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L. Randall Wray

L. Randall Wray

Posted: December 30, 2010 08:35 AM

In a series of pieces I have argued that MERS, a creation of the mortgage banking industry, has effectively destroyed the institution of private property in America. Ironically, MERS was created to facilitate quick and easy and cheap securitization of mortgages -- what are called mortgage-backed securities. In fact, what it did was to eliminate any backing of the securities by mortgages. Of the total securitized asset universe, something like $7 trillion are (supposedly) backed by residential mortgages. However, MERS helped to delink the securities from the mortgages. At best, they are unsecured debt -- there is no property backing the securities. What this means is that foreclosure is not permitted. As I have said before, it is likely that most or even all foreclosures occurring in the US are illegal seizures of property -- home thefts. We are talking about 100,000 completed home thefts per month, with another 250,000 new foreclosures started to steal homes every month. Projections are that 13 million homes will have been "foreclosed" (read: stolen) by 2012.

Worse, from the perspective of the banks, they've got to take back all the fraudulent MBSs, most of which are toxic.

In what follows I want to present the most favorable case for the mortgage industry. That is to say, I will ignore fraud and criminal conspiracies. Let us look at the current predicament as if it resulted from a series of monumental errors. With that in mind, what is the best-case scenario? First a caveat: I am not a lawyer nor am I an investigative reporter. I have relied on my perusal of reported evidence, plus a discussion with James McGuire who has put together an entirely convincing argument that the securitizations of mortgages resulted in securities that are not backed by mortgages. I urge interested readers to go to his website.

With that caveat, let us work through the problems now facing the banks.

1. A valid "mortgage" requires a ("wet signature") note and a security instrument; these must be kept together, and any subsequent transfer of lien rights to the security instrument must be recorded at the appropriate public office. The mortgage note must be properly indorsed each time the mortgage is transferred. In the era of securitized mortgages this can be a dozen times or more. If ever presented for foreclosure, endorsements should demonstrate a clear chain of title, from origination through to foreclosure; and this should match the records at the public office.

2. MERS intended to provide an electronic registry of all mortgages. By appointing a "vice president" in every financial firm, it believed that all transfers of lien rights among these firms were "in house". Hence it operated on the belief that no subsequent public recording was necessary, and no further endorsement of the mortgage note was necessary for in-house transfers of the payment intangible as it kept a record of transfers of the mortgage. It claimed to be a nominee of these firms (purported to hold the mortgage) but also to be the holder of the mortgages including the "Unidentified Indorsees In Blank" -- mortgages that were never properly endorsed over to purchasers. We know, however, that MERS recommended that mortgage servicers retain notes, so MERS's claim to be the holder rests on its claim that appointed VPs are employees. But these employees are not an agent/employee of the "Unidentified Indorsee In Blank", nor are they paid by MERS or in any way supervised by MERS.

3. This practice is in violation of numerous laws. Property law requires filing sales in the public record. Notes must be affixed (permanently) to the security instrument -- a mortgage without the note has been ruled a "nullity" by the Supreme Court. MERS's recommended business practice (with the servicer retaining the note) would make the mortgages a "nullity". A complete chain of title is required to foreclose on property -- every sale of a mortgage must be endorsed over to the purchaser, and properly recorded. Without this, it is illegal to foreclose on property -- no matter how many payments the homeowner has missed.

4. However, if the notes can be found and if MERS can provide records, it is possible that the mortgages can be made valid ("proved up") for purposes of collecting upon the indebtedness, but foreclosure would not be possible without a valid continuous perfected mortgage showing a chain of title from origination through to the current party trying to enforce the mortgage note. Any break in the chain of endorsements along with any break in the chain of title renders the Power of Sale clause in the security instrument to be a nullity and therefore no party can foreclose on the real property. So long as there is no fraud affecting the mortgage note, then rights to enforce the indebtedness can be further negotiated. If there is no break in the chain, when fraud is shown affecting the security instrument (such as robo-signers, etc), this does not affect the rights to enforce the mortgage note -- but such fraud will affect the validity of the security instrument perhaps making foreclosure impossible. Fraud affecting the mortgage note would affect the right to foreclose.

5. If the notes cannot be found and a Lost Note Affidavit can not reestablish the indebtedness, then foreclosure is not possible and collecting of the indebtedness is also not possible. Homeowners still can be sued for collection of owed moneys upon a "proved up" note or lost note affidavit but a current perfected lien is required to foreclose.

6. However since the mortgage-backed securities are governed by PSAs (pooling and service agreements), the practices above make the securities unsecured debt and there is no solution. The securities are no good. (This would be a Representation & Warrant violation as the MBSs stated that a secured indebtedness was to be purchased, but since the Trustees of the securitization would not have the notes, the securities cannot be "secured".)

