SEC Securities Fraud Complaint

Name: [YOUR FULL LEGAL NAME]

Address: [YOUR ADDRESS]

Phone: [YOUR PHONE]

Email: [YOUR EMAIL]

Whistleblower Award Sought: Yes / No

Primary Subject - Securitization Trust:

Trust Name: [REMIC/TRUST NAME, e.g., "CWABS 2006-BC5"]

Trustee: [TRUSTEE NAME, e.g., "Bank of New York Mellon"]

Depositor: [DEPOSITOR NAME]

Servicer: [SERVICER NAME]

Trust Closing Date: [CLOSING DATE from PSA]

Securities Involved:

CUSIP Numbers (if known): [CUSIP NUMBERS]

Approximate Value of Securities: [ESTIMATED VALUE]

I am reporting securities fraud and REMIC violations involving mortgage-backed securities issued by [TRUST NAME]. The violations include:

1. Failure to Transfer Mortgages Before Trust Closing Date
   The mortgage on my property (Loan No. [LOAN NUMBER]) was purportedly transferred to the trust via an assignment dated [ASSIGNMENT DATE], which is after the trust closing date of [CLOSING DATE].
   
   Under the Pooling and Servicing Agreement and IRC § 860D, the trust cannot accept mortgages after the closing date. This suggests either:
   (a) The mortgage was never properly transferred to the trust, or
   (b) The assignment was backdated to conceal the failure to transfer
2. Securities Fraud - False Representations to Investors
   Investors in securities issued by this trust were told their securities were backed by properly transferred mortgage loans. The failure to properly transfer mortgages means:
   - Securities are not backed by the represented collateral
   - The trust's claimed ownership of mortgages is fraudulent
   - Investors have been defrauded
3. REMIC Tax Violations
   The acceptance of mortgages after the closing date violates IRC § 860D requirements for REMIC status. This may result in:
   - Loss of tax-exempt status for the trust
   - Significant tax liability for the trust and investors
   - Additional securities fraud for failing to disclose tax risks
4. Document Fabrication
   To conceal the failure to properly transfer mortgages, the subjects have fabricated documents including:
   [DESCRIBE - backdated assignments, robo-signed documents, forged endorsements]

A. My Mortgage and the Trust

• Property Address: [PROPERTY ADDRESS]
• Original Lender: [ORIGINAL LENDER]
• Original Loan Date: [LOAN DATE]
• Original Loan Amount: $[AMOUNT]
• Trust Claiming Ownership: [TRUST NAME]
• Trust Closing Date (per PSA): [CLOSING DATE]

B. Chain of Title Irregularities

Analysis of the recorded chain of title reveals:

• Assignment from [ASSIGNOR] to [ASSIGNEE] dated [DATE] - [DESCRIBE IRREGULARITY]
• Assignment to trust dated [DATE] - after trust closing date of [CLOSING DATE]
• [ADDITIONAL CHAIN OF TITLE ISSUES]

C. Pooling and Servicing Agreement Violations

The PSA for [TRUST NAME] requires:

• All mortgages must be transferred before the closing date
• Original notes must be delivered to the trustee with proper endorsements
• Assignments must be in recordable form

Evidence suggests these requirements were not met for my mortgage and potentially thousands of others in the pool.

D. Prospectus Misrepresentations

The prospectus and offering documents for securities issued by this trust represented:

• That mortgages would be properly transferred to the trust
• That the trust would have valid ownership of the collateral
• That REMIC requirements would be satisfied

These representations appear to have been false for my mortgage and potentially many others.

1. Chain of Title Documents: Recorded assignments showing transfer dates after trust closing
2. Pooling and Servicing Agreement: [SOURCE - SEC EDGAR filing, etc.]
3. Prospectus/Offering Documents: [SOURCE]
4. Robo-Signing Evidence: Documents bearing signatures of known robo-signers
5. QWR Responses: Servicer's failure to document proper chain of title
6. Expert Analysis: [IF AVAILABLE - forensic document analysis, chain of title report]

This complaint involves:

• Securities Value: The trust [TRUST NAME] issued securities with initial principal balance of approximately $[AMOUNT - available in SEC filings]
• Investor Impact: Investors holding these securities may have been defrauded regarding the collateral backing their investments
• Tax Implications: REMIC violations may result in substantial tax liability
• Pattern of Conduct: Similar violations likely affect thousands of mortgages across multiple securitization trusts

• Securities Act of 1933, § 17(a): Fraud in the offer or sale of securities
• Securities Exchange Act of 1934, § 10(b) and Rule 10b-5: Fraud in connection with securities transactions
• IRC § 860D: REMIC qualification requirements
• Sarbanes-Oxley Act: If public companies were involved in the fraud

1. Investigate the securitization practices of [TRUST NAME] and related trusts
2. Examine whether mortgages were properly transferred before trust closing dates
3. Investigate document fabrication and backdating
4. Bring enforcement action for securities fraud
5. Require disgorgement of profits from fraudulent securities sales
6. Refer tax violations to the IRS for REMIC compliance review
7. Coordinate with DOJ for potential criminal prosecution

I declare under penalty of perjury under the laws of the United States that the information provided herein is true and correct to the best of my knowledge and belief. I am providing this information voluntarily and understand that the SEC may share this information with other agencies.

I [am / am not] seeking an award under the SEC Whistleblower Program. I understand that to be eligible for an award, I must provide original information that leads to successful enforcement action with sanctions exceeding $1 million.

[YOUR SIGNATURE]

_________________________________
[YOUR PRINTED NAME]
Date: [DATE]

Exhibit A: Chain of Title Documents and Analysis
Exhibit B: Pooling and Servicing Agreement (relevant sections)
Exhibit C: Assignment Documents Showing Post-Closing Dates
Exhibit D: Evidence of Document Irregularities
Exhibit E: QWR Correspondence
Exhibit F: [ADDITIONAL EXHIBITS]