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Do We Have a Fraud Problem? The Case of the Mysteriously Appearing Allonge

posted by Adam Levitin

I have generally been willing to give mortgage servicers, servicer support shops (like LPS), and foreclosure attorneys the benefit of the doubt when it comes to documentation irregularities (to put it mildly) in foreclosures. My working assumption up to this point has been that the documentation problems have been a function of corner cutting with securitization based on the assumptions that (1) the loans would perform better than they did and (2) those that defaulted would result in default judgments in foreclosure, so no one would ever notice the problems. I've also assumed that lack of capacity has played a critical role in problems in the default management chain--the system is held together by Scotch tape at this point. In other words, the problems in the system weren't caused by malice.

I got some grief about this from people down in the trenches when I posted a comment about this a couple of weeks ago. And I was tempted to write it off as a function of litigants being too close to their cases. But a document I read today is making me rethink these assumptions. Here is an order from a Florida court that makes me start to wonder if we might have a serious fraud problem going on with blank endorsements and allonges.

To be sure, one data point isn't an epidemic, but servicing is an industry where things tend to happen en masse. As Obi-Wan Kenobi explains: 

Obi-Wan: "A fighter that size couldn't get this deep into space on its own." 
Luke: "Yeah, he must have gotten lost, been part of a convoy or something." 
Han: "Well, he ain't going to be around long enough to tell anyone about us." 
Luke: "Look at him. He's headed for that small moon." 
Han: "I think I can get him before he gets there. He's almost in range." 
Obi-Wan: "That's no moon. It's a space station." 
Han: "It's too big to be a space station." 
Luke: "I have a very bad feeling about this." 
Obi-Wan: "Turn the ship around." 
Han: "Yeah, I think your right. Full reverse! Chewie, lock in the auxiliary power."

To start with, let me explain endorsements and allonges. And endorsement (or indorsement) is a signature on an instrument for the purpose of transferring rights in the instrument. (See UCC 3-204 for more details.) They work the same with notes as with checks and are governed by the same law. There are three types of endorsements. There are endorsements in blank--just your signature, nothing more (e.g., Adam J. Levitin), and special endorsements (Adam J. Levitin to Katherine Porter), and restrictive endorsements (Adam J. Levitin, for deposit only in Safe'n'Sound Bank).

A blank endorsement (by the instrument's payee, of course) turns the instrument into bearer paper. That means it's like cash. Whoever physically possesses the note, including a thief, can enforce it against the maker. And as a recent 9th Circuit BAP opinion, In re Veal (about which I hope to blog more) noted (fn 25), bearer paper has long had lots of nefarious associations (I would add Godfather III to the bearer bonds movie list in that note). In contrast, a special endorsement limits who can enforce the note; only the specially noted endorsee has rights in that note and can enforce it (they could transfer it to someone else, but that's another matter). 

Now allonges.  An allonge isn't a delicious throat-soothing lozenge from Switzerland. It's a piece of paper that goes a-long with the note. The allonge is basically an overflow sheet for extra endorsements. Frankly, no one should ever be using an allonge if there is room for an endorsement on the original note. Yes, it's easier to print on the allonge, but allonges create evidentiary problems, namely that it can be difficult to tell when the endorsement on the allonge was done or if the allonge is even meant to go with that particular note. And I'm not sure what the evidentiary weight of an affidavit or testimony on this point could possibly be. Unless the affiant or witness has some basis for knowing that this particular allonge goes with this particular note ("I distinctly remember the peculiar coffee stain on both pieces of paper--it looked like Karl Malden's nose"), then there's little probative value from the affidavit or testimony.  

The law on allonges is not particularly well-developed. The 1951 version of the UCC, in force in NY and South Carolina (I think), covers them in section 3-202, but the current version does not. The old version of the UCC required that allonges be "firmly attached." That requirement seems to have been fulfilled via pasting or gluing and maybe stapling. Query whether paper clip or rubber band or simply in the same folder will suffice. I'm not sure why any of them would. None of these methods answers the question of when the allonge was created. I can paste or rubberband the day of trial. There's a smidgen of state law on this, but it hasn't been a major issue previously.

