2019.06.21 1793945 Appeal 19-7025-Addendum Declaration Robert DiMarco (114-142)

USCA Case #19-7025 Document #1793945 Filed: 06/21/2019 Page 1 of 151
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Case 1:14-cv-01047-RMC Document 136-4 Filed 11/29/18 Page 1 of 29
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
)
UNITED STATES OF AMERICA, et al., )
ex rel. LAURENCE SCHNEIDER, )
)
Plaintiff-Relator, )
) Case. No. 1:14-cv-01047-RMC
V. )
) Judge Rosemary M. Collyer
J.P. MORGAN CHASE BANK, N.A., )
et al., )
)
Defendants. )
_ _____ _________ )
DECLARATION OF ROBERTO L. DI MARCO
I, Roberto L. Di Marco, state that the following is true:
1. I am a partner in the law firm of Foster, Walker & Di Marco, PC.
2. I am licensed to practice before the state and federal courts of Massachusetts. I have
been admitted pro hac vice to practice before this court for this matter. I am an attorney
in good standing and my Massachusetts bar number is 645157.
3. I am one of the attorneys representing the Plaintiff-Relator, LAURENCE SCHNEIDER
in the above captioned matter, and Plaintiffs S&A CAPITAL PARTNERS, INC.,
("S&A"); MORTGAGE RESOLUTION SERVICING, LLC. ("MRS"); and 1ST

st
FIDELITY LOAN SERVICING, LLC, ("1 Fidelity") (collectively "NY Plaintiffs") in
·the matter of Mortgage Resolution Servicing, LLC et al v. JPMorgan Chase Bank, N.A.
et al, Case no. 15-cv-293, before the United States District Court for the Southern District
of New York ("the NY litigation").
ADD 114
4. I have personal knowledge of the facts set forth in this Declaration, which I make in order
to place before the Court certain information and material relevant to Relator's Motion
for Hearing.
5. Attached hereto as Exhibit Dis a true and accurate copy of a document produced in the
NY litigation, Bates stamped JPMC-MRS-00051154, titled Chase Default Customer
Management: Mortgage Banking Recovery.
6. Attached hereto as Exhibit E is a true and accurate copy of a document produced in the
NY litigation, Bates stamped JPMC-MRS-00319625-00319628, titled Audit Department
Report.
7. Attached hereto as Exhibit F is a true and accurate copy of a document produced in the
NY litigation, Bates stamped JPMC-MRS-00208917-00208922.
8. Attached hereto as Exhibit G is a true and accurate copy of excerpts of a document
produced in the NY litigation, Bates stamped JPMC-MRS-00155219, JPMC-MRS-
00155230-00155231, titled Mortgage Banking Business Requirements.
9. Attached hereto as Exhibit H is a true and accurate copy of an email produced in this
litigation, Bates stamped JPMC-MRS-00055684-00055686, from Robert Adamovic to
Krista Hensley and others, dated June 21, 2013.
10. Attached hereto as Exhibit I is a true and accurate copy of a document produced in the
NY litigation, Bates stamped SA00327604, titled Vacation and Rescission of Release of
Mortgage.
11. Attached hereto as Exhibit J is a true and accurate copy of a document produced in the
NY litigation, Bates stamped SA00433946, titled Vacation and Rescission of
Modification of Mortgage.
ADD 115
th
Signed under the pains and penalties of perjury this 28 day of November, 2018.
ADD 116
EXHIBIT D
ADD 117
ADD 118
Page 120 of 151
Chase Def a ult Cu sto mer Manageme nt: Mortgage Banki n g Recove r y
FY2012-14 Recovery by Channel (Owned)
FY2012- ov..n.d Recovery

. , . . 0 0 . ,u
.12 .!!
" ..
.E .,
.ll 14 15 16 17
Jen.-t2 hb•12 Mar•12 Apr..12 May.12 Jun,;.1'2 Jul-12 ......12 Sep,,12" Oet-12 Nov-12 o.e.12 FY2012
bv Channel lSM~
ln-HoUM No~BK $12 364 $13 432 $17 725 115 039 $1$844 $15 637 $1$238 $16 530 S1-t 308 $1-t 968 $13.766 $11871 $176,7'24
ln"'4ouse BK $626 $ 1178 $81!2 $1148 $668 $450 $847 $823 S9\l3 S92" $1 085 S731 $10,270
Agoncv~poci:al ty, Non-BK and BK .$8,Bn $9.499 $13,238 $10,998 $11,271 $11,753 ~ 1.otl3 $10,038 $7,839 $10,704 $ 8.725 $8,881 $122,683
Early-Out $1 so 50 $0 so $0 so so $0 so so $0 S2
P'°'ON S2.810 $2,714 1-3.7'22 S2.900 S2 080 S.2,926 S.2.612 $2025 S 1.590 S2.036 S1682 S1.993 $29.60,
SCC0/1~ $1.767 St. 139 51.591 $1.302 St 422 $1.0 18 51.16' S939 $815 $946 S697 S936 $13.73'5
TMiilM)' $352 "3i $691 $663 $733 $418 $€28- S325- 5246 $377 5284 5339 S:5,491
8 Quad S3ll5 $713 $1.520 S9<6 $1 . 106 $951 S.1.121 $780 $677 5638 $051 $491 $9.89\l
suos
·~
9 s a!tv Non-BK 5694 $1.466 $1.$5-4 $1,182 $1,809 $1.790 $1,743 $877 $1.3~0 $1,296 '$1.712 S1.SS88
10)
11
$pe,-;t~11y8K
Ol'l~r
$2,190
S•69
..
$2.341
5088_
$2.866
$1.004
$2.999
$1,00~
53320
S291
$2.e,;7 $3.?~
$519_
S3 261
_§9~
$2.910
SI~
$4.200
$65~
$3679
$$36
$3.004
$387
..
$3896$
SJ,;,106
Filed: 06/21/2019
12 Bulk Sale so so so so so so so so so so so
13 -SublOU1I o~ratlonal $21,968 $24.109 $31,8!53 127,18$ ..$2{ 784 $27,840 $27,1A 127;389 123,040 .s2s,eo1 523,HIIS ·S21,4&4 $-309,IIS7f
14 MISC. Entries (2MP) S 10.643 $4,572 S3.751 S2,083 Sl,710 $2.826 $ 1.880 $6006 S-475 S3.409 S1.524 SS.092 $45,371
15 >.lsc. En'1es (.,surance) S1. 148 $2,293 $3.673 S3.463 $3893 $5.957 $4,526 52 358 ($175} S2.742 53,943 $4.182 $38,202
16 Ml&c. Entll~.s {Racoursel $234 $2,063 $1.204 S 1.038 $571 $1.033 $1.183 52,630 52,173 $213 $414 $0 $127◄6
17 Msc. Entries BAU I S2.S98 $46S $1.039 $1.049 $1 ,527 $1.273 $4.920 $1,714 S3.1S2 $1.026 $32'1 $1.132 $9,129
18 s,1btohtl Other $14,823 $9,383 $8,867 S?,833 S7701 S11,089 $2.889 S13.B07 SS.828 $7,390 $SSSS $11.•05 S108.S48
19 '' fotol Roe-o..,crv oor-G/L $·38.2$1 $33.492 $41,7:20 $34.818 _US,4$4 038.929 S2",938 "40997 $28 66$ $33,991 $29 1 3.1 ·S<l2. .... $418 226
w
V '
-~·
fY2013 Owned R~ove,y
In-House, Non-BK
In-House, B K
., •... J1u,.•f3
$11,689
S961
f,tb-1"3
$9,!567
$975
Mat"-13
$12,067
$1 2()9
Apr.13
S,9,!591
$1,146
May.13
$10.737
$1 213
Jun,.13
$9,3!56
S8T7
J ui.13
$8,907
$1 374
Aug-13
$8,417
$1 035
Sep.1'3
S,7,841
$1,323
Oc:M.3
S9.2n
$1,234
Nov.13
$6,864
$1,292
Dec.-13
S,11.148
$1.637
fY2013
$115,449
$14 277
n Aaene / Soeelattv. Non-BK and BK $7,003 S7.591 S9 143 $9,487 $9 728 S9 208 $10,175 $7 7$3 $8,012 $7,021 $7032 $6, 290 $98 430
so so so so so so so so so
....
D !;arlv,Oul $2 $0 $0 $2
B Pnm&IY $ 1 .272 $1173 S1 651 S1 55S $1 690 S1.3 1::) s, ?52 s, 266 $ 1 .549 S1218 $1 162 S1283 sro 479
2'I SeCC1idMV 9612 ..,9 S524 S367 S483 $705 S493 S346 $281 S345 S'542 $5,1~.~
26 TcrtlttN $273 1210 $410 5271 S194 S309 $~50 S224 S282 S290 5288 S349 sa.~s @l!fil
ff Q""d $516 $444 $537 $619 $759 $674 $388 $178 $313 $130 552 S84 t)4.J'04 (52%)
26 s 'altv Non.BK $969 $1,794 $2.31),1 S22()2 $2•152 $21197 $2.488
~-= $2 423 S2,208 S1 237 $1953 S988 $23 5f5
-....
~
26
w
~
$ artv8K
Oller
Bull: Salo
SJ.021
=$0 .. ..
$2,991
$460
$3.300
s=
S3,732
=so
$3820
$44()
so
S,31S09
$310
so
S.86
so
S2809
$369
so
SJ,048
$'lei
$0
$3.5~1
$a13
$0
S30<3
$190
so
S2.730
S29.C.
so
$4o,2',0
'$1:,408
$0
~
n~
Document #1793945
32 Subtotal Otw1,niitlO~I $18~3 $19..123 $22..418 S20 224 $21 878 S19 438 $20,456 $17 205 $17176 S17 5'JO $15188 $19 065 $228155 ~
R Misc. Entries (2MP SJ.093 S3.042 $2.291 S1.475 $1 .206 51.601 $ 1.5 19 $69 S2.428 $957 S1.494 SU08 S20,484 (5""4
34 ~c. En"ies (rlsuruncc S3.515 $1,535 $2.831 S2.411 $5221 $ "35 $460 $2,789 S20 S2.882 S2.250 $3,625 $28272 ~
~ Misc. En~es Recourse) S,10 $1,275) $1.588 $4,200 $1 755 $1.338 $776 $1 535 S 1.530 $603 $530 s,2, $13414 0%
35 Msc. Entries (BAU) 5320 cS379) $210 $620 ,s1931 S1.694 S1.211 $818 S2,330 540 $103 S2S7 $7,224 @fil
D Subto1a1 Other $7,338 $2,923 .. 720 .$8,90$ Sf 9\l4 S.S.768 $3.960 $5, 211 . . 308 $4,482 $4 377 S.S,414 S69.39$ ~ -
35 Tota l RacoYaN' nar-GIL $28,991 SZ1.0M $291"39 $29 129 S29Be2 S25;£07 $24.• 22 .$22,415" S,2348' $22,012 S19 585 S2''.C79 $297 550 2 I i 29%
..., ...... ·-· ,....,

