendations for future action regarding each of these categories.
SCAM 5: TARP to bail out the banks and not the people.
SCAM 6: HAMP TO FOAM THE RUNWAY for the banks to slowly manipulate the theft of the houses, and to leave the homeowners homeless. http://washingtonexaminer.com/video-geithner-sacrificed-homeowners-to-foam-the-runway-for-the-banks/article/2502982
SCAM 7: MODIFICATION FRAUD: The HAMP carrot used to trick bate and switch the people into modification fraud to steal the maximum houses possible by trickery, telling the homeowners to get behind on the payments to get a mod with no intentions but to steal the house and manipulate defaults to foreclose on the people. http://deadlyclear.wordpress.com/2013/01/18/hamp-the-modification-scam-and-now-settlement-sham/ Look up mod whistleblowers. http://www.nakedcapitalism.com/2013/01/37705.html
http://www.salon.com/2013/06/18/bank_of_america_whistleblowers_bombshell_we_were_told_to_lie/ BOA employees were coerced to lie and were given gift cards to avoid approving modifications.
Go to your local city counsel members with friends and people who can testify to this crime against you and all of us. The move below is after the US V Banks settlement proving the crime is on going and never stopped, breaching the settlement.
http://www.youtube.com/watch?v=3nuPc9XvoOE
SCAM 8: DEADBEAT HOMEOWNER PROPAGANDA!
http://www.youtube.com/watch?v=Cmg-41xACTA
http://www.youtube.com/watch?v=SdRuZeKB3NM
[Once securitized there is no lender.]
APPARENT DISCRIMINATION?
SCAM 9: THE COVER UP
The Settlement that protects the banks and not the people. http://stopforeclosurefraud.com/2012/03/12/read-the-smoking-hot-banks-intentionally-and-thoroughly-violated-the-law-complaint-usa-vs-foreclosure-fraud/
Pretending to give justice to millions but only letting the banks off the hook and leaving the people in the same exact harm we have been enduring:
EXCERPT:
57. In the course of their conduct, management and oversight of loan
modifications in the plaintiff States, the Banks have engaged in a pattern of unfair
and deceptive practices.
58. The Banks’ failure to discharge their required loan modification
obligations, and related unfair and deceptive practices, include, but are not limited
to, the following:
a. failing to perform proper loan modification underwriting;
b. failing to gather or losing loan modification application
documentation and other paper work;
c. failing to provide adequate staffing to implement programs;
d. failing to adequately train staff responsible for loan
modifications;
e. failing to establish adequate processes for loan
modifications;
f. allowing borrowers to stay in trial modifications for
excessive time periods;
g. wrongfully denying modification applications;
h. failing to respond to borrower inquiries;
i. providing false or misleading information to consumers
while referring loans to foreclosure during the loan modification
application process;
j. providing false or misleading information to consumers
while initiating foreclosures where the borrower was in good faith actively
pursuing a loss mitigation alternative offered by the Bank;
k. providing false or misleading information to consumers
while scheduling and conducting foreclosure sales during the loan
application process and during trial loan modification periods;
l. misrepresenting to borrowers that loss mitigation programs
would provide relief from the initiation of foreclosure or further
foreclosure efforts;
m. failing to provide accurate and timely information to
borrowers who are in need of, and eligible for, loss mitigation services,
including loan modifications;
n. falsely advising borrowers that they must be at least 60
days delinquent in loan payments to qualify for a loan modification;
o. miscalculating borrowers’ eligibility for loan modification
programs and improperly denying loan modification relief to eligible
borrowers;
p. misleading borrowers by representing that loan
modification applications will be handled promptly when Banks regularly
fail to act on loan modifications in a timely manner;
q. failing to properly process borrowers’ applications for loan
modifications, including failing to account for documents submitted by
borrowers and failing to respond to borrowers’ reasonable requests for
information and assistance;
r. failing to assign adequate staff resources with sufficient
training to handle the demand from distressed borrowers; and
s. misleading borrowers by providing false or deceptive
reasons for denial of loan modifications.
3. Wrongful Conduct Related to Foreclosures
[…]
Lynn Szymoniaks case is sealed from the public! Look up newly unsealed case!
And then there is this testimony and settlement concealed from the public by all AG’s! Everyone of the AG’s at the time, never exposed this settlement.
ANOTHER TESTIMONY IN THIS ARTICLE OF AT LEAST 90 PERCENT OF MORTGAGES HAVE NO PAPERWORK TO FORECLOSE ON.
|
Please accept this email as my request for information pursuant to the Texas Public Information Act (“TPIA”) for the following information:
1. Copies of the quarterly reports detailing the efforts of LPS to fulfill the obligations placed upon it as described in the Section titled: “IV. 4.1 Remediation to Homeowners”, as part of the “Agreed Final Judgment and Injunction” in 2013DCV-0413, “The State of Texas v. Lender Processing Services, Inc.”;
2. Proof of payment by LPS to The State of Texas of $5,755.050 as a settlement in this matter;
3. Proof of payment of 7 million dollars in attorney’s fees awarded to the State of Texas, as well as $483,333.00 as additional attorney fees.
