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Veterans Foreclosure Crisis

Closing the gap that puts veterans out of their homes

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WHAT HAPPENED

Every claim on this site traces to a document you can open.

This page holds the chronology. The claims register and the source register are on the registers page under Sources & Data. 8 further documents sit under it, listed below, each one a full record in its own right.

44 dated events. 76 registered claims. 292 sources, 125 of them archived against link rot. 30 sources still carry a provisional title and say so in their own row.

INDEX

The 8 record documents

Each one is a reference document, not an article. Take the one that matches what you came for. The section count says how much is in it.

The 8 documents under The Record, what each holds, and how many sections it has.
DocumentWhat is in itSize
What is happeningThe live implementation record, servicer-specific access, the three cohorts, and the fiscal case.12 sections
Policy and fiscal analysisCongress wrote the authority; the VA wrote the exclusions. The legal and fiscal case, laid out.37 sections
Accountability trackerWho is engaged and where it stands, plus three officials on the record in five days.25 sections
Oversight capacity729 open watchdog recommendations at VA, and the auditors who wrote them being cut back.16 sections
Bills in Congress right nowVA home-loan bills and related legislation, what each would do, and its recorded procedural status.11 sections
They were warnedSix documented warnings, who received them, and what happened next.11 sections
Housing and healthWhat the research establishes about housing instability, veteran suicide risk, caregivers and children, and the gap nobody has measured.11 sections
Impact and the recordWhat each policy period did to veteran families, with the document that shows it beside the sentence.6 sections

THE COVERAGE GAP

When a partial-claim-style program was available to a veteran family, and when it was not

Covered

31 months

Gap

19 months

Covered

11 months

Gap

13 months

Partial

5 months

H.R. 1815 signed
Jul 30, 2025

Mar 27, 2020Nov 28, 2026

  1. Period 1 · Covered

    COVID-19 partial claim available

    Mar 27, 2020 to Oct 28, 2022 · 31 months

    T001 to T002 · S049

  2. Period 2 · Gap

    No partial claim

    Oct 28, 2022 to May 31, 2024 · 19 months

    T002 to T005 · 38 CFR 36.4809(c)

  3. Period 3 · Covered

    VASP available

    May 31, 2024 to May 1, 2025 · 11 months

    T005 to T009 · VBA Circular 26-25-02

  4. Period 4 · Gap

    No program

    May 1, 2025 to Jun 15, 2026 · 13 months

    T009 to T020 · S010

  5. Period 5 · Partial

    Partial claim live, not required at every servicer until November 28

    Jun 15, 2026 to Nov 28, 2026 · 5 months

    T020 to T023 · KnowVA 554400000324998

80 months in this window. 32 of them with no partial-claim-style program in the waterfall at all.

Source: the chronology register, data/timeline.csv, rows T001, T002, T005, T009, T010, T020 and T023. Every period boundary and month count is computed from those registered dates. As of Aug 11, 2026.

Limitation. Month counts are whole completed months, so the five periods sum to 79 of the 80 months the window measures; the exact day counts are in the table. The register also holds that the absence of a partial claim after October 2022 is a structural finding rather than a single documented event: it rests on what 38 CFR Part 36 did not contain, and no one document states it.

The same five periods as a table
Computed from data/timeline.csv. Months are whole completed months and therefore truncate, which is why the five period figures sum to 79 while the window itself measures 80 months and 2,437 days.
PeriodStateFromToDaysMonthsRegister rows
COVID-19 partial claim availableCoveredMar 27, 2020Oct 28, 202294531T001 to T002, S049
No partial claimGapOct 28, 2022May 31, 202458119T002 to T005, 38 CFR 36.4809(c)
VASP availableCoveredMay 31, 2024May 1, 202533511T005 to T009, VBA Circular 26-25-02
No programGapMay 1, 2025Jun 15, 202641013T009 to T020, S010
Partial claim live, not required at every servicer until November 28PartialJun 15, 2026Nov 28, 20261665T020 to T023, KnowVA 554400000324998
H.R. 1815 signed, marker inside period 4MarkerJul 30, 2025Jul 30, 2025Point eventPoint eventT010, S010
Whole window32 months in a gapMar 27, 2020Nov 28, 20262,43780T001 to T023

CHRONOLOGY

What happened, in order, with the document that proves each step

Rows with no source say so rather than going quiet.