FY.2014 Owned Re¢overy Jan•1• Feb-14 Mar-14 Apr•14 M.iy-14 Jun-,14 Jui.14 AuiH4 &p. 14 OCl•14 No~• 14 De-c- 14 FY2014TO
Bir
I FY2014TD ~ FY201
Y SILY Y STL
In-House, Non-BK $5,830 $8,580 S8,18-8 18,483 SS.338 $6,100 SS,995 $4,817 S$,S20 S8,285 $82,1111S (S35,32t
~
40 ' In-House, BK S1,209 $1,279 $1,870 $2,474 $2,890 $2,543 $2,742 $2,2" S2,838 $3,578 $23.480 $12.133
'
~ ~•ncy I S eecia~. Non-BK and BK .$8,835
so
$8,002
so
$5.793
so
.$5,088
so
$6,270
so
ss.oet $7,009
~so
$8.509 .$5,355
so
.$5,093
so
m.s12
so
. (S26.3051
a Earl",....'I $0 $0 {$2)
a p""'~ $531 $758 $489 $467 so $2
ff'
g
I Secondarv
Te,U__a')'
$791
$293
$207
$923
$300
$182
S1.067
$251
S2"4
5218
S298
$207
$11$,
$121
$2()2
$686
$249
$107
$190
$126
$185
$20
$170
S8
~.763
$2, 183
$1-,5U)-
i!~:~+
J$1,2021 (44%)
>
----.
•a Quad
Spedolt\r Non-BK
$196
S1.9S1
$88
s1.n;
$276
$1.47◄
S88
$1.436
sse
$2667
so
S.2.127
so
$3,554
so
S3 305
$0
$2,8-01
so
$3.206
$i4(f"
S24ST9
l$3,EU11
$3,6(!6
(.84%)
191<
48> SIX"';i3llvBK S2.960 $2.646 $2.269 S2.412 S2.317 S.2.078 $2.264 S2 403 S2290 S1.658 S2'H18 (S1U72l (3254)
~
~) '
Otier
Bulk Sa~
S2()6
so
$128
so
$212
so
$43
so
$126
so
$43
so
$30
so
$is_
so
$59
so
553
so ---- $9t6
·--w-
f$3.0061
so
(17%)
"'
USCA Case #19-7025
~ Subtotal Ooerotlonal $13 673 $13,860 $1!56.31 $14 043 $15-488 $13,704 SU,747 $1~595 $13711 $14 957 $1«,408 S.fi9."9i4
~ Misc. l=rltnes (2MPJ $ 1.478 $1,975 S t.50. $638 $2.226 $1.967 $00$ $ 1, 110 $4"" $576 s12:&;1 {$!>.-3-221 (30%}
..''
~
M
;
S8
~
>A$C En'1es. (t'l51,.1~nce)
MISC:, Entnes (R&COUl'H)
MiSc. Entries (BAU)
Subtolal Other-
Tol81 Reco11e rv floAr GIL
$2.593
$375
S,85
S4.938
$18,609
$1,372
$285
$309
$3,941
$17.802
$6.17$
$347
$ 1.105
$9,132
$24,762
$ 1 ,931
$$50
{ $33}
S3,083
$17.126
$1 341
$1,050
$ 1.691
$6,308
$21,798
$86G
$11 :5
(S91)
S2.857
$18.M11
$2,.:J,88
$468
$ 1.070
$4;834
$20,381
....
$536
$149
$2.388
$15,983
$ 1 ,002
5244
$637
S2.583
.$18,274
$679
($12)
$917
S2.159
$17. 116
$ 18,989
-- ~3.~
$6.883-
s-12.001
S188,A10
J$3-)
t.$8,6911
S 18
($17.602}
$87,088
(15%)
(71""1
""'
(30%)
l
Comments:
.2)1) lower.
FY2012 Total Recovery was 8% lower lhan FY2011 $37MM ($416MM v. $453MM).
Of
FY2013 Total Recov"ry was 29% lower than FY2012 ($298MM v. $416MM, or$119MM) as Operational Recovery was 26% lower and Non-Operational Recovery was 35%
I oet-14TD is $67.1MM unfavorable to STLY due to Operational befng $49.5MM unfavorable and Non-Operational being $17.6MM lower.
22
Confidential T reatment Requested by JPMC JPMC-MRS-0005 11 54

EXHIBIT E
ADD 119
JPIV[ORGK'\ CJ:L\SE &Co.

Audit Department Report
Home Lending - Recovery Operations and Recovery One (RCV) Application

Report Number: M-11/038
Audit Rating: Inadequate
Report Date: August 0 1, 2011
Audit Type: Audit
Prior Report Number: M-06/019

Prior Report Date: March 29, 2006
Prior Report Rating: Satisfactory
Prior Audit Type: Audit
Business Overview and Context