Provide me with the copying cost and I will see that it is paid expeditiously.
Richard A. Roman, Esq.
Texas has known forged and false documents have been used to steal homes from its own residents dating back to the 1990s, but until lately, the state didn’t seem bothered by all these state jail felonies being committed throughout the state en masse.
In the 2007 (pre-crisis) certified Texas Supreme Court transcript of the “Meeting on Foreclosure Rules”, Michael Barrett (now deceased), of the Texas foreclosure-mill Barrett-Burke, Castle, Daffin & Frappier, admits that the mandated paperwork required to lawfully execute a foreclosure simply does not exist in 90% of the cases:
“So finding a document that says, “I am the owner and holder, and I thereby grant to the servicer the right to foreclose in my name” is an impossibility in 90 percent of the cases.” (transcript page 27, line 16)
The remedy for when, as Mr. Barrett confirmed “There really isn’t such a document” (Page 27, line 8), was revealed by Judge Bruce Priddy (See State of Texas v. Judge Priddy D-1-GV-08-002311) when he added:
“They just create one for the most part sometimes, and the servicer signs it themselves saying that it’s been transferred to whatever entity they name as applicant”. (page 28, line 10)
First American Title added:
“Well, the other problem — Judge, this is Tim Redding. The other problem that I see — and, Tommy, you and I talk about it regularly – that we have a bunch of servicers that are corporations or trusts attempting to foreclose on behalf of other trusts using a power of attorney, and I don’t think that’s really proper. I mean, we all kind of turn a blind eye to it, but I think that’s an issue that’s out there that somebody could use to potentially attack a foreclosure.” (p. 33, line 5)
According to Mr. Barrett’s statements; that means 9 of every 10 foreclosure/eviction cases filed in Texas likely contain uttered documents, a/k/a state jail felonies. That is absolutely stunning! Many people might assume the Texas district attorneys, U.S. Attorneys, FBI, IRS, Texas Rangers, Secret Service, etc. would be investigating this multi-billion dollar criminal enterprise that has been operating in the state for close to twenty-years. But it appears the El Paso AG office is the lone ranger against this massive land grab and transference of wealth, and they don’t seem to want anyone to know. We applaud anyone who goes toe to toe with the banks, but where is the stipulated ‘remediation to homeowners’?
The case against Countrywide
Another obscure case discovered this week was filed in El Paso in 2009 by the State of Texas against Countrywide. The AG obtained an Agreed Final Judgment and Injunction on the same day the petition was filed. Among other things, the injunction places Restrictions on Initiation or Advancement of Foreclosure Process for Eligible Borrowers.
Here is the Docket, Petition and Agreed Judgment in State of Texas v. Countrywide Financial, Countrywide Home Loans and Full Spectrum Lending
Did the media not know about this case either?
I REPEAT STILL ON GOING! THIS VIDEO IS A YEAR AFTER THE SETTLMENT TO STOP THIS ON GOING CRIME!
http://www.youtube.com/watch?v=3nuPc9XvoOE
THE BANKS ADMIT THIRTY PERCENT OF THE HOMEOWNERS WERE NOT IN DEFAULT–A BANK PICKED NUMBER MOST LIKELY OVER NINETY PERCENT. NINETY PERCENT WITH NO PAPERWORK TO FORECLOSE AND MANIPULATED DEFAULTS USING ECONOMY TERRORISM AND HAMP CARROT TO DRAG INTO MODIFICATION HELL, BENT FOR FALSE DEFAULTS.
HERE WE GO AGAIN! OCWEN ADMITS ON PAPER THEY DON’T KNOW WHO OWN THE LOANS. I DO “THEY DON”T” THE LOANS ARE UNENFORCEABLE! YA THINK? http://foreclosuredefensenationwide.com/
What would happen if we all send our complaints and the abuse of the foreclosures companies manipulating fraud defaults to HUD? Showing HUD how many loans are really in (fruad) closure? Seems like the banks are hiding this from them. Is the reason your property taxes and insurances are being paid, and the reason the banks are stealing the houses to most likely quiet title them resell and never mention to HUD they were in foreclosure. WANT TO MAKE BETS ON THIS?
http://mattweidnerlaw.com/bombshell-americans-banks-may-liable-57-billion-new-foreclosure-losses/
SCAM [who’s counting anymore?] Promontory and the rest used to cover up the fraud and leave the people in the dust without anything but penitence recovery. Look up all other companies.
PROMONTORY HAS BEEN IN THE GET OUT OF JAIL BUSINESS FOR A LONG TIME
ONE BIG CON GAME SCAM SHAM AGAINST THE AMERICAN PEOPLE!
Monday, February 11, 2013
Bank of America Foreclosure Reviews: How Promontory Became a Shadow Regulator (Part VA)
Today we release the two latest posts in our whistleblower series on the Bank of America foreclosure reviews, focusing on the role of the “independent” consultant hired to perform the reviews, Promontory Financial Group.
