In a new report entitled “The Title Crisis: Clouded at the Core”, Foreclosure Intervention Specialist (and former Fannie Mae Broker-Specialist) Mildred Wilkins lays out what is really going on underlying the “fraudclosure” scandal. The report is a response to bank and government propaganda that the crisis has been “looked into and resolved,” after the furor that erupted due to a number of high profile lawsuits, rulings, and mainstream media articles early this past fall. In this first-publication of the report online, ML-Implode brings you Mildred Wilkins’ powerful words and in-the-trenches perspective.

(See Mildred’s web site at “Foreclosure Intervention Specialist” is a registered trademark of Mildred Wilkins. This article is Copyright, all Rights Reserved Mildred Wilkins and Mildred Wilkins Consulting, LLC. Posted with special permission.)


I would have made this report shorter if I could have explained what you need to understand in fewer words. I honestly didn’t believe that I could, so I have written what I feel compelled to share. It’s long, but developed in such a way as to provide an adequate background, lead you to factual information, and give you a professional analysis of the broader picture.


We have been assaulted with revelations, facts, anecdotes, bankster PR and media spin for more than three (3) months now discussing and uncovering the fraud associated with the foreclosure problem in America. We’ve had congressional hearings, interesting legal decisions and the promise of a riveting expose from Wikileaks founder Julian Assange against one of America’s largest banks. If he can manage to keep himself alive long enough to deliver, we could have revelations which will make the stuff of the past few months kids’ play by comparison.

Thus far the startling revelations have come so fast that all of us are waiting for the other shoe (or next unbelievable TRUTH to be revealed) that we have been left with barely enough time to breathe, certainly little time to analyze anything before there is another incredible revelation. Headlines such as “Judge refuses to let public into his court room” are now common. There is more research, follow-up, corrective action. Wash, rinse, repeat. I’ve jokingly (only kinda) told friends I can hardly sleep for six hours straight anymore because I don’t dare not check in with updates from my most reliable sources to see what’s the latest incredulous revelation. If you miss for more than 6 hours you will be seriously behind in your foreclosure reading. My personal favorites are, LivingLies weblog and Mortgage Implode-o-Meter ( Only Living Lies provides lengthy analysis or opinion pieces on what all the ‘facts’ mean or could mean.

We now have a fulltime job trying to absorb the enormity of the ‘facts’, ‘incidents’, ‘life stories’, ‘personal tragedies’, ‘court decisions’ and ‘sworn testimony’ which continues to unfold. It has been difficult to focus on anything other than uncovering the activities of the banksters which are now clearly systemic, anti-consumer and frequently illegal. Indeed, I have had numerous professionals ask me “why are the banks doing this?” “Why are they trying to foreclose while pretending that they really don’t want to foreclose?”

Understanding the issue (and consequently the answer) requires a broad understanding of what I have called for years ‘the BANK GAME’. Almost no consumers and very few professionals have spent any time analyzing the entire banking process—why would you? You only need to know so much to open a checking and/or savings account and get your debit card. You need to know a little bit more to get a mortgage and they happily provide you with the information and lead you through the process. They get your financial information (or as we now know, make some up for you if your true information does not work for them) and presto/chango, you became a happy homeowner. You learned a bit more if you needed to re-finance (this could be dicey if you tried in the past 5 years) but the truth is that they were more than accommodating if there was in any way possible to ‘make it work’. Almost nobody would have called dealing with your bank ‘a game’. They were your bank, there to serve you and meet your financial needs. They told you that and you believed them.

In reality, it IS a game. Perhaps it didn’t start out that way but about 20 years ago (at least 20 years ago) the consumer’s relationship with the bank shifted. No longer was the consumer the most important part of the equation and their needs paramount but the needs of the institution became paramount and the consumer became a necessary pawn in the BANK GAME. You have been drawn into the GAME without your knowledge or permission. You are impacted whether or not you know it and are now faced with external behaviors such as their fore-closure practices which seem suspect. If you never knew there was a game you would also be unaware of the existence of game rules which details all the activities associated with playing the game. In fact there are TWO rule books, the official one and the one they actually use.

The official BANK GAME rule book has rules/stipulations which cover every conceivable activity which a bank might be required to perform but I will only focus on the mortgage related rules since the bank serves other functions. The rules cover areas such as:

  1. The loan application process
  2. The recording and transferring of your mortgage and note (or deed of trust)
  3. On-going responsibility for keeping up with and recording title transfers (for several good reasons)
  4. Steps for conversion of mortgages into securities
  5. Loan servicing requirements, including responsibilities to the consumer who took out the loan
  6. Guidelines for reporting to the government and Wall Street revalent information about the loan, the borrowers and other information, as required
  7. Responsibility of processing foreclosure—when a default could not be cured by any other method—as a part of loan servicing

All of these activities which were entrusted to lenders are governed by a multiplicity of federal laws, federal regulations (not the same as federal laws) legislative recommendations (totally different than laws or regulations AND totally unenforceable (HAMP for instance) state laws, basic contract law and assorted other considerations. When you factor in employee cost and the time needed for them to cross reference all of the above and still make a profit which would allow them to pay billions of dollars in bonuses—off YOUR money—they had no choice  (from their perspective) but to cut corners. It was also imperative that they get really creative in creating new revenue streams.

The necessity to make the most money possible meant there had to be a 2nd set of rules—the
ones they operated by on a daily basis while giving lip service (and the finger) to the official rule book. Everything which has been uncovered is evidence of the existence of the 2nd set of rules and the norm for our biggest banks. Many readers are still trying to grasp HOW things got off track and WHY have the banks been willing to go to such extreme measures to deny actions which have clearly been uncovered as systemic. What does it means other than they are lying?

Let’s discuss the HOW part first.

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