March 2020

CARES Act forbearance begins. Federal agencies issue written guidance to FHA, VA and USDA servicers stating paused payments are repaid over time and a lump sum is not required.

Federal agencies (interagency) to Servicers · CARES forbearance fact sheet

S049 CARES Act Forbearance Fact Sheet for FHA VA and USDA servicers · archived

Apr 8, 2020

VA's Loan Guaranty Service tells servicers, in its own circular, that a CARES Act forbearance must be granted on the borrower's word alone, that the borrower sets its length, and that no lump sum may be demanded on exit.

VA Loan Guaranty Service (Jeffrey F. London, Director) to Servicers · Circular 26-20-12

S259 VA Circular 26-20-12, Extended Relief Under the CARES Act for those Affected by COVID-19

Apr 29, 2020

VA tells servicers how to flag a COVID default in its own servicing system: by replacing an existing reason code, 'Energy/Environmental Cost', with 'National Emergency Declaration'. The flag is generic and repurposed; it does not name COVID.

VA Loan Guaranty Service to Servicers · Circular 26-20-17

S261 VA Circular 26-20-17, New Reason for Default for those Affected by COVID-19

Aug 24, 2020

VA extends the COVID foreclosure and eviction moratoria through December 31, 2020, in two circulars that say their contents 'are part of the guaranty contract' and 'are meant to bind the public'. Two of the 63 VA circulars this project holds say that; two others, on deferment and on refinance access after forbearance, say the opposite.

VA Loan Guaranty Service (Jeffrey F. London) to Servicers · Circulars 26-20-29 and 26-20-30

S263 VA Circular 26-20-29, Extended Eviction Moratorium for Borrowers Affected by COVID-19 · S264 VA Circular 26-20-30, Extended Foreclosure Moratorium for Borrowers Affected by COVID-19 · S262 VA Circular 26-20-33, Deferment as a COVID-19 Loss Mitigation Option for CARES Act Forbearance Cases · S265 VA Circular 26-20-25, Impact of CARES Act Forbearance on Purchase and Refinance Transactions

Sept 9, 2020

VA extends the COVID foreclosure moratorium through December 31, 2020 by a one-page change order to Circular 26-20-12. VA never reissued the base circular; its website still served the April 2020 text on September 12, 2026.

VA Loan Guaranty Service to Servicers · Circular 26-20-12 Change 1

S260 VA Circular 26-20-12 Change 1

Sept 14, 2020

VA authorizes deferment as a way out of a CARES Act forbearance: the missed payments move to the end of the loan with no added cost, fees or interest. The same circular says deferment carries no servicer incentive payment, and is not allowed for a veteran who needs a lower payment.

VA Loan Guaranty Service (Jeffrey F. London) to Servicers · Circular 26-20-33

S262 VA Circular 26-20-33, Deferment as a COVID-19 Loss Mitigation Option for CARES Act Forbearance Cases

Oct 28, 2022

The COVID-19 Veterans Assistance Partial Claim Payment program expires by regulation. VA will not accept a request for a partial claim payment after October 28, 2022. No replacement tool exists for VA borrowers exiting forbearance.

S104 38 CFR 36.4809 -- Expiration of the COVID-19 Veterans Assistance Partial Claim Payment program. · archived · S145 Loan Guaranty: COVID-19 Veterans Assistance Partial Claim Payment Program (final rule, 86 FR 28692)

2022 to 2024

The years with no partial claim. Families exit forbearance on terms the 2020 guidance ruled out.

S021 eCFR Title 38 Part 36 (VA loan regulations)

Nov 30, 2023

VBA Circular 26-23-25. VA strongly encourages a foreclosure moratorium on all VA-guaranteed loans through May 31, 2024, urging servicers to cease initiating, continuing or completing foreclosures. Stated reason includes the pending availability of VASP, which the circular places in March 2024.

VA to Servicers · VBA Circular 26-23-25

S091 VA Circular 26-23-25, Loan Repayment Relief for Borrowers · archived

Feb 15, 2024

House Veterans' Affairs Committee hearing. The partial claim gap and foreclosure exposure are raised directly, three months before VASP launches.