What does all this mean? In plain simple language, the banks are royally screwed. They cannot foreclose on the properties. Holders of the "mortgage-backed" securities can turn them back to the banks because they are actually unsecured debt. In previous pieces I have also explained why MERS's recommended practice also violates US tax code -- so back taxes are owed. And we know that the mortgages stuffed into the securities did not meet the "reps" of the PSAs.

So, in short, banks have got to take the whole lot of toxic waste securities back. Trillions of dollars worth. The banks are toast. There is no cooking of the books that will turn this blackened toast back to bread.

This post first appeared at Benzinga.

 
 
 
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Kyle Ransom
Former veteran mortgage broker and mortgage securi
01:21 PM on 01/03/2011
Mr. Wray, this was an excellent account of how MERS screwed the banks and the foundation of my foreclosure defense.
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Ross Schuman
Eye of the Storm
09:24 AM on 01/02/2011
http://livinglies.wordpress.com/2010/12/31/we-dont-need-big-banks-that-escape-regulation/

If you are not familiar yet, and need help with your home mortgage that is part of this collective mess, get a report from these people and get an attorney ASAP. YOU CAN WIN.
12:21 AM on 01/02/2011
You know I don't hate Banks cause they have Billions, I hate them because they are able to do business with a different set of rules then me and you have to follow. Then they act like there so sophisticated, there really not smart I mean who could not make money with the set of rules they have to go by. Give any guy here writing in this blog the same set of rules and just watch how good he will do to.
11:27 PM on 01/01/2011
Man seriously we need to stop fighting between ourselves. Its not about Dem VS Rep. That's what they want us to do both sides have been bought to the tune of Millions of dollars. The sooner we see this the faster we can fix it.
06:15 PM on 01/02/2011
Bullseye!
08:47 PM on 12/31/2010
Here's something to chew. There is a case right now in which a Mortgage Broker is suing MERS. It seems MERS transferred notes it believed it owned on the mere say so of other companies. MERS said the they transferred the note based solely on the representations of the transferee. This is a conveyance of property with no proof whatsoever. It could be a phone call!
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cats530
16 Trillion To Banksters Per GAO Audit
03:20 PM on 01/02/2011
Yes, and MERS has 15,000 "Vice Presidents" too. Wonder why the IRS has not investigated these "employees"? Are social security and other taxes being paid by MERS for these "employees"? Wonder why these MERS and bankster "vice presidents" also have to supplement their high-powered/high salaried jobs by working at Burger King & Wal-Mart?
04:07 PM on 12/31/2010
Well I understand the dilemma as described, except for the separation of note and mortgage nullifying the transaction part you write about In section 4.

My own opinion (and I also am not a Lawyer!) is that at the point of the break in the chain, the original holder, would still be able to bring a whole new suit, not, as Mr Wray puts it “renders the Power of Sale clause in the security instrument to be a nullity.” It would in fact do what Mr. Wray said to all those purporting to hold title UP the chain… but they lack standing. Since the breaks are pre servicer and pre trust, then it would fall back either to the securitizing entity or the original lender. Interestingly though, since the originating lender used monies from the trust and not their own…

As Investor’s sue to regain monies lost them through misreps and warranties, they’ll get paid back from the Lenders…. the debt to them is repaid plus actually, probably reaping a higher profit on their investments because of fines, penalties, etc.

The Investors would be getting repaid because of the fraud brought on by the Banks. Leaving one to think the Banks then would recover from the homeowners… but the Banks NEVER lent any monies to the homeowners in the first place… it was money taken from the trusts!

Essentially then the Banks would suffer no loss! And suffering loss is part of what needs to be to have standing.
12:14 PM on 12/31/2010
Screw the homeowners, they should just pay their mortgages....oh wait that was last month before the rest of the world realized that the banks were robbing us all blind...right in front of our faces...and with our own money....this can only end with a catastrophic blow up......our courts have conceded too much to the criminal banks already....
11:31 AM on 12/31/2010
Don't let them take your home, pro se if need be!
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DARK STAR
One small step for Man...
11:11 AM on 12/31/2010
Unwinding this is not that bad, or as bad as the article is making it out to be, if there is a clear path, the work and the details that assure the integrity of the mortgage are there. If it is not found, if fraudulent, there is little to no data to support the loan, then you have something else that is probably illegal on your hands and happened as a result of bad operators that should be removed from the system.

No one has been sanctioned or even disciplined that I know of and the shame that occurred with sub prime loans seems to have disappeared. If these loans were fraudulent, then examples need to be made as this used to be a land of laws, not of people- specifically rich people with lots of money for lawyers, but of laws that kept this kind of behavior in check so that it does not go too far. If it goes to the top, then so be it, ceo's can learn a lot in prison.