Home Lending (BL) Reco ery is responsible for the collection of post ch,'IIge-off deficiency balances that are
recoverable while following bank policy. stale and federal laws and regulations, and investor guidelines. JII Q l of
2010, the HL Recovery organization increased the resources and capacity of the Home Equity and Mortgage
Recovery team in response 10 an increasing loss portfolio. HL Recovery grew from approximately 25 to 150
employees and as of June 201 l, there are approximately 59,000 acUvc recovery accounts (318.000 Bank owned
and 41 ,000 Investor owned ccounts) with accoun1 balances totaling $28 billion. The business reco,·cred
approximately $306 million in deficiency balances during 2010 and approximately $165 million in 2011.
Recovery collection strategies utilize in-house collectors and n network of21 third party collection agencies. TI1c
Recovery collectors leverage the applications Recovery One (RCV) and Mortgage Servicing Package (MSP) to
collect and document recovery activities for Investor and Bank Owned por1folios. RCV is a High risk ranked
mainfrnme based application supported by HL Technology but used in other lines of business, including Auto,
Business Banking, and Asset Management.
In Q3 of 20 I 0, Management performed a comprehensive end 10 end Control Self Assessment (CSA) aimed at
identifying control gaps and control weaknesses, and developed process enhancements to improve the effectiveness
of the recovery organization. The self assessment identified over 20 significant control issues for which
Management has pro-actively initiated remediation projects to eliminate t11e gaps. Specifically. HL Recovery has
added resources and reached out for cross functional support, suspended the recovery work against suspect accounts,
developed or revised over 90 operational procedures, developed an inventol)' of daily, weekly and monthly
management and exception reports, and developed data integrity initiatives ensuring recoverable balances arc
accurate across servicing systems.
While progress has been made and Management remains committed to building.a sound control environment, other
Default business and technology initiatives outside of Recovezy have taken priority and has impacted the
remediation and implementation of a target environment. Furthennore, at the time of our audit a significant amount
of remediation.. control design and implementation still remains to be completed.
CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00319625
ADD 120
Audit Scope
This review focused on the adequacy and effectiveness of key controls surrounding the HL Recovery process and
the RCV application. Additionally, the review focused on Marn1gemenl's Self Assessment lo ensure a tJ1orough
review was perfom1ed with approp1iatc action plans developed for remediation. Specifically:
• Recovery efforts arc being perfonned in an appropriate manner and in compliance with regulatory
requirements (Fair Debt Collection Practices Act (FDCPA), Fair Credit Reporting Act (FCRA), etc.) as
well as established internal policies and procedures.
• Sworn Documents - Adequate controls exist to ensure compliance with regulatory requirements and
accuracy of sworn documents.
• Application Security Assessment (ASA) & Control Self Assessment (CSA) are properly perfonned
including identification of key controls, documentation of issue root cause, impact, and remediation of
issues is complete and timely.
• Security Operations - Adequate controls exist for access adrninistr.ation, privileged access, and access
recertification for the RCV application.
• Information Management - Appropriate data confidentiality and integrity controls are in place to ensure
complete and accurate data and protection of infonnation from unauthorized disclosure.
• Vendor Management - Adequate controls are in place lo manage outside collection agencies including
service levels, agency audits, etc.
Key Findings
The current operational and technology controls over Recovery operations are not sufficient to ensure compliance
with bank policies, laws and regulations, therefore, an Inadequate rating is assigned. Issues were identified that
could cause legal and repulalional risk in particular relating lo lhe execution of sworn documents and lhe need for
personal knowledge prior to signing assertions. Issues were also identified relating to data integrity, risk
management and access administration. Management has initiated remediation of known control deficiencies, and
continues to react to various changes in the regulatory environment associated with the finn's compliance with state
and federal requirements, and consistent treatment of customers. A summruy of these issues follows:
• S iYOrn Documcou - Adcqunle controls do not exist to ensure sworn documcn1s (e.g.. Affidavits) are
completed appropdately and in adhcre·nce ""ilh Ule Bank's procedure and all Jaws. regulations and
statutes. Personal knowledge is 0 01 consistCDUy obtained prior to signing a sworn document, recoverable
balances are not supported, and tJ1e notary processes do not comply with bank procedures resulting.in
violations of state laws.
• Source System Data Integrity - While Management has initiated efforts to improve data quality, the lack
of systematic interfaces, manual business processes and prioritization of other default initiatives has
resulted in recoverable balances that are not always accurate on MSP and/or RCV. At the time of our audit,
plans to investigate and resolve out of balance accounts were not fully implemented, out of balance
accounts still exist and significant amounts of remediation (i.e., account balancing, look back analysis)
work remains. Management identified out of balance accounts dating back to early 20 IO and suspended
active recovery efforts on all known inaccurate balances.
• Risk Management - Management was pro-active in identifying significant control deficiencies and has
been working to implement baseline controls. However, the Finn's risk management practices, such as
logging issues and action plans in the Phoenix tool, were not always followed, resulting in control
deficiencies not addressed timely or appropriately.
• RCV Access Administration - While RCV is engaged in the Retail Identity and Access Management
(I&AM) initiative, profile management has not been addressed. As a result, HL Recovery personnel have
CONFIDENTIAL TREATMENT REQUESTED BY JPMC J PMC-MRS-00319626
ADD 121
entitlements to create accounts and alter outstanding balances, which is a segregation of duties concern.
Additionally, offboarding, recertification and activity logging are not operating effectively.
Root Cause
The root causes of these issues was a rapid build and implementation of the recovery organization without properly
designed controls, a lack of system interfaces and prioritization of other default business and technology initiatives
outside ofRecoverv .
Status
Management has developed action plans to address the issues contained within this report and target dates arc
scheduled. Several operational enhancements have already been and continue to be implemented to address self
identified and audit identified issues.
Business Details
Level 1: Home Lending
Business Executive: Frank J Bisignano
Level 2: Home Lending

Business Executive: Kevin Watters
Scott E Powell
Location: Texas, North America

Business Executive: Mark WDavis
Michael A Zbranak
Business Details
Management Team Member: Wilson, Janice A
Audit Manager: Kyle S Kinney
Technology Audit Manager: Pauline W Saunders
Auditor In Charge: Sco11 J Calabrese
Detailed Findin~s and Mana~cment Action Plans

Issue: Sworn Documents
Issue Severity:
Adequate controls do not exist Lo ensure sworn documents (e.g., Affidavits) are completed appropriately and in
adherence witl1 the Bank's procedures and all laws, regulations, and statutes. Recovery Affidavits are prepared by
outside legal counsel and reviewed and notarized by HL Recovery prior to submission to the courts for judgment.
While only 421 affidavits have been completed since 2008, Management's go forward strategy is to increase
recovery efforts through tl1e Affidavit process. Based on our review of the preparation and execution of sworn
documents, we observed the following :
• Finn wide initiatives to standardize sworn document preparation have no1 been full implemented or
consistently followed. such as having personal knowledge. where required, of documented recoverable
balances, and notary processes, resu ll.ing in violations of state Jnws.
ADD 122
• Sworn docwnents. sucJ1 as ll1e Amouni Due Affidm•it, submitted to the coUit contain balances tluu could
not be traced to source syst ms Inaccurate balances may resull in potential violations ofJudicial laws and
bank policies that have been the subject of llle industJy wide criticism of S\ om document practices
While Management has implemented signing authority controls and has developed baseline sworn document
procedures, these gaps contributed to exceptions to llpplicable loca.Vstale laws. Many of lhe operational
improvements recently adopted in foreclosure that have similar regulatory guidelines, such as document execution,
were not adopted resulting in the types of errors that have resulted in regulatory criticism.
Management should work with the Legal and Compliance teams to implement the finn wide sworn document policy
and controls for document execution to ensure required sworn documents are prepared, approved, and reviewed in
accordance with all applicable laws and regulations.
Root Cause
The root cause of these deficiencies is Management's failure to implement best practice documentation execution
standards and quality controls, similar to their peers across the firm.
Action Plan
• Implemented documented signing authorities, notazy logs, and a quality JCvicw process ensuring sworn
documents reconcile to source ,systems, are completed accurately and the personal knowledge requirement
is satisfied (Target Date: Complete).
• Pelfonn an independent control assessment along with Legal, Compliance and Risk assessing sworn
document control procedures and execution. Assessment resultB will detemtine if suspension of sworn
documents should occur or additional controls need to be implemented (Target Date: August 31, 2011 ).
• Training will be conducted on the new finn wide sworn document policies for Recovery personnel.
Recovery will continue to work with Legal and Compliance lo ensure the successful integration of
company wide practices around sworn documencs into all Recovery processes and discuss if any
remediation is required for completed swom documents (Target Date: October 31, 2011).
Target Date: October 31, 2011

Owner: Patrick M Boyle
Issue: Source System Data Integrity

Issue Severity:
A combination of manual business processes and system conversions has resulted in inaccurate customer account
balances within the servicing systems MSP and RCV, which could lead to the collections of inappropriate amounts
and inconsislenl treatment of customers due to a lack of systematic interface between RCV and the MSP loan
servicing system and no reconciliation process. A reconciliation process between servicing systems and RCV
ensures recovery balances agree with the system of record. Specifically, we noted the following:
• Management identified hWaMu and hChase out or balance accounts and suspended active recovery efforts
dating back to early 2010 until they can investigate and resolve out of balance accounts. However, at the
time of our Audit, a plan to correct out of balance accounts and a look back approach was not implemented
for the hWaMu portfolio. Further, while account balancing for hChase accounts has been implemented,
approximately 7,800 Chase accounts (9%) are out of balance by a total of $27 million as of May 2011 and a
look back approach has not been delennined. Out of balance accounts and the suspension of recovery
efforts could potentially result in the inconsistent treatment of customers and diminish shareholder value.
ADD 123
EXHIBIT F
ADD 124
No. ObseNatlon/Recommenda tion Manaeement Action Items, Owners, and