Witnesses at hearing to House VA Committee · HVAC printed hearing record

S056 Hearing transcript, HVAC Subcommittee on Economic Opportunity, February 15 2024 (Hearing 118-53) · archived

Apr 10, 2024

VA announces VASP, stating the program will help more than 40,000 veterans stay in their homes, and says it has strongly encouraged a foreclosure moratorium through May 31, 2024.

VA to The public and servicers · VA news release

S146 VA announces new program to help more than 40,000 Veterans stay in their homes

May 29, 2024

VBA Circular 26-24-12, Loan Repayment Relief for Borrowers. VA announces a targeted foreclosure moratorium on VA-guaranteed loans running through December 31, 2024, stating its purpose is to give servicers time to implement VASP. Servicers may implement beginning May 31, 2024. VA expects full implementation not later than October 1, 2024. Circular valid until January 1, 2025.

VA to Servicers · VBA Circular 26-24-12

S092 VA Circular 26-24-12, Loan Repayment Relief for Borrowers · archived

May 29, 2024

VA press release announcing the extension. Describes the moratorium as originally slated to expire May 31 and states that VASP officially launches May 31 and mortgage servicers must have it fully implemented by October 1, 2024. Under Secretary for Benefits Josh Jacobs is quoted calling on servicers to follow the targeted moratorium.

VA (Under Sec. Josh Jacobs) to Servicers and the public · VA press release

S147 VA calls for extension of Veteran foreclosure moratorium through Dec. 31, 2024

May 31, 2024

VASP is implemented as the final option in the VA Home Retention Waterfall.

S011 VASP program record · archived

Oct 1, 2024

VA's own full-implementation deadline for VASP. From this date to the May 1, 2025 rescission is roughly seven months of broadly usable program, not the twelve months the period is commonly described as.

S092 VA Circular 26-24-12, Loan Repayment Relief for Borrowers · archived

Dec 12, 2024

Mortgage Bankers Association publishes a white paper on the coming gap in VA loss-mitigation options.

Mortgage Bankers Association to VA and the public · Published white paper

PENDING CITATION

Mar 11, 2025

MBA testifies to the House VA Subcommittee on Economic Opportunity. Asked what happens without the rescue program, Elizabeth Balce answers: the short answer is foreclosure. Period.

Mortgage Bankers Association (Elizabeth Balce) to House VA Subcommittee on Economic Opportunity · Subcommittee hearing testimony

S009 'Foreclosure. Period.' warning (Balce) · archived

Apr 9, 2025

Sens. Richard Blumenthal and Elizabeth Warren and Rep. Mark Takano, in a letter signed by 22 Democrats and Independents, ask Sec. Collins to reverse the end of VASP and avoid foreclosing on veterans who wish to keep paying.

Sen. Richard Blumenthal, Sen. Elizabeth Warren and Rep. Mark Takano, 22 signers to Sec. Doug Collins · Letter

S060 Blumenthal, Warren & Takano to Collins: Stop Pushing Thousands of Veterans into Foreclosure

Apr 23, 2025

VBA Circular 26-25-2 issued, announcing the VASP program wind down.

VA to Servicers · VBA Circular 26-25-2

S011 VASP program record · archived

May 1, 2025

VA rescinds the VA Home Retention Waterfall. VASP ends. 10,000 or more veteran families have already lost homes.

S011 VASP program record · archived

Jul 30, 2025

H.R. 1815 signed into law. Both chambers passed it by voice vote. Creates the Partial Claim Program at 38 U.S.C. 3737. Section 3737(h) permits the Secretary to act by administrative guidance before regulations.

Congress to VA · Public Law 119-31

S010 H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 · archived

Sep 2, 2025

Reps. Mark Takano, Chris Pappas and Nikki Budzinski ask Sec. Collins in writing to explain reports that about 35,000 veterans received erroneous foreclosure letters, and to contact each borrower.

Reps. Mark Takano, Chris Pappas and Nikki Budzinski to Sec. Doug Collins · Letter

S290 Letter from Reps. Mark Takano, Chris Pappas and Nikki Budzinski to Secretary Collins on erroneous foreclosure letters, September 2 2025

Oct 28, 2025

Deadline for VA's report to the House and Senate Veterans' Affairs Committees on its strategy to make sure a veteran buying a home with a VA-guaranteed loan is not at a disadvantage in getting a real estate agent or broker. Section 4 of H.R. 1815, 90 days after enactment.