Which brings us to BONY v. Faulk. In this case, the foreclosure filing included a 3 page note. The note lacked endorsements connecting the originator to BONY as trustee for the foreclosing securitziation trust. This set up a motion to dismiss on the grounds that BONY didn't have any right to do anything--it had no connection with the note. 

But wait!  Suddenly BONY's attorney tells the court that she is in possession of the fourth page of the note, which includes a blank endorsement. Puhlease...  What a ridiculous deus ex machina ending. Are we do believe that this attorney filed 3 pages of the note, but not the 4th? If so, I sure hope she's not billing for that screw up.

But here's what perplexes me. Suppose that an allonge is produced. How are we going to know when that allonge was created or that it even relates to the note in question? (Just so everyone's clear--if the endorsement were created later, then BONY as trustee for CWABS 2006-13 trust had no standing at the time the action was filed because the trust didn't own the note at that time.) How do we know that this attorney isn't engaged in fraud on the court (and a host of other violations of state and federal law)?  

And this isn't even getting into the question of whether the PSA at issue requires specific endorsements, not endorsements in blank. As it turns out that's a problem in this particular case. Here's the PSA for CWABS 2006-13 trust.  Section 2.01(g)(1) provides that the Depositor deliver to the trustee: 

the original Mortgage Note, endorsed by manual of facsimile signature in blank in the following form: "Pay to the order of _______ without recourse", with all intervening endorsements that show a complete chain of endorsement from the originator to the Person endorsing the Mortgage Note...

As an aside, let me point out that "endorsement...in blank" does not mean endorsed in blank in the UCC sense. In the UCC sense, endorsed in blank simply means the endorser's signature, just as you might put on the back of a check before depositing it. Here, it means endorsed with a blank for the endorsee's name.  Critically, this PSA requires a complete chain of endorsement with all intervening endorsements. A single endorsement in blank ain't gonna do it if this PSA means anything. And there were a lot of MBS investors who assumed that it was going to be followed. 

I think this PSA just puts the attorney in an even worse place. The only way there should be a separate blank endorsement page is if there was non-compliance with the PSA. Are we really to believe that happened? (Well, yes, but the attorney can't really argue that BONY generally doesn't comply with its duties as trustee, now can she?)

We've already seen pretty shocking evidence of documentation fraud in foreclosures.  Remember that the robosigning scandal was the by-product of depositions that aimed to show backdating of assignments to trusts. The shame of the robosigning press coverage was that it focused on some shmucks signing 10,000 assignments in a month--which didn't necessarily produce any harm itself, just carpal tunnel syndrome--and overlooked the really quite serious criminal problem of the backdating of assignments. The depositions showed pretty clearly that there was backdating--the notarizations were by notaries who didn't have their commissions until a couple of years subsequent or were done on Christmas Day, etc. 

Document fraud in the mortgage industry is nothing new. It's appeared in all flavors and sizes for centuries. The laws of negotiability are first and foremost evidentiary laws meant to protect against fraud. Negotiable instruments are reified obligations--the instrument itself is the right to payment (UCC 3-203, cmt. 1).  That means that one can sue on either the instrument or on the underlying contract (but Statute of Frauds might require some writing for enforceability). I hope that courts will recognize that real serious potential for fraud that exists when one combines endorsements in blank with allonges and start demanding (1) that the complete note be filed with the original filing and (2) that anyone using an allonge prove that the allonge goes with the note in question. I think we've passed the point were there can be any assumptions of good faith and fair dealing.

I'd be curious to hear if any foreclosure defense attorneys have been pushing on the evidentiary status of allonges--namely what proof beyond a staple or the like is there that an allonge goes with a particular mortgage and wasn't just photocopied from another one. 

And yes, this sort of evidentiary scrutiny adds huge costs to the system. But it would be pretty easily avoided if PSAs had been followed in the first place--there was a reason that they required complete, unbroken chains of endorsement. 