Target Dates I
1 ScJ tlcma r,t Oversight : Settlement strategies and the corresponding operational activities have undergone multiple
changes in reaction to changing ma,ket conditions and business targets since the last update to the governing Risk .
Action Plan:
Compare operational rrnrerlures to the
poliq1 (P060,00 and P060.30). While the current pruce;;es wens in,plemented in coordination with Risk based on
communications provided, the changes were not subjected to formal risk managemert change practices, . risk policies and Identify any gaµs
Update the policy lo al gn :o current
documented approvals could not be provided, and the policy was not updatPd. Addit ionally, some of t he
operational changes did not include expected controls. Specific examples of the current processes not aligning wi th . requirements
Update prncedure, to dFf1oe expected
.
the policy or missing controls incluoe:
Current settlement strategies were implemented in 2012, and make use of "thresholos" (<1 predefined
percentaee of the charged-off UPB) that drive collection negotiations. The policy references Net Present .
svs~em documentai::ion tor settlement
deci:;ians
I
lrr1p\r~me.:1t rcp0rting </ elem1=ms
aJ: nEd ·r. P01i0 '.Ju and ,xceot oos
. Values ,o de:ermine fina1 se:tlement practices.
Exceptions ar~ made to the settlement thre;;holds on a recurring basis. While we were able to identify
documented procedures on how to perform 2nd approve er.ceptions the governing policy (P060.30) is
iril udir11; lrt:r1:Ii 1g anci ll,11:::$ho,J:: 1or
t:!SC31CJ1iori (8,1\j
.
silent on exception, and required apprav;ils ~nd there is no aggregate level monitoring tc ensure
consistency and prorriety of exceptions.
Certain settlements are executed via a short sale or payment plan. While these are bank owned assets,
.
I F-;ii'.ibli,1, ;-i QC r:rnrP~o; fnr dr~ciir1ei;, IQA)
Eri,S?..gi:- ce."'ltr,filed QA teaM to reins:zite
QA 1e~li'lg 'or ReuJvt:r·,' Ounn~1ons (QA)
. there is no reference of these in the existing policies applicable to Recovery Operations.

Current recovery reporting is not fully compliant w;th required reporting elements outlined under section
9 of P060.00.
Operational processes that are not compliant with exis t ing policy subject i:he firm to financial, regulatory, end
reputational risk. We recommend management map current operational procedures back to the Mk policy and if
gaps exist remedi.ite or obt.iin exception approv.ils through the appropriate channels of governance.
Quality Assurance Design and Execution: The Qu.irterly Deal Review Quality Assurnnce (QA) Program, lades the
I
I
2 Action Plan;
appropriate framework, which iocludes sampling, ch•cklist criteria and reporting, ro adequately idPntify 5t'r 5~1tl'::'1,,t'ri! Ove:1 ~iyl::
.
substandard transactions and address concerns effectively. Specific observations are as follows:
Sampling- methodologies do not ensure coverage of the enlire population of transaction types and
sample sizes are not large enough to appropriately identify concerns. For example:
I
I) No OA is pPrfnrmP.rl nvPr SFttlFmP.nt dP.nials.
0 Payment plan breaks are not subject to the QA process.
. 0 Methodology does not ensure proper coverage of the population.

Checklist Criteria which drive the testing approach are not specific enough to allow for reaerformance and
consistent resul:s. contain outdated elements that do not align with the current process, and/or are
performed at inappropriaite poims Ir. rhe process:
0 In our samplt: or 10 selllements subject lv QA, we we:re unable to repedorm Lht:: step "was Lhe decJI
justified?'J due to incomplete writteri pro:edures. Furthermore 1 this attribute is considered a "non-
. crirical" error which does not appear appropriate.

Reporting in place does not orovide management with transparency into the critical operations of the
group. Missing elements include :
0 No trending or internal ,eporting of quarterly QA results is produced.
0 QA quality ra,e targets have not been defined or implemented into emoloyee performa nce
Confidential Treatment Requested by JPMC JPMC-MRS-00208917
ADD 125
evaluations [e g. scorecards) . l
Ineffectively desientd ke~· controls increase the risk of operational issue5 that may result in iinnncial loss or
regulatory action taken against the firm . We recommend Manageme1t reassess the design of the current QA
3
proc@ss anri take steps to address the gaps noted above and any additional design issues that result from the
reassessment.
Vendor Managl!ment ; Recove 1y Operntions hos not estoblished the required oversight controls to monitor the J Action Plan: I
.
vendors critical to their operations. Specifically:
Formal service level agreements (SLAs) have not bPen established over the processing of the active
• Update monthly scoreca rd s and
quart erly assess ments to in clud e agree d-
. bankruptcy portfolio for Recovery