Congress, in Section 4 of H.R. 1815, the VA Home Loan Program Reform Act to Department of Veterans Affairs · Statute

S010 H.R. 1815, VA Home Loan Program Reform Act - Pub. L. 119-31 · archived

Nov 12, 2025

Pub. L. 119-37, div. G, title III. Sec 7307(a) narrows the 38 U.S.C. 3720(h) foreclosure protection; sec 7307(b) to (e) amend 38 U.S.C. 3737, including the 3737(h) guidance-in-advance-of-regulations authority.

Congress · Public Law 119-37

S019 Pub. L. 119-37 §7307(e); 38 U.S.C. §3737(h) as amended · archived

Feb 11, 2026

House Veterans' Affairs Committee oversight hearing. Asked by Rep. Chris Pappas when the partial claim program would be operational, Sec. Collins answers: "It should be done shortly." The first of three VA answers over 79 days that grew less specific, not more (Mar 26, Apr 30).

Sec. Doug Collins to Rep. Chris Pappas (HVAC Economic Opportunity Subcommittee Ranking Member) · HVAC Full Committee Oversight Hearing

S171 HVAC Full Committee Oversight Hearing, February 11, 2026

Mar 26, 2026

NCLC testifies that the draft policy would push roughly 30,000 veterans into average payment increases of about 150 dollars per month.

National Consumer Law Center (Alys Cohen) to House VA Committee · HVAC hearing

S003 NCLC analysis to HVAC EO Subcommittee (Cohen) · archived

Mar 26, 2026

Chairman Van Orden asks VA for its word that it will not foreclose on any veteran, if within its power, until the partial claim is done. The transcript records no answer.

Rep. Derrick Van Orden, Chairman, HVAC Subcommittee on Economic Opportunity to VA Loan Guaranty Service (Patrick Zondervan) · HVAC Economic Opportunity Subcommittee hearing

S255 Kitchen Table Issues: Lowering Costs for Veteran Families Through the VA Home Loan Program, printed hearing, Serial No. 119-53, HVAC Subcommittee on Economic Opportunity, March 26 2026

Apr 2, 2026

NPR reports that the VA's decision to end its rescue program is driving veteran foreclosures.

NPR (Chris Arnold and Quil Lawrence) to The public · National reporting

S002 NPR VA foreclosure investigation (Arnold/Lawrence) · archived

Apr 2, 2026

VA answers a senator, a national broadcaster and a congresswoman in writing about foreclosed veterans, spring 2026. Each answer recites the process; none offers a way back into the home.

VA Loan Guaranty Service to Sen. Patty Murray (for a Washington family, Leann Ledford's own); NPR; Rep. Harriet Hageman (for a Wyoming family) · Constituent-inquiry replies and a written statement to NPR

S258 VA Loan Guaranty Service response to Sen. Patty Murray's inquiry for a Washington veteran family (the household of Leann Ledford, who compiles this record), forwarded by the senator April 2 2026 (Intranet Quorum IMA00592850) · S253 Congressional Record, Vol. 172, No. 86, May 20 2026, House pages H3632 to H3642: debate on H. Res. 1300, the rule for H.R. 1041, H.R. 6047 and H.R. 1329 · S257 VA Loan Guaranty Service letter to Rep. Harriet M. Hageman, May 7 2026, answering a constituent inquiry about a foreclosed VA-guaranteed loan in Wyoming

Apr 23, 2026

House Report 119-622 on the FY2027 MilCon-VA appropriations bill directs VA to report within 90 days of enactment on five items, including the number of veteran borrowers delinquent or at risk of foreclosure and the Partial Claim Program timeline.

House Committee on Appropriations to Department of Veterans Affairs · Committee report

S195 House Report 119-622 accompanying H.R. 8469, MilCon-VA Appropriations Act 2027

Apr 30, 2026

Senate Appropriations MilCon-VA subcommittee hearing. Asked by Sen. Jon Ossoff to commit to working with the subcommittee on foreclosure prevention and veteran homelessness prevention, Sec. Collins answers: "Yeah, we are and trying to find the right way to do that."

Sec. Doug Collins to Sen. Jon Ossoff · Senate Appropriations MilCon-VA subcommittee hearing

S159 WATCH: Sen. Ossoff Secures Commitment from VA Secretary Collins to Work on Preventing Veteran Foreclosure · S161 Ossoff Presses Doug Collins On Reports Of 'Retaliation And Intimidation' At VA Facility (video)

May 7, 2026

VA answers a congressional inquiry about a Wyoming veteran foreclosed on in September 2025: "restoration of the prior loan terms is no longer possible." The same official had told the House on March 26 the partial claim was coming in the upcoming months.