Adam, being one of those in the trenches who took a shot at you recently, let me thank you for opening this can of worms. Yes, indeed, we are actively litigating these allonge issues. Let me give you some examples of a few of the battles that we have fought.
We have a case with a loan made by First National Bank of Arizona. That bank was merged into First National Bank of Arizona. The allonge is on the letterheaed of FNB Nevada, but has a stamped indorsement to WaMu by a person signing as VP for FNB Arizona. We raised the defense required by UCC §3-308(1) that the indorsement was not authorized (a defense that far too few attorneys know that they need to make to raise this issue in these cases) arguing that the indorsement must have been made after the merger of FNB Arizona into FNB Nevada since it was on FNB Nevada letterhead and there could have been no FNB Arizona vice president after that merger. After 9 months of battling opposing counsel and in court for a demand to see the original note it was finally produced. I was handed a file folder containing a three-page note with the pages unattached but with numerous staple holes in the upper left corners of all three pages. The next item was the purported allonge with not a single staple hole anywhere in it, no signs of taping or gluing. We beat summary judgment on these issues, and just before trial the JPMorgan Chase dismissed the case.
Then, we have the "double floating allonge" issue. This one is indorsed "Pay to the order of *see attachment* " and signed on behalf of the note payee, Accredited Home Lenders. Then it has another piece of paper behind that with the name of a Deutsche Bank trust typed on it in different print. We raised the UCC §3-308(1) defense there arguing that the "indorsement" could not have been signed with the present intent (UCC §1-201(37) to create an indorsement to the Deutshe Bank trust. That fight is ongoing for over two years now.
We know to a certainty that the GMAC modis operandi has been to store its original notes in Minnesota. We know to a certainty that Jeffrey Stephan signs papers that GMAC calls allonges in Fort Washington Pennsylvania. In a recent case, GMAC submitted a Stephan summary judgment affidavit attaching a photo copy of the note with a never before produced allonge signed by Stephan himself. We raised the §3-308 defense and submitted the PSA with our opposing papers, with the PSA showing that Stephan's purported indorsement was not within the chain of transfers prescribed by the PSA. At that point GMAC claimed that Stephan's allonge was a "mistake" and submitted a new photocopy of the note with two new never before seen indorsements stamped on it on the signature page. That case just settled.
One major problem with allonges that you do not raise is the requirement of UCC §3-204 that an indorsement "means a signature . . . made on the instrument" and going on to state that "For the purpose of determining whether a signature is made on the instrument, a paper affixed to the instrument is a part of the instrument." When Stephan signed that piece of paper in his office in Pennsylvania, it was not affixed to the note that was in Minnesota. Thus it was not an allonge. Sending that piece of paper to Minnesota to be "affixed" to the note cannot make it into an allonge. The paper must be affixed to the note at the time that it is signed in order to be an allonge. See Sinclair, The Case of the Air-Conditioned Allonge 9 Ann. Rev.Banking l. 143, 181 (1990).
As you correctly point out with the single example you cite, the allonges that we are seeing virtually never contain the chain of indorsements that follow the PSA prescribed chain. The three examples I cite above are just a few of hundreds of dubious allonges that I have seen. I simply have no doubt that allonges are being routinely and fraudulently created, long after PSA closed, for the purpose of trying to doctor the notes to be usable in foreclosure litigation. It is still a tremendous challenge to convince our judges that our national financial institutions would resort to this kind of fraud and deception but we are making gradual headway.

I'd like to thank you for flipping this rock too, Professor.

Taking allonges, indorsements and PSAs into consideration, I'd like to ask both you, Professor AND Attorney Cox (thank you, btw, for your efforts up in Portland) where you fall on borrowers being 3rd party beneficiaries...

Horace v. LaSalle Bank http://scholar.google.com/scholar_case?case=13956959064454229138&hl=en&as_sdt=2&as_vis=1&oi=scholarr

or U.S. Bank v. Congress http://www.scribd.com/doc/50074488/US-Bank-v-Congress-Order ?

Personally, I don't see how a borrower could NOT be at least peripherally tied to the PSA given the chain of title WITHIN the securitization process. If the A to B to C to D xfer is broken then the borrower note never properly ends up at D. Game over.

Of course, I also think MI got it right in the recent Hendricks v. US Bank http://stopforeclosurefraud.com/2011/06/08/mi-trial-court-finds-mers-transferred-nothing-purported-transfers-endorsements-or-assignments-are-void-ab-initio-hendricks-v-u-s-bank/ where they spanked MERS b/c of the PSA as well...

"Those aren't the fraudulent allonges you're looking for."

"These aren't the fraudulent allonges we're looking for."