1he monthly Delivery Scorecard prepared by Recovery Operations Vendor Management does not include
all services provided by the vendor. .
upon benchm arks and segment
oper ational and performa nce metrics
Enha nce the pe riodi c co mmunlcatiom
with the Ban kru ptcy Recovery ven dor; to
These missing elenents are required by Chase Third Party Oversight (TPO) policy. TPO policy requires that contracts consolidate t he monitorine tools,
for third party relationships should identify measurable minimum performance standards or service levels for the
services provided by the yendor, and the Scorecard should Include and monitor seNlces olf of these SI.As from the
contract with a Delivery Scorecard provided to the vendor 0/1 a Monthly basis for Tier 1/2 vendors. Wh Ue
. benchma rks, and feedback
Un da·, e ·✓ e nd or M,, na gcr-nc n: Proced ures
lo in rludF! r.h.:rnninr, p~s(wr,rd n.! \/t>nrloi
managemem has established a quarterly assessment process to review the vendors' services, the reiults of all the l 'llti :11ed i·1'orm.=t:ion every 30 d2vs
services revrewed are net r2por tcd on the current Monthly De!IYC,Y Scorecard as required, and the contr;,cts for
these vendors do not include any measureable service ievels1 which weaken; the effectivess of the vendor
management and may make any recourse with these vendors difficult.
Vile recommend mcrnagement upd.:He the contr.lets with lhest: vendors to include- me.:isureiible SLAs for the
services provided, and enhance the monthly Delivery Scorecard to monitor vendor performance off of these SLAs
for ;:ill servi ces provided. I
4 Bankruptcy/Forcdosur e Activities performed bV Recovery Operations: Action Plan: TSO
Recovery Operations pffforms bank, uptcy and foreclosure activities for ct-,arged off loans with processes that are
not consistent with similar, more stringent processes ir place with the Mortgage Banking teams who service pre-
charge off loans (MB Bankruptcy and MB Foreclosure Operarlons teams) Specifically, chain-of-title reviews are not
be ing performed to ver ify and document ownership of Notes prior , o a POC o r a surplus funds foreclosure fi ling,
which are bo:h fried as sworn documents. While Chase Legal has indicated the upstream teams perform thorough
chain-of-title reviews prior to filing court documents as a best practice in accordance with Consent Order
requirements, not regulatory requirements, we recommer,d management review existing Recovery practices for
Bankruptcy and Foreclosure activities and determ ine if similar con t rols should ue implemented ror con sis lent
oroc1?.1Slni!. of these activiries throunhoul the Mcrtl1.aGC Bank.
5 Recovcry Call Quality: The recently implemented internal call monitoring quality assurance (OA) reviews and
monthly reporting have identified sustained below standard quality rates for internal recovery calls. The QA process .
Action Plan: TBD
Engage Cen trali1ed Call Qaality team to
conduct monthly calibration sessions and
includes;; review and scoring over Legal, Compliance. and Policies and Procedures adherence Established Largel
quality rates are 1D0% for Legal and Complionce adh erence, and 95% for Policies and Procedures "dherence. The develop process to action negative
QA providP~ WP.P.kly u orfatP.c;; to thP qecovP.r\i Te;im, whP.rP. trP. n d!=: rmd ri=irnmmi=-ndPrJ .:iction~ iHP. dii.c1Ji.c;pd to rfrivP trends
improvements in below standard quality rates; however, the reporting has shown rates remain well below the Cre;ite thre~hold; to identify Recovery
established targets for the :ast six months (January -June 2D15). The following 5 month .:iverage quality scores Collectors performing below
were observed in the monthly QA monitoring reports: expectations and require documented
Legal and Compliance: Average quality rate of 75 1% attendance ir. the calibration sessions
ADD 126
. Policy and Procedures: Average quality rate of 36.7%
We were unable to id,mtify any formal actions taken by Managem~nt to identify ar,d root cause the drivers for
these below standard monthly scores. Additionally, these scores were in line with Audit's independent review over
20 inrernal recovery calls fror,i May and June, where 3 calls (15%) were identified in which proper authentication
did not occur [Legal and Comoliance adherence), and in 2 calls (10%) the collector did 110L µruvid~ a quali t y
customet· experienc.e (Policies and Procedures adherence). No complilints have been opened in relotion to the calls
we observed ,hat were not compliant with existing policy and procedures
Audil recommends Recovery rnanagemenL enhance call quality by providi11g appropriate Lraining to internal
collectors and enhancing procedures/saipting as necessary to improve call qua lily, and establish formal processes
to action negatlve :rends identified throll{lh cal I monitoring QA reviews.
Action Plan,
I
6 FDCPA Control Report, Testing of the FDCPA control report whlch is a kav report utilized by manaeement to
identify violations ot FDCPA that occur with Recovery collectors determined the following: *JIRA Reque,t#537 submitted to enhance FDCPA
Case I hree - New York City- This case identifies all calls within the five New York City boroughs. ll was report to capture all NYC borough zip codes and
• the SL code for Connecticut borrowers in the
determined that the NYC Borough is comprised of 178 zip codes and the coding identified utilized 175 zip
codes. 10065 and 10075 were missing from the coding. Of the 12 calls identified in zip code 1D055 that reporting.
were not included in the NYC FDCPA Monthly Report, zero calls were determined to be potential 'Perform UAT LeslinM over changes to repor; lo I
violations. Rom cause was coding did not include Lwo zip codes: 10065 and 10075. ensure changes implemented appropriately.
. Case Seven - Connecti~ut- Ir Connecticut no messages are allowed. Audit determined that 13 potential
FDCPA violations occurred during :he month of June, and the lune Fl)CPA Monthly Details Reports did not
I
identify 10 potential violations (additional review by management determined these were not violations)
Root cause Is coding for the FDC?A Monlhly Details Report w.s not complete and did not include SL-
"Alternate Number." for Case Seven.
For both of the above observations, potential risk resides in the completeness of the FDCPA report to properly
identify ooten1lal FOCPA violation,. While the incomplete logic observations idemifled b f Audit did not oignif;cantly
impacl the reporting of violations of FDCP/1 wi:hin the report, we recommend the report logic be enhanced to
capture all loans applicable to FDCPA violations for appropriate reporting
7 Change Management : An opportunity to strengthen com rols within the Decision Masters dJange management Action Plan:
process 2xists by implementing o formalized and documented review process specifically designed around test 'Enhance change management procedures and
results that are reviewed and Villidated by 3r. individual In addition to the person performing the testing. .4 review submit cbange request tc update written
and aprroval of the testine results would decrease the risk of incomplete or rnaccurate testing results. procedures to require a review and approval of
implementation testing results as a part of the
ch;mge management process.
g RCSA : The Ride and Control Self Assessment !RCSA) for Recovery Operations folled to identify the controls gaps or Action Pl~n; TBD
ineffective controls identified by Audit regarding Recovery policies and procedures, Deal quality assurance, and
control reporting (FDCPA control report). We recommend Customer Assistance Controls incorporate the missing
controls identified by Audit into -:he RCSA, ;ind enhance valid;1tion testinJ over the controls in the RCSA to
aooropnatelv confirm control effectiveness.
Access Administration (Draft Word ing): Audit's testing identified instances wnere users had excessive or Action Plan: TBD
9
inappropriate access to the Recovery One application. Specific details of the observation are below:
. 9 users had excessive acce~s with update c.::ipc1bility when such users, as a part of their job functions did
ADD 127
not need to make upna,P-5 or cha~ges to the information in Recovery One.

• 25 users did not need a,cess to Recovery one to perform their Job functions and as such had Inappropriate
access.
Access to the Recovery One application should be controlled so as to minimize the risk of unauthorized disclosure
10
of confidential customer information.
Data Confldentlallty: Passwords for proof of claim submissions are not rhang~d on a r~gular basb. which increases
the risk of unauthorized disclosure of confidential customer information.
I
Action Plan:
See Vendor Managem~nt
JPMC-MRS-00208920
confldentlal Treatment Requested by JPMC
ADD 128
CHASEO
Audit Rating Definitions
ADD 129
SATISFACTORY NEEDS IMPROVEMENT INADEQUATE

AUDIT RATING DEFINITIONS Internal control processes are Internal control processes are not f ully effective Internal control processes
operat ing as designed and are and require management attention Risk are general,y ineffective.
e<'n1>r;il1y effective Risk management processes require improvement, Risk management
management processes are as some issues were noted. processes are ineffective,
effective. ils se veral issues were
noted.
Key Report Element Dimensioning Guidelines
Cn nrrols ere adequately designed. Control~ tHC not adequate:y

Control Design
design~d
D~~ign ,md sustalnabilit\' of control systems,
proc:(lc;~cs, r:ind pract1c~s for Key business
p1oc.c.~ses, systems, and risks.
Contrub ill e inecffective.
Control Effectiveness Controls are effecr·ve
Effectivenes£ of operational, technology,
governance, and risk management controls.
Appropric'JtQness of defined tolera,')ce limits
1::1½1, r1I::: ·.J1 (1'"1 ;-i~,1cri-: "11 l11Lk lI', fl.isl< mitir,iltion practices, including co mpemat i ng Risk rni tig □ tion proce:,sc-s,
Rlfk MJtlg~tion
C':'"•r•r ;.~<,:,t,nf rf1~troi .. h;pi,_: '..It{ ll controls. hi:ive bl!~n est:Jblished but arc not fully including compQns::itinr.
Eff!ICtt""" <n cont>'al l~~.l'tomlrlz,,te etfecttve. controls, are nonexisten t ,
L•~.JJli 1. 'L'r. ,m:J ,-; •,: c:i;,; 12 11 \:
bus en, p,oc.,,,,, t...dvi~1 ;\ d Ol~~ •b insu ffic ient. or ineffective.
c• ffr!:::: 'N v (lnh,,:,r~nt ri~k is \IE:'r1• ltWI)
A rnhu,1 pmc?S5 !o idrntify c.Jntrol !. ;,;0'""c:::.1r.,1r.1" 1I -~ !{•--it·, v-.,,,: ~·111-'-<., -:, . q, 11 11 Ma1cgement has no process
Issue Identification ·1
w~akuc.!~~L'~ 1.:xisb, and idcntifi~d issuc-s f f')i l.r:•r 1:ff 1. ,..i '\r S,··J('I :1 '·'•'· ::~ :·,:: •,• f \•.'~ to idC'mify con1rol
Robustness and reliability of manage men I 1:-ir.1Y. 1~,_,r1 .-nr'c. : 1:,.•,1.1•~ 7;1,n"')l,;11 , ,1 •J••\1 ·:;. •·1\=f J \"J~ak11e:::.~1=s, or t hL• prmt::::.!, ,s
are am:irop ~1 ate lv ad dressed
processes to proactively identify control
(QA lS :h::- ::irly 1:,<:.U:' not identified. Tl,e (~~U(' I~a~ incffoctiv~
we.Jknessl'S, e,ro~, and exceptions. ,,.,,;"i r .... ut:o'. f'i •<-il,ltl ,nrl '~'-'".:Ulmr, bv !h,, OA 11.1n, \
D-: t.r ·~ll '~ r,o:: "i.. [1_,~,-:1.-,, ... I'd: ol Yh1•1 ·,,-.
1 Dr.di:::ienci~~ µu:::.c r"l1 □ clera rc risk of tidverse i mpact to t he D~f1dcncics pose signif1c;:mt risk to
Rl~k EJ(pasure firm r1nd/or clicn1'.i of the firm. Man agement shou ld the fi --m and/o r cli ents of t he fi rrn
i·n;r,-:1 r,:: ti·•. (i,-r, ,-.1.:;/:r r'1c--1 .-:/ th,:
POll'lll16 lm pllCI c,fld,awn and cdo-ntlfl•d Ma1c:gement should addres5
[: ii :,f, 1 1a,:r.rr \··111 '.'IC.,l:i rli)f!I(• ' ddi..l1t>S!t i<.Jt>nt ifit:-d toutrol weaknesse!l as a mar:erof
IL:':; ,·,t 1f ,,·cl c::: 1'"1tl ,:.I',\·:~ ,'<I:~,.•~. :r::, ·,•,•11,.' t'" priority ic ent 1fied cor.trol we3knesse3
ur.orr r,l.~F. irrun,;;digtelv.
{ ~,n1 ~, {i ,•,·.- c'.".o:.,.· r,'(•:· l'-l~n1'; Control brc:ilcs o r Nronoccur pc-riodi:.1lj,,, Control brcJk!'. or ~-ror.; occur
lSJue Probablllty :· , .,, 111
frcqueollf.
· ~ t ~•IJhi>-OCl 1,r Ir lltlltYthat.eontml
1
~.i~, occur In the -m•I (OUJU of busincu
opf.(~tiop•
Audit report ratings are reflehive of the scope of the audit.
JPMC-MRS-00208922
Confidenlial Treatment Requested by JPMC
ADD 130
EXHIBIT G
ADD 131
Mortgage Banking
CHASEO Business
Requirements
The purpose of this document is to describe business requirements completely, accurately and unambiguously
in a Technology-independent manner. All attempts have been made to use business terminology and business
language wfli/e desuibing the requirements in this document.
Walk Population Lien Release