Bring back a RTF like body to deal with this and make a ruling, banks need to get back to banking and making loans to small businesses to grow and flourish. Eric Holder, please make a stand for once.
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blueken
Finger Picking blues man
10:34 AM on 12/31/2010
So let the tidal wave wash over the banks and clear out the filth. Slowly the tide will rise again. New banks will spring up, and we can make sure that sensible regulations keep them on the straight and narrow. In my small town of 35,000 people there must be 25 banks. That seemed a bit redundant to me.
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blueken
Finger Picking blues man
10:26 AM on 12/31/2010
About 10 years ago the company I worked for hired a consultant to teach us the "Comitment to Excelence" method of management. All the managers "bought into" the "process". As soon as the consultant left mangement apeared to follow the "daily steps towards execellence", but in reality it was what I called a "Commitment to Appearence". This represented no change in managemnt at all. This article tells me that the banks, mortgage brokers and Wall Street was following the "Commitment to Appearence". It is far easier to appear as if you are doning your job, than doing it. They just follwed the path of least resistance.
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Kyle Ransom
Former veteran mortgage broker and mortgage securi
01:41 PM on 01/03/2011
Allow me to go a step further and say senior executives seem place profits over ethics and corporate responsibility. Unfortunately, this type of thinking is the fabric of capitalism. Almost every major companies has been cited for some ethics issue.

Kyle Ransom
http://gofightforclosure.com
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Nansue
09:13 AM on 12/31/2010
Banks aren't the only mortgage industry stakeholders in MERS. The list of owners includes ALTA (American Land Title Association), MGIC (Mortgage Guaranty Insurance Corp.), Stewart Title, PMI (PMI Mortgage Insurance Co.), and First American (I'm not sure if this is First American Title or another entity). So it isn't just a problem for the bankers.

http://www.huffingtonpost.com/rj-eskow/pictures-of-mers-part-1-c_b_769181.html

I work for an attorney who does foreclosures and we recently ran into problems when a title company that issued a foreclosure guarantee couldn't resolve discrepancies in the chain of title it reported in the guarantee.
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BlairCase
08:44 AM on 12/31/2010
The courts have consistantly ruled that blank endorsements give MERS legal standing to conduct foreclosures on behalf of its member banks. MERS claims that it never files for foreclosure unless it has possession of the note. Homeowners who doubt this can challenge MERS in court. Foreclousure is simply an additional service that MERS offers to its member banks. The banks can opt to conduct their own foreclosures. Banks say that instances in which titles were not transferred to trustees along with mortgage-securitized bonds are adnormalities. Whether titles can be transferred retroactive to the sell of the bonds is being tested in court cases. However, the strategy that unhappy investors who bought the packaged mortgage bonds are pursuing is to threaten banks with lawsuits alleging that the banks continued to sell the bonds as low risk after it became apparent they were high risk. Banks are buying back some of the bonds to avoid litigation.
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cats530
16 Trillion To Banksters Per GAO Audit
03:31 PM on 12/31/2010
Incorrect. The courts have not "consistently ruled" in favor of MERS and MERS has been found to have NO LEGAL standing to conduct foreclosures - JPM Chase stopped using MERS 2 years ago and Fannie Mae does not allow any FCs in MERS name. MERS has become the well-deserved pariah that it is. Of course, banksters will say that any foreclosure fraud is an "anomaly". But facts prove otherwise, i.e., Bank of America Corp. lost a bid to prevent MBIA Inc. from using statistical sampling to pursue repurchase demands in a lawsuit. No one is believing MERS or the bankster propaganda any longer.
04:33 AM on 01/02/2011
99% of the time is not consistently?
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Longtimeliberal
08:33 AM on 12/31/2010
In addition, isn't someone required to pay the county filing fees the MERS system avoided costing each state untold amounts of money. The States Attys appear to be the only ones left to prosecute due to deregulation by congress. The State Property laws have not been stripped therefore states have a lot of power. Their investigations just recently started and I expect them go full speed ahead and voters will hold them accountable.
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cats530
16 Trillion To Banksters Per GAO Audit
03:32 PM on 12/31/2010
I certainly hope you are right. MERS was also complicit in defrauding the IRS. I see no investigations taking place there.
04:32 AM on 01/02/2011
How were they defrauding the IRS? That sounds ridiculous
07:43 AM on 12/31/2010
The first of numerous questions that this piece provoked in my mind was, "If in fact laws have been broken, why have there been essentially no criminal prosecutions?" There are, after all, fifty state jurisdictions whose laws have been broken. It would seem to me that if it were really so obvious that laws were broken, some honest or ambitious state attorney general would have charged someone with something. The absence of such activity suggests an answer: truth is, the industry has been deregulated to such a degree that they cannot be prosecuted for anything. The Congress and President had the opportunity to remedy this, but did effectively nothing. Let us not forget that. Let us also not forget, as some commenters already have, that this crisis was not the work of a single administration or political party. Conservatives and libertarians are especially to blame for their incessant desire to allow the rich and powerful to do whatever they wish. They will be satisfied only when we are reduced to an economic state of anarchy, married to a police state to repress the poor.