"GMAC can go about its business."

"GMAC can go about its business."

Here's an interesting case on allonges from Ohio.


Yes,foreclosure defense attorneys have been pushing on the evidentiary status of allonges. Nick Wooten's Congress case is the most significant matter to date. He introduced expert testimony on the unique NY UCC requirements for an allonge. If you'd like, I can send you Professor Ira Bloom's testimony in Congress.

Nick also cited the following Third Circuit opinion containing an in-depth discussion of allonges and ruling against the noteholder claimant:

“Financial institutions, noted for insisting on their customers' compliance with numerous ritualistic formalities, are not sympathetic petitioners in urging relaxation of an elementary business practice. It is a tenet of commercial law that ‘holdership and the potential for becoming holders in due course should only be accorded to transferees that observe the historic protocol.’" Adams v. Madison Realty, 853 F.2d 163, 169 (3d Cir. 1988) (citation omitted).

Mark - It would be great to get that testimony for my own case prep. Can I email you?

Another great post, Professor Levitin. I follow this blog religiously, but this is my first post.

Although I do not do typical foreclosure defense, I deal with this issue often in bankruptcy with the numerous motions for relief from stay that are filed by mortgage servicers. Until recently, the Judge in Wyoming has required an evidentiary hearing upon a debtor's objection to the motion. The Judge requires that the movant bring the note, and any attached allonge, to the hearing. In numerous cases, the movant files a first motion for stay relief, and the supporting documentation does not contain an allonge. I object based on standing (the note is still payable to original lender but the mortgage was assigned to the servicer). The motion is withdrawn, only to show up again down the road, this time containing an allonge. I have been basing my objection on standing (Rule 17 and the "real party in interest"), but a recent decision by the Judge has put me in a predicament. A motion for relief was filed (by Onewest) and I objected based on standing (for a multitude of reasons, including the mysterious appearance of the allonge). The Judge did not address standing at all, and merely granted the motion. It is set up for an appeal, but I am concerned that at this point any servicer can file a motion for stay relief, with any manipulated documentation attached, and the Judge will grant their motion as a matter of course (if the debtor is behind on payments and the property is absent of equity). I was confident about this case considering the "allonge" issue, the mortgage assignment by Erica Johnson-Seck(infamous robo-signor from Indymac) and Fannie Mae claiming to "own" the loan (amongst other legal arguments). I imagine an appeal will be forthcoming. The Court's finding in this particular case was very unfortunate. I had high hopes that this one would really show the Judge the problem.

One last note. A great tool to utilize to demonstrate that the right party in interest is not before the court is the "loan lookup tool" on both Fannie Mae and Freddie Mac's website. In the majority of cases I see, the mortgage servicer does not indicate the loan is securitized, and that they are merely a servicer. They claim the mortgage has been assigned to them (through an assignment of mortgage), and that they are also the current payee under the note (as the holder of an indorsed-in-blank note). Thus, they claim to own the loan. You can put the debtor's info into the "loan lookup tool", and if it's securitized through Fannie or Freddie, the tool will say "Fannie Mae (or Freddie Mac) owns this loan" (or something similar). The servicer should be required to go through the PSA, etc., and indicate they have the proper authority to be there. It's rather simple, to be the note holder one must be "entitled to the payments" under the note (language in the note). The only entity entitled to the payments is the loan investor. The servicer should be required to show it has the requisite authority to foreclose. I am working on a much bigger case that I imagine will be of quite interest, more to come.


Allonge forgeries have been an enormous problem, but NOT for the reasons that you and most others in the foreclosure defense community surmise.

But a forgery is a forgery. And those engaged in such forgeries need to be investigated, charged and brought to justice. This is NOT a civil matter!

The FACT of the allonge forgery can very often be proven with reference solely to public records, though historically this was somewhat harder to do than proving assignment forgery.

Attorney Cox's examples are excellent! And with a really good defense attorney, good discovery and a supportive judge, one can very often develop strong proof within a case as to the FACT of the forgery.

But one thing that attorneys and defendants continue to overlook throughout is the value and importance of a good expert. And I am NOT talking about people to examine handwriting, paper, or other document forensics. Those NOT actually familiar with the mortgage industry and standard business practices look at an indorsement, and allonge, and/or an assignment and FAIL TO SEE the conspicuous evidence of forgery, because you are generally UNFAMILIAR with what the REAL thing looks like!