Version: 2.0
Work Request #(WR): 13029927 I 12048923

Quality Center Work Item
nwuber(s) #(QC):
Requirements Author(s):
Demand Management ID # (DM)

Ente:rprise Customer and Deposit
ID# (ECO)
Business OWnership
Executive Bponsor(s): Steve Hemperly
Business Sponsor(s): Lisa Shepherd

Project Management
Program Manager(s) - Business: Tom Monson
Program Manager(s) - IT: N/A
Project Manager(s) - Business: David Meyer
Project Manager (s) - IT : N/A
Others
Business Architect(s):
Solution Architect(s):
,..,N
0
N
..:::.
1..1
....
ro
Page 1 ~
~
ADD 132
Project Name Vers i on #
• 8/2/2013 Presentation to Gordon Smith for approval to proceed with lien release.
Lien release decision was deferred . PowerPoint from presentation attached below.
The following files outline how the number of loans was arrived at for the 1st lien "walk"
population.
The following PDF contains the 1st and 2nd lien potential volume. The potential
number is greater than 200,000. Looking at the 1st liens only, the center column, the
total Charge Offs plus the Walk/AFP add to 62,003.
Lien Release
WaterfaB Analysis
The following URL will display a Sharepoint site with an XLS file with the loan details
(filters include only Client numbers P156 and P465, also the MAN Code has been
filtered to include only code "W" - walk). The result reduces the 62,003 loans down to
56,875 potential "walk" loans.
htlp://sp001 .jpmchase.neVsites2/spxhshrs/AC2/Forms/Allltems.aspx?RootFold
er=%2fsiles2%2fspxhshrs%2fAC2%2flien%20Release%20on%201st%20Lien
%20Walk%20%2d%20Charge%2doffs%2fBRD&FolderCT ID=0x012000CECB4
8A6C2C6E443BAE49420211E6A50
The following PowerPoint file is the executive presentation give to Gordon Smith on
8/2/13. Slide 2 breaks down the 56,875 loan population into categories. The initial
management decision expected is to facilitate the release of 15,085 investor owned
loans.
Exeaitive Update
Powerpoint
4.2 Out of Scope Statement
Scope
Item Out of Scope Item Description
#
The forward flow lien release process created as part of the DOJ settlement fo r Charged Off loans
1.
as of 10/1/2012.
2. Any OCC or D01 related lien release requirements.
3. Any anti-blight fund project initiatives.
MB Business Requirements CHASE O Page 12
ADD 133
Project Name version:#
4. Any recovery efforts associated with balances post lien release completed as part of this project.
No letters will be sent to borrowers or municipalities to alert that Chase is releasing the lien on the
5.
loans in scope for this project.
No debt will be forgiven of borrowers associated with the properties which have received a lien
6. release as part of this project, with the exception of states where on amended release is not
possible. In such cases the release w/11 state that all obllgatfons have been satlsfied.
Bank-owned second liens where Chase is still in lien position are out of scope for this lien release
,
7.
effort.
8. This project will not require submission to the NBIA process.
MB Business Requirements CHASE O Page 13
ADD 134
EXHIBIT H
ADD 135
USCA Case #19-7025
Fr<lm: Adammlic, Rober1 I<
------·-·---------- -------
To: Hens~~. llf!Stll R :90¥1e, Palritk M.

CC: Kassem Omar ;Adamm.ic. Rober1 I("
Sen!: 8/21/2013 7:07:00 PM
Subject: RE: ((( 1st Lien Release E>il Meelir,g Agooda )))
I spoke to Mike last right and ,-e agrl'!ed lha1 we smud bring legal into the discussion for question nunber 3. Was planning on pc sing the question lo GIEm and Bob L today (Wiiii,,,a rot iiliiii fite>.-@iri ~ o r ~ 1$eoau,ie!I
li'fffii""p'is1 \fuooToi"com i"a., ~elt11S95Jo • OOJ ~ ~ l . '° ,~--~
\l;lil,v,:iw;t..ret(I to--litart.~,lhat~ c1e~r:ei::101 11:11<;ocitli'iii'Ciii s. lib pco~ l>Gaofl'\!S~ ei---1s-1eo~f811 i;--ffll!IUHI r/19
~ I i , ,,, """"'.-....,.."'il.l.~ iiosns.sron or ll'e fl<op,,t\Y, 1m unsLll! if ltlis Is 1r<1y aregitauonor'c11l'ilge!ltla nem (or Ltsa. B~ -•10Ud s11n ~IG l'I09I ,vr.it li!gats opiiion ,son the maner. \"JID.a!sti pase Ille cr.-,onto c;;;em em-Bob 1>1oday
~~Gr.ave . . .. . .. ,__ . . ...
1uc1 a.mu~~ ~nbTtfoiijli'liiJoiw,.1c1ft\O. ..ti<:nwsls S1.9.s30.p91...u;c;oirt,,.ef ~ o. cu~ o,~ of q,..esGorl lf "e have !o m\O 25k acco\111• ~ r month. lniiadiUof\ aren't we still required lo o.pkeep the property vihelher we just walk
a.'13Y 31'0 ~ - r~ lien or not? Good incite This en&re Issue llegatl llecau$a lls-l·s gr~ 1PropPJ1\• Pr%~rv/ltjon) is required lo maintain '-'1keep on some vacant proJM!rt•es; this is de~l'ldenl on cay regulations T~y warit OLA; lharefore, they
are pushing for nen releases on ail 1'1 l•ens.
Document #1793945
~IPf-~~11••~~'l•~~P..f'VJ:t11V1'o',~l11JJ"W,--~~f1."l-,~=-i,'I' oWWlf,~/\•~r ~~.:,t'-.t.J!..r··r.~ ~~-~~~~ ~<II~
!~ ~· J~~~_____l<r.:.
~~ ~~t .g. 0 I - ' ~_:_ ~ :_)'L,J - .:, [• t ~- t;; b.~ ~ca 0,,,,..-... . , (
··-
• • Title C learing·
JPN'"811 lihase llank.NAllthMle
Doclfflll1111111.!iilllllmiWlllalla Pnllat #lllrtlm
,..., -·
Filed: 06/21/2019
Doc~ Refllnalme11 Vllldallon IVIIIII
!\ITC R~Sterth •~ s 352,393.00 S 8.50
Researth Pass-Through Costs• s 468.625.35 S 11.30
-
• 1rc-JJfta ~~ro..""fa,,. (o;,y COffJ, Ottl'M' IH! $ 121,018.35 $ 19.IIQ
lllrlllasa t:nllttll ad kCOld8tllll Tllll

;,rrc Release Processing Fee s 248,748.00 S 6.00
Release Recording Fees S964,599,58 S 2,.i1
r,_,,ail Fees s cl.1,458.00s 1.00
$ 1,254,805.58 $ 30.27
Page 138 of 151

Robert Adamovic I Strategic Operalions Manager
ADD 136
Confidential Treatment Reauested bv JPMC IPIIA~_I\A~~nnnr:.r:.i::i:1,1

USCA Case #19-7025
Mortgage Baridng Loss Recovery I JPMC
1820S Sky Halbor'Cir, Phoeriic. AZ85034
Offtee: 602~-8730 I E-Fa,c 602·396-5010