Patrick J. Zondervan, Executive Director, VA Loan Guaranty Service to Rep. Harriet Hageman, on behalf of a constituent family · VA constituent-inquiry letter

S257 VA Loan Guaranty Service letter to Rep. Harriet M. Hageman, May 7 2026, answering a constituent inquiry about a foreclosed VA-guaranteed loan in Wyoming · S245 Hearing transcript, HVAC Subcommittee on Economic Opportunity, March 26 2026, "Kitchen Table Issues: Lowering Costs for Veteran Families Through the VA Home Loan Program"

May 19, 2026

Asked five times how many veterans are likely to be foreclosed on, HVAC Chairman Bost answers on the Rules Committee record: 90,000, which with the 10,000 already foreclosed would be 100,000 veterans.

Rep. Mike Bost, Chairman, House Committee on Veterans' Affairs to Rep. Teresa Leger Fernandez, House Committee on Rules · House Committee on Rules, hearing on H.R. 1041, H.R. 6047 and H.R. 1329

S140 Rules Committee Hearing H.R.1041, H.R.6047, H.R.1329 · archived · S256 Congressional Record, Vol. 172, No. 85, May 19 2026, Daily Digest pages D530 to D531: Committee on Rules, hearing on H.R. 1041, H.R. 6047 and H.R. 1329

May 20, 2026

Senate Veterans' Affairs Committee. Sec. Collins commits under oath to a June 15, 2026 partial-claim standup date.

Sec. Doug Collins to SVAC · SVAC hearing

S096 Veterans affairs secretary collins testifies on 2026 budget request / 679573 · archived

May 20, 2026

Senate Veterans' Affairs Committee. Chairman Moran asks the VA Chief Financial Officer to explain a proposed restructuring of how VA reports healthcare spending. The CFO answers that the account structure co-mingles costs: "all I can tell you is that it's going to cost more and that we can't manage to it because we don't know where we're managing to." The testimony concerns VA's health care account structure, not the home loan program.

Asst. Sec. Richard F. Topping, VA Chief Financial Officer to Senate Veterans' Affairs Committee (Chairman Moran) · SVAC hearing, May 20 2026

S096 Veterans affairs secretary collins testifies on 2026 budget request / 679573 · archived · S001 Sen. Blumenthal remarks, SVAC hearing (15,000+ figure) · archived

May 20, 2026

On the House floor, Rep. Teresa Leger Fernandez puts the numbers into the Congressional Record: more than 10,000 veterans have lost their homes, and 90,000 more are behind on their mortgages or in the foreclosure process.

Rep. Teresa Leger Fernandez to House of Representatives · House floor, debate on H. Res. 1300

S253 Congressional Record, Vol. 172, No. 86, May 20 2026, House pages H3632 to H3642: debate on H. Res. 1300, the rule for H.R. 1041, H.R. 6047 and H.R. 1329

May 26, 2026

Twenty-eight members of Congress, led by Rep. Chris Pappas, demand a targeted foreclosure moratorium and the VA's legal basis if it refuses. Written response required by June 2.

28 members of Congress to VA · Letter

S015 Rep. Pappas + 27 colleagues (28 signers), foreclosure-moratorium letter · archived

Jun 1, 2026

VA issues Transmittal Sheet Change 14 and creates M26-4 Chapter 22, the Partial Claim chapter, effective June 1 2026. Ten qualifying criteria in section 22.02, seven of which do not appear in 38 U.S.C. 3737.

VA Loan Guaranty Service (Patrick J. Zondervan) to Regional Loan Center personnel and Loan Administration participants · Transmittal Sheet Change 14

S013 M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) · archived

Jun 2, 2026

The deadline set by the 28-member congressional demand letter for VA to establish a foreclosure moratorium passes. VA does not respond by the deadline.

Congress to Department of Veterans Affairs · Congressional demand letter

S015 Rep. Pappas + 27 colleagues (28 signers), foreclosure-moratorium letter · archived

Jun 15, 2026

VA Partial Claim Program is available and live, per Transmittal Change 14.