The single problem which CLOUDS your understanding is that you are operating on a totally FALSE PARADIGM about the nature and character of the frauds and WHY these frauds have arisen.

You look at the documents routinely filed in cases and, because essentially ALL of the evidence is FABRICATED, you ASSUME that this is what REAL indorsements, REAL allonges and REAL assignments LOOK LIKE. Ooops!

You incorrectly believe that a particular instrument LOOKS regular because it looks like all of the other forgeries.

You are making FALSE COMPARISONS. You need to compare the forgeries with the REAL instruments. And you DO NOT KNOW what these look like!

When you KNOW what the real instruments look like, you can INSTANTLY TELL whether a document is a forgery (at least in the case of the more common and cruder forgeries).

With this realization, you come to discover that essentially ALL of the assignments used in support of foreclosures are forgeries. NOT belated corrective assignments. FORGERIES.

MOST of the allonges being pleaded are also forgeries, but this is not as monolithically true.

Some of the notes being pleaded are forgeries, but this is far less common. And the REASON for the fabrication of a note is NOT what most fear or suspect.

The mortgage foreclosure fraud crisis is NOT a minor "paperwork problem". Rather, it is the single largest commercial criminal conspiracy in global history. Thousands of people have perpetrated millions of crimes.

The correct answer is right in front of your nose and can be demonstrated solely with reference to readily available public information. But you have bought into the securitzation defect hysteria propagated by Yves Smith and a number of other poorly informed self-aggrandizers.

The fraud is mostly NOT in the securitization. The fraud is in the foreclosure.

William A. Roper, Jr.

Great Post, as always Adam.

In my OWN case in Washington State, I have been yammering about the allonge that appeared magically. The timing of the appearance is CLEARLY going to be a problem for the Trustee: Northwest Trustee Services, Inc.

Consider this: Upon my receipt of the Notice of Default (Washington is a non-judicial state) I responded with a dispute of the debt letter. (We rescinded our mortgage more than two years ago, and it was done absolutely perfectly.)

There was NO response from the Trustee AT ALL (I call them "Straw Trustees" on my blog). Instead, SEVEN weeks later, I received a response from Routh Crabtree Olsen (a large foreclosure mill in the western states) "on the trustee's behalf". Keep in mind that this legal firm is owned by THE SAME PRINCIPLES AS THE TRUSTEE!! (The conflict of interest is another topic entirely)

The attorney sent a "debt validation packet" with my loan docs, copy of note, etc... and ONE allonge (that I had too). Weeks later, when my attorney made a visit to their office, SURPRISE, a NEW allonge was now in the validation packet!! One from the previous loan servicer (who was the SERVICER, not the HOLDER of the note) - signed by one of their "VP's". Here's the kicker: They were not in business any longer! HILARIOUS! They think this looks legitimate? Wow, what a world.

Great to see Lender Processing Services losing it all today. WHAT will the fraudsters DO without their manufacturing plant?? I know they are going to shut their doors eventually... Wait until the investors of BofA and the rest see the quagmire that results from THAT! Then they will really start to see red.

Just a simple query - what if the lender (named on note/mortgage) was never a member of MERS - despite MERS on the document if no party (borrower and lender) were ever members of MERS then there were/are no legal basis for MERS to have any connection with the 'transaction' at all - the first thing I did was to confirm in fact that the lender (albeit now a straw, ghost) was never even a member thus MERS never had a legal conduit or authority to do anything, including uploading information or acting on behalf of the lender because there was no 'legal contract' between MERS and the lender in existence - it turns out the MIN Nos. on the docs at closing were instead numbers belonging to pseudo party servicer (PHH), etc. Start insuring that anyone to the original 'contract' was even a MERS' member first and foremost - if not then it can only knock MERS out of the picture from the get go....MERS has NADA to act on; the lender must be a member of MERS in order for MERS to be allowed to do anything on that lender's behalf...

Papergate - Great point.

Here is a different question.

Let's assume the chain of title is:
(broker) to (CHL) to (SPV's to make BK Remote) to (BONY)

If the SPV's were not explicitly MERS members by name, would that matter?