Email: -,obert.k.adamovir.@chase.com
Fran: Hensley. K(,sla R

Sent: Fridav. J...e 21. 2013 8:2~ AM
To: AdllmMC, Robert K; Boyle, Patriek M
cc: Kassem. <>mar. Palellas. Parttos
Subject, RE; ((( 1st Lien Release Eldl Meeting Agenda)))
--rt.
I si,oliii,fif~ lad dgtUM ai,wd 'hatwesll>ud bfirG ~ lrto U)II .Ssa.is,ronr01 q,MSliol\runbet3 We hav•not falre11Wc:u1cco11'11 ........ or 1>0tth9-property lu i ~ tt1 .-1 i/orOO:, at 01'IWll i~•uen rele..s \ ( ) ~
reQJ,emer6}. ~ rm 1'10'-sttt -IM'.ilid neoe410-1tanwngtretas edett1rllHrQ facRj-. Bli wowd
5111 illelO" trar•;ma11e9a1"s- opi<i'onts on IIYH1'1'1!ef
Document #1793945
IDOis. tltrlii- WlZ~ ,n lt-e ~ l l'O ~~OCG\,lpal'q atd how camidel1< ~Wl!'ill Ill& tl'AOJTl1atfo/l? In acl(MIOll. aren't we stil reqtJred ID I.peep the property whether we just walk away an:! release the Uen or not?
Krista Hensley I Vice President. Recovery Operations I Mortgage Bankirg I Chase

1820 East Sky Harbor Circle South. Phoeriic. Arizona. 85034
602-827~ (work), 877-593-0104 (faxi
Krl•~••v•c~as@."""'
Ftom: Ada~. Robert K
Sent: Ttusdav. Jme 20. 2013 2:08 PM
To:~. Pallid; M; Henste1, Krista R
Cc:: Kassem, Omar; PaleUas Parickos
SUbleel: FW; ((( 1st Lien Release E>dl Meeting Ageflda}J)
Olring the projf!dca!l lodai,. Lisa stated Iha! she mat wilh Hemperly and he is - a that there are 1st Jens in Recovery tt,at have vatue W would ody consider1he possibility of keeping the liens inlact if we metlhe 3 requremeritsbelow. S!eYe has
requested U\e folo\Airg irlormation ii \~ want to make a cate to keep Ille 1" lilns lrtact:
Filed: 06/21/2019
1. 11t Lien Rev;mue Trend Analysis
a. Provide 2012 revenue. S20MM
b. Provide YTD reverue - $6MM
C. Provide 2013 forecast- S13MM
2. Does Recovery nave Ille llllil,ly to va~date oc;cq,ancy? Accordino to the New Rules (LnSlle 11.tTat she was referring lo), if a home becomes vaaint Chase i$ required to mairiain !hi! ~ or in some cities required to take o~hp
th-ough a (orecloS<M"e, ·
a. Parid<os did develop a process lo ID oc.cq,ar,cy for AFP bl.t ii was far from peifeet and was a 1x scnb
3. Legality of fair treatment
a. If we choose lo rel!!ase lhe li!!l'I on vaeari accou,ts orly; wil that pw Iha firm at risk for not provkf,ng fair ana consis1en lrealmenl?
b. If we ChOose 10 release !he I,en on amrt payer I SIF, SS: 'Ail lhal cause a oacl<JaSt\ from the customer tor r.m1r treatment? V\11 lllis cause the customer 10 demand all payments or cause a suit?
How do you want to PfOceed? ShoUd I engage Panickos and Legal?
Page 139 of 151

Robert Adamovic I Strategic Operations Ma,agar
Mongage Bal"lking Loss Recuvery I JPMC
1820 S Sky Harbor Cir. Phoerix. AZ 85034
ADD 137
Confidential Treatment Reouested bv JPMC 10u~..u0~nnc;c.~111:.

USCA Case #19-7025
Offlcv: 602-627-8730 IE-Fax; 602-396-5010
Email: roberl.k.adamovie@chasa.com

From: Mamovc. RDl>MI K
Senl: Tlusday. Jlft! 13, 2013 9:34 AM
To: llo\,te, Pallid M
Cc: HenSiey, Krista R: Kassem. Omar
SUbject: FW:((( 1s1 Uen Rell!ase E>I M~lng Agende '1)
st
We are coming to lhe end of the or \tis project and Lisa Shephetd may have U-.Own a cuvebal She stated that aff charged off secued ownedlseiviced 1 fiens v.rill be released rega,dless or if the accomt is cwently paying, lm,olved in a short
sale. or is in good conditiorvoca.,pied. 1was in:fer 1h8 impression you were stil vetting~ question v.ith Hemperly? was a decision made lo do a !Iii release on the Recovery 1 portfolio?
91
Document #1793945
Roben Adamovic I Slra1egic Operations Maiagar
Mortgage Barjdl'IJ l.oss Recovery I JPMC
1820 S Sky Hart>orCir, Ptloenx. A285034
Office: 602-627-8730 I E-¥ax: 602--396-5010
Emait robert.luldal'novjc@chaSEl.com
Fran: Meyer, Dal.(d W.

SUit: Tiusday. June 13, 2013 e:39 l>Nt
To: l.ie!l Release Proleci Taam
Sabject: Lien Releese Meelhg Ag<,nda
Attached is the mmr,g ageme ror today's Lien Release process re-.iew meetill! 3che<Med for 11 AM Central time.
Filed: 06/21/2019
Da\llcl Mayer, PMP I t'°"9:!lg@ ~,,._~ DE-hlA Pr0tttf Marag.t-b'lti"C I J"P."o1~an f.lus,
Email dl-'d.W [l'e\-e-lftpndaM; OO!D I FhDDO! 1: of-6:J>.::28'J71 =i'B~·
Ult!@ ·!1st! Or Ma•l!k>p: TX 1-:4J I L11?1.WS\tlo!! T.< 7~0~7 USA
CHASE O
~-r.
~,tu!! ,!'ll,...... ""'> tei\tu\.t,~ t-111~ :'l.ln'..a·.-.;11J Mrr.=a!Jo::. If .n:,,~. •-N•l.., ,. ,r •rn,1 p.u.. ~.ru ~.u,"VHrb7 r.pf'.1 ..n,a,}.:,:j :1:''T'..O.RIJ!• .:,.w. ~l!"ll!IIJIP, ''-C' ar.ya!f9("1fflo~~~c'~•~fl"',dC('~f¥-- rO,W~ Tl=.ar.K !,'OU
Page 140 of 151

ADD 138
Confidential Treatment Reauested bv JPMC JPMC-MR~-nnn!'i.E,FIRA

EXHIBIT I
ADD 139
Instrument \lolut11e Pas@
20140000~823 2936 10
WH!JC•0•J482J
File,d for Re•:<:>rd in
C~DDD CDUHTY OKLAHOMA
PATRICE DOLCH, COUNTY CLERK
05-27-201~ At 10:18 om,
RELEASE I~. ()O
Volu1t~ 2'136 PaH 10 - 10
V-l<'Whcn Rcu,urdctl Re1um To:
Jl'Mori; n Chase U3nk. N.A.
C/O Nationwide Title Clew-ins, foe.
2100 Air. 19 Nonh
Palm Hnrbor, FL 34683
Loan-#: 00118!1S209R
VACATION AND RESCISSION OF
RELEASE OF MORTGAGE
I. A J\1ortgogc was mode by 1..EANDER G. ECK[WAUDAH AND DEDBlE L. ECKIWAUDAR to
AD\IA:'IITA
NATIONAL BANK And rccort!cd in lhc <>A'icc of the County Clerk of CADDO Caunt,Y, Stote or OklohorM, in
Boak 1200,
antl/or Document ~ 9900236 upon Ute property siluated in said Stale and Counly :is more full y desetibtd in ~.iid
Page } 02.
Mangage or (if needed) her,:in to wit .
LOT 1'WO (2), BLOCK TWO (2). PRAIRIE VILLAGE ADDJTlON TO THE CITY OF ANADARKO, CADDO
COUNTY, OKLAHOMA, BEING A PART OF THE NORTHWF.ST QUARTER (NW/4) OF SECTION FTFrEEN
(I S).
COV~TY.
TOWNSHIP SEV[;N (7) NORnL RANGE TEN (10) WEST Or TIIE lNPl/\N MERIDIAN. CADDO
OKLAHOMA. ACCORDING '.fO THE RECORDED PLAT THEREOF.
the " Release") of said
2 . 'll1rough iMd \·e.ne1ice and mistake lhe undersigned executed n Release of MongaRC (hereinafter
Mol1gagc, which Rclc:i..e of !llonsase was RECORDED 11/1312013 IN BK; 2915, PG: JS8,
AS OOCH 201300009886,
DATED 11/1912013 in the official records ofsaidCounly.
the Release hod never
3. The undersigned hereby cunccls and rescinds t:he Relcose 10 the same ex1cm and eifec1 es though
been i,.,uecl and recnrded
Date.cl on ,a5.,, 1'3 1_ /</(Jl.tM/DD/Y\'\'l')

