Affidavit signers and midlevel managers responsible for the affidavits told us that Wells Fargo management was aware that they did not read or verify the information in the affidavits that they signed. Several persons we interviewed said that they had expressed concerns about signing the affidavits (such as swearing that they had personal knowledge of the loan and had verified the document’s content when they had not). Affidavit signers informed upper management that they could not handle the workload. Wells Fargo management did not correct the problem and, instead, in a March 2008 email, reduced the timeframes for processing the affidavits from 5 to 7 days to 24 to 48 hours, and the affidavit signers were required to sign the affidavits they received each day at 9 a.m. by 12 p.m. that same day, often signing in excess of 100 affidavits during that time. The following are excerpts from the email:
“The Doc executable team is working very hard to obtain a 48 hour turnaround time for our docs. Due to attorney feedback and our wonderful challenging environment, this 48 hour turnaround time is critical.”
“The Doc executable team is working very hard to obtain a 48 hour turnaround time for our docs. Due to attorney feedback and our wonderful challenging environment, this 48 hour turnaround time is critical.”
CONCLUSION
Wells Fargo did not establish an effective control environment to ensure the integrity of its foreclosure process. Because it failed to establish proper policies and procedures to ensure compliance with laws and regulations, its affiants robosigned foreclosure documents, and its notaries failed to authenticate signatures. As a result of its flawed control environment, Wells Fargo engaged in improper practices by not fully complying with applicable foreclosure procedures when processing foreclosures on FHA-insured loans. This flawed control environment resulted in Wells Fargo’s filing improper legal documents, thereby misrepresenting its claims to HUD.
During the period October 1, 2008, through September 30, 2010, Wells Fargo submitted 14,420 conveyance claims for payment in the 23 States and jurisdictions totaling about $1.7 billion. DOJ used our review and analysis in negotiating the settlement agreement.
Wells Fargo did not establish an effective control environment to ensure the integrity of its foreclosure process. Because it failed to establish proper policies and procedures to ensure compliance with laws and regulations, its affiants robosigned foreclosure documents, and its notaries failed to authenticate signatures. As a result of its flawed control environment, Wells Fargo engaged in improper practices by not fully complying with applicable foreclosure procedures when processing foreclosures on FHA-insured loans. This flawed control environment resulted in Wells Fargo’s filing improper legal documents, thereby misrepresenting its claims to HUD.
During the period October 1, 2008, through September 30, 2010, Wells Fargo submitted 14,420 conveyance claims for payment in the 23 States and jurisdictions totaling about $1.7 billion. DOJ used our review and analysis in negotiating the settlement agreement.
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