The document "embellishment" goes well beyond cleaning up the foreclosure documents. We see many instances of other documents that have been forged, fabricated, or modified as needed. The scope is much larger than is being reported.

E.g. a client was a victim of a broker bait and switch. After a few days and realization that the broker would not follow up with the promised correction, the client went to a new lender to refinance, having been reviewed for loans that approximated what the broker had promised.

Upon contacting the current lender, client was shocked to learn of a prepayment penalty and requested a copy. The prepay addendum was a clear forgery, even misspelling the wife's name. Even tho' lender's fraud team found the document "suspicious", lender insisted on enforcing the penalty, killing the refi.

After a year of haggling with lender, lender insisted on forensic document examiner paid for by client. Examiner reviewed at lender HQ and concluded obvious forgery.

Incredibly, weeks later, lender produces a different addendum, claiming it's the real one. Lender (and its attys) are completely untroubled by posession (and prior enforcement) of the forgery.

Fortunately, the growing evidence of the massive document "irregularities" is starting to result in growing judicial distrust of lender evidence. Indeed, the judge's opinion in the SoCal Arizmendi bankruptcy cited numerous examples in which the lender (One West) had been sanctioned for dishonesty before the court and found a pattern of such conduct that required coercive sanctions.

Having a non GSE loan which has no assignment to the servicer and has clear irregularities here I sit. After disputing this debt, and being denied HAMP I recieved my NPV inputs letter 260 days after it was due to me. Of course it is all wrong.

I am sitting with this big decision. Wait for them to take action where I can bring Adams most applicable points..............

Responding to the INPUTS with anything other than a debt dispute is incorrect I believe.

"If the homeowner were able to bring a standing challenge, there’d really be no way to avoid addressing the PSA on its own terms because that is what determines whether the securitization trust has an interest in the mortgage in the first place.
More generally, I find the argument that there's no standing to argue over chain of title misplaced. Perhaps the most fundamental defense to a foreclosure is to argue that the party bringing the action isn’t the creditor. That’s a standing question, and there’s simply no way to examine it without getting into the PSA.

Unlike an action on a note, which is an action at law, mortgage foreclosure is an equitable action—it is the cutting off the borrower’s equity of redemption. Most states have abandoned the formal law/equity division, but the principles still stand, even if the court structure does not. While a thief can enforce bearer paper, the idea that a thief could enforce a mortgage is laughable. If you don’t have clean hands, don’t expect relief in equity."

Great article about another area of paperwork fraud. What was really amazing was the number of comments from other lawyers who are seeing the fraudulent allonges and other instruments.
One wonders if this is something being directed by senior management at the banks and other lenders or if it's just something endemic in the system and is practiced at all levels.
On a lighter note, your comment about the lawyer suddenly finding a fourth page of the note reminded me of the movie "Changing Lanes" with Samuel Jackson and Ben Affleck. I would hope this lawyer didn't "forget" the fourth page due to a similar traffic accident.

I am doing a TILA case in the Eastern District of Virginia (Alexandria). The issue is rescission, which normally cannot be granted in the absence of the current noteholder. HSBC as servicer raised an "indispensable party defense" claiming that the owner of the loan was absent and needed to be brought in for rescission relief to be granted.

Anyway, in resolving the noteholder issue, my client examined the original note in the foreclosure mill's attorney's office in February 2011, and it did not have an allonge. Then, suddenly, in June 2011, the original note is brought into court with an allonge.

Additionally, the custodian of the note (as we found out through discovery) was located in NY, so NY's UCC applies -- no allonge permissible if there's room on the note itself (which there is).

The point is, in a foreclosure case it would not be so obvious that the allonge is bogus, but in a federal TILA case their "game" is a lot more transparent and subject to challenge.

Hi. I was wondering if this is a case of a fraudulent allonge. When the servicer filed a relief from stay motion it attached the note and there was no allonge, nor any reference to it on the last page of the note. 1 year later, when the investor filed a foreclosure lawsuit, the attached note did have an allonge and a stamped reference to it on the final page of the note. It was dated 5 years prior. It was signed by the original mortgage lender/broker The allonge was not in favor of the investor though. So, I ask, is this a fraudulent allonge? What good does it do the investor? Thanks.

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