i.~.
ct!:
JPMORCAN CIUS£ SANK,
n,,r
. Ingrid \\\i
VICE PRF.SWENT
- -=
STATE OF LOUISIANA
~'O~ Cli!: ~ ( MM/1)1)/ YYYY), bcfor, me oppean:d Ingrid Wlully.
On A I~
P me petJor.~lly known. who did
lrl ~D)
in<in.,mi,111 l\':l< ~le,n~d n
1h01 hr ~hl'/thty ,cJ.v,: 1h VIC I! PRES IDENT of JP;\10RGII. N Cl-!ASE BAN K, NA.. ~nd thot 1hr
n:knowlcdscd :he
bchalr 11: the CO"J">rution tor nssuciu:ion) , by uutl,oniy from 11~ bonnl or director.. onJ rh bt hc/flu:/lhey
lo51nl mcni to be the free m and deed or the corporau0t1 (or assoda1l0n).
'"'•" -~
Notary Public - Stare of LOUISIANA
,...,,. eo•"'
OUACHl' M 'AAI SH. LOUISIANA
IFfY...1c: COIJI.' ss1n
Commission expires: LIFErlME N01/\RYIO o <'-19
Documenl Prepared By: E.LnnceJNTC, 2100 Alt. 19 North, Palm Harbor, FL 34683 (800)346-9152
CHAS6 23641892 _-PRIME TlZl-4055810 [C-1] RCSOKJ
111111111111m111m1111111111111111111111111 WI I111111111111111111111 lllll lllll lllll lllll lllll lllll lllll llll llll
Jgrl4o•
•l)f)(l(MI I
SA00327604
ADD 140
EXHIBIT J
ADD 141
USCA Case #19-7025 Document #1793945 Filed: 06/21/2019 Page
Instrument# 144 of 151
2015-188092 # 15
Book: 7172
Page: 11233
05/27/201' 07::U All
Ind:naentl 2014--092821 I I
Book: 6992
Page: 3573
D1UIII N. Namuaek
Wbtn RtWl'ded Betam Toa Vo1ua1a Colrity, Clerfc of r.oirt
JPMorpn Chnae Bank, N.A..
C/O l',lallonwlcle TIiie Clearl1111,
Ille. 2100 AIL 1, Nlll'III
Palm Barbar, I.IL 34611!
Duaameni Pn,pand B71

E.Lllllc:e/NTC, 2100 Alt. 1ll North,
Palm Harbor, JIL 34683
(800)346-9152
Loan#:
VACATION AND RESCISSION OF MODIFICATION OE' M()RTGAGE

RBCORDBD 11/19/2013 JNBK: 6930,PG: 4838, AS DOC#: . . DATBD
ll/06!'20Lg
I, A M01tgagi, was made by PATRICIA B, KING and recardad in tho Official Rcr.ords oftha Ocrk of the
Clroult Cowt of VOLUSIA Conni)', Flmlda, In Book 61'4ll, Pap 4414, or lnetrument # 2007-2415690 upon the
property aitualed In aald Stale and Coulll)' as mo19 folly deecriboil 111 11id rnartpgc.
AS DOC#: ·--·'ll!D
2, 'lbloush iDBdvc:rtoncc and mistake the undeiaigned cucuted a Home Affordable Modlficadon of (hereinafter
the "Modlficad011") of said Mortglll!e. which ModlflClllon w11 RECORDS() 11/19/2013 IN BIC: 6930, PG: 4838,
ll/06/ZOU h1 tho ofllclohwo,d1111f Hid O.nmty.
l, ·'Ille underlllgned hereby c:a11cels anll rescinds the Mlldlllcauon IO lhe aame mont D11d effect u lhoup Iha
Modification ~ad n6ver been 11181111d and lllCOnlcd,
Daiei ~.J.l=..j_!j__ (MMIDD/YYYY)

JPMORGAN CHASE DANK. N.A,
By1~------
VICE PRESIDENT
CHAS6 23641573 _. PllIMB T09t40ml4 [C.I] llCSFLl
IRllU IIIQWW! m1H11 mn 11111 f l 1111 lll~l~IIIHHIHlllllll~m11111

•23641573• •
SA00433946
ADD 142

2019.06.21 1793945 Appeal 19-7025-Addendum Declaration Robert DiMarco (114-142)

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USCA Case #19-7025 Document #1793945 Filed: 06/21/2019 Page 1 of 151

UNITED STATES COURT OF APPEALS

'LVPLVVDO2SLQLRQ 0DUFK $''

UNITED STATES DISTRICT COURT

DECLARATION OF ROBERTO L. DI MARCO

I, Roberto L. Di Marco, state that the following is true:

1. I am a partner in the law firm of Foster, Walker & Di Marco, PC.

in good standing and my Massachusetts bar number is 645157.

3. I am one of the attorneys representing the Plaintiff-Relator, LAURENCE SCHNEIDER

("S&A"); MORTGAGE RESOLUTION SERVICING, LLC. ("MRS"); and 1ST

of New York ("the NY litigation").

NY litigation, Bates stamped JPMC-MRS-00051154, titled Chase Default Customer

Management: Mortgage Banking Recovery.

NY litigation, Bates stamped JPMC-MRS-00319625-00319628, titled Audit Department

NY litigation, Bates stamped JPMC-MRS-00208917-00208922.

8. Attached hereto as Exhibit G is a true and accurate copy of excerpts of a document

produced in the NY litigation, Bates stamped JPMC-MRS-00155219, JPMC-MRS-

00155230-00155231, titled Mortgage Banking Business Requirements.

litigation, Bates stamped JPMC-MRS-00055684-00055686, from Robert Adamovic to

Krista Hensley and others, dated June 21, 2013.

NY litigation, Bates stamped SA00327604, titled Vacation and Rescission of Release of

NY litigation, Bates stamped SA00433946, titled Vacation and Rescission of

FY2012- ov..n.d Recovery

..., ...... ·-· ,....,

Confidential T reatment Requested by JPMC JPMC-MRS-0005 11 54

JPIV[ORGK'\ CJ:L\SE &Co.

Home Lending - Recovery Operations and Recovery One (RCV) Application

Prior Report Number: M-06/019

Business Overview and Context

CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00319625

CONFIDENTIAL TREATMENT REQUESTED BY JPMC J PMC-MRS-00319626

Level 2: Home Lending

Location: Texas, North America

Detailed Findin~s and Mana~cment Action Plans

CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00319627

Target Date: October 31, 2011

Issue: Source System Data Integrity

CONFIDENTIAL TREATMENT REQUESTED BY JPMC JPMC-MRS-00319628

No. ObseNatlon/Recommenda tion Manaeement Action Items, Owners, and

. there is no reference of these in the existing policies applicable to Recovery Operations.

. 0 Methodology does not ensure proper coverage of the population.

. crirical" error which does not appear appropriate.

Confidential Treatment Requested by JPMC JPMC-MRS-00208917

. bankruptcy portfolio for Recovery

Confidential Treatment Requested by JPMC JPMC-MRS-00208918

. Policy and Procedures: Average quality rate of 36.7%

Confidential Treatment Requested by JPMC JPMC-MRS-00206919

not need to make upna,P-5 or cha~ges to the information in Recovery One.

Audit Rating Definitions

Confidential Treatment Requested by JPMC JPMC-MRS-00206921

SATISFACTORY NEEDS IMPROVEMENT INADEQUATE

Key Report Element Dimensioning Guidelines

Cn nrrols ere adequately designed. Control~ tHC not adequate:y

Walk Population Lien Release

Work Request #(WR): 13029927 I 12048923

Demand Management ID # (DM)

Business Sponsor(s): Lisa Shepherd

Project Name Vers i on #

4.2 Out of Scope Statement

2. Any OCC or D01 related lien release requirements.

3. Any anti-blight fund project initiatives.

MB Business Requirements CHASE O Page 12

Confidential Treatment Requested by JPMC JPMC-MRS-00155230

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