VA to Servicers · VA announcement

S013 M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) · archived

~Jun 15, 2026

NCLC launch-day release renews the demand that VA direct servicers to hold off foreclosing until the program is actually operational.

National Consumer Law Center to VA · Public release

S120 VA Must Pause Foreclosures Until New Mortgage Assistance Program Is Accessible · archived

Jun 19, 2026

Military.com reports the launched program carries equity-stripping and re-foreclosure risk, and restates the 25 percent reinstatement cap.

Military.com (Derricke Dennis) to The public · News report

S116 New VA Mortgage Assistance Program Warning for Veterans Facing Foreclosure · archived

Nov 28, 2026

Full implementation deadline. Transmittal Change 14 states full implementation is expected no later than 180 days from publication of the final policy. 180 days from June 1 2026.

VA to Servicers · VA handbook and email

S013 M26-4 Chapter 22 (VA loss-mitigation / partial-claim policy) · archived

THE OVERSIGHT RECORD

What VA’s own Inspector General reported, years before this crisis

Three public audits, 2019 to 2023. None of them is ours.

The strongest evidence that VA knew is not anything a family wrote. It is what VA’s own watchdog published, on VA’s own website, before most of these foreclosures happened.

2019. The oversight of servicers was not there. Report 18-03979-204, September 30 2019, examined how VA oversees what servicers do when a loan goes into default.

“The OIG found the Loan Guaranty Service did not always provide sufficient oversight to ensure borrowers in default received the needed assistance.”

VA Office of Inspector General, report 18-03979-204

From a review of 200 loans, the audit team estimated that 14 percent of loans had at least one oversight deficiency. All four recommendations are recorded as closed and implemented, the last of them on June 23 2020.

DOCUMENTED FACT C067 S176

2022. The Inspector General told VBA leadership this was a pattern, and VBA disagreed in writing. Management Advisory Memorandum 22-01290-237, December 8 2022, drew on at least four reports issued since 2018.

“VBA’s well-intentioned focus on solving organizational challenges has, however, resulted in negative consequences for some veterans and their families.”

VA Office of Inspector General, memorandum 22-01290-237, page 2

VBA’s response is printed in the same document, five pages later:

“VBA strongly oppose[s] the implication that VBA did not always fully consider the effect organizational decisions would have on Veterans, beneficiaries, and their families.”

Veterans Benefits Administration, in the same memorandum, page 7

DOCUMENTED FACT C068 S177

2023. Thousands of borrowers were overcharged, and VA could not tell. Report 21-01295-149, August 23 2023, found that on the three requirements federal law turns on, “LGY was unable to sufficiently ensure those three requirements were met,” and estimated that at least 3,200 borrowers were overcharged $1.6 million in one fiscal year. That audit is set out in full, with the law it measures against, on the refinance check.

DOCUMENTED FACT C065 C066 S178

What these do not show. The 2019 audit projected from a 200-loan sample and covered default resolution, not refinancing. Closing a recommendation records that VA satisfied the OIG it had acted; it does not measure what happened to families afterwards. The 2022 memorandum is cross-cutting across VBA, is not a Loan Guaranty finding, and makes no new recommendations. The 2023 figures are statistical estimates projected from audit samples, not counts of identified people. All three were read against the published documents on August 21, 2026.

THE ENFORCEMENT RECORD

Where regulators and courts have already acted on this conduct

Two state regulators, one state attorney general, and one federal appeals court.

A common answer to families is that nothing can be done and nobody has ever won one of these. That is checkable, and it is wrong. The actions below are public, dated, and none of them was brought by anyone in this record.

The companies named below are named because a published enforcement action or a court opinion names them. The subject here is the conduct and whether anyone enforces against it. It is not any one company, and no argument on this site rests on one.

A state attorney general has enforced on this exact theory. On December 17 2025 the Massachusetts Attorney General announced a $4.65 million settlement with Newrez LLC, as successor by merger to Specialized Loan Servicing LLC. The headline of the announcement is “AG Campbell Reaches $4.65 Million Settlement with Mortgage Loan Servicer for Unlawful Foreclosures and Deceptive Business Practices,” and its subtitle is:

“Violations Include Failure to Correctly Implement Covid-Era Protections.”

Office of the Massachusetts Attorney General, December 17 2025

DOCUMENTED FACT C069 S179

A federal court has approved a