PLAINTIFFS’ ORIGINAL COMPLAINT
I. PRELIMINARY STATEMENT
1. Plaintiffs are and represent people who purchased their first homes between 1994
and 2006, usually with loan assistance from the Federal Housing Administration and the U.S.
Department of Veterans Affairs. Their loans were all serviced by Defendant BAC, which is a
wholly owned subsidiary of Defendant Bank of America, N.A.
This lawsuit complains not of
poor customer service by BAC, but of a systematic home loan servicing scheme that includes
hours of telephone runaround, misleading and inconsistent information, lost correspondence,
verbal abuse, and extensive delay, all of which have documented costs not only in terms of
money, but in health. The facts in this case reveal the harsh reality that underlies the loan
Case 6:10-cv-00051 Document 1 Filed in TXSD on 06/29/10 Page 1 of 51
servicer’s press statements about loan modifications and forbearance agreements following
collapse of the U.S. housing market.