The Plot So Far
As we described in earlier posts in this series (Executive Summary, Part II, Part IIIA, Part IIIB, Part IV, and Part IVB), OCC/Federal Reserve foreclosure reviews meant to provide compensation to abused homeowners were abruptly shut down at the beginning of January as the result of a settlement with ten major servicers. Whistleblowers from the biggest, Bank of America, came forward to provide compelling evidence that the bank and its independent consultant, Promontory Financial Group, attempted to suppress evidence that borrowers had been harmed by the false and deceptive practices of the mortgages lenders. Together, they reviewed over 2500 files. When asked to estimate the percentage of harm and serious harm they found, the lowest estimate of harm was 30%, with the majority judging the rate of harm at or over 90%. Estimates of serious harm ranged from 10% to 80%.
In this post and the next, we focus on how Promontory was badly conflicted and incompetent. Here we discuss how it has become a powerful, yet unaccountable shadow regulator. In the next post, we show how it made a hash of the foreclosure reviews and probe what the egregious expenses might be hiding.
Promontory, the Shadow Banking Regulator
Promontory has increasingly come to serve as the dominant shadow regulator in the financial services arena. It is difficult to name a player who occupies a similar role in any other heavily regulated industry.
Promontory has been an influential player virtually from its inception. Its founder and CEO, Gene Ludwig, was the Comptroller of the Currency under Bill Clinton and recognized the potential of the then-sleepy agency to end run other regulators.* After a stint as vice chairman of Bankers Trust, Ludwig established Promonotory and began hiring former regulators, along with attorneys with financial industry experience and former bank officers. The firm gained public visibility when Ludwig prepared a review for the board in the wake of a currency trading scandal at Allied Irish Bank.
As the firm became larger, Promontory recruited more senior and well connected former regulators, both to work at the firm and to serve on its advisory board. Its roster includes former SEC chairman Arthur Levitt, former Nixon and Ford administration official and NASD chief Frank Zarb, and Fed vice chairman Alan Blinder as advisors. Uber lobbyist Ken Duberstein is also on the advisory board. Fed governor Sarah Bloom Raskin is a former Promontory managing director. Their current staff is virtually an alumni association of the people who ran TARP, 1990s deregulatory advocates in Europe and Australia, and examiners from the OCC and Fed. And it doesn’t hurt that their public relations is handled by a former executive editor of American Banker. Analyst Josh Rosner has described Ludwig and the pre-eminent bank regulatory lawyer Rodgin Cohen of Sullivan & Cromwell as probably the two private sector parties most responsible for bank deregulation in the U.S.
Since Promontory is private, it is impossible to know its mix of revenues. However, its activities focus heavily on the adept circumvention of regulations. For instance, it operates CDARS, the Certificate of Deposit Account Registry Service, which is a service that divides large deposits and distributes them across a network of over 3000 banks. This is regulatory arbitrage, taking deposits that would otherwise exceed FDIC deposit insurance ceilings and breaking them into amounts that fall below the limits. A Bloomberg article, “Exploiting FDIC Loopholes Enriches Former U.S. Bank Regulators,” noted:
“These guys know how to work the system,” says {Sherrill] Shaffer, [former chief economist at the New York Fed] who’s now a professor of banking at the University of Wyoming in Laramie…Promontory charges banks more in fees, about $12.50 per a $10,000 one-year CD to get access to federally insured funds, than the FDIC itself charges in insurance premiums, typically $5-$7 per $10,000 deposited.
Another one of its major activities is getting financial firms out of hot water. From Promontory’s website (emphasis ours):
Promontory Examination and Enforcement Advisory Services offers financial and regulatory risk diagnostic and remediation services aimed at preempting, complying with, and mitigating the severity of regulatory enforcement action.
As one reader quipped,
Promontory has been running this scam for a long time. I used to be involved in Patriot Act/Anti Money Laundering Compliance industry working with the largest banks in the world. Every time there was a regulatory action, Promontory was brought in to be the overlord. The running joke was that there the OCC and FRB stapled Ludwig’s business card to consent orders.
Marcy Wheeler has called this the “Get Out of Jail Free industry”. But recently, Promontory’s most visible engagements have involved failed efforts at prettying up diseased managements. For instance, it told MF Global’s board that the broker-dealer had “robust risk management” a mere five months before it failed. And not only was this reading “absurdly sanguine,” but it was remarkably self-serving. Promontory was retained in 2009 to help implement reforms in the wake of an alleged trading scandals, so the report was an assessment of its own work. Similarly, Promontory prepared an analysis for Standard Chartered of wire transfers with Iran and other sanctioned countries, and reported only $14 million were out of compliance. The bank later admitted that at least $250 billion were impermissible, an over four order of magnitude difference.
LIBERTY ROAD MEDIA 
“Shelley’s Total Foreclosure Defense Works”
^^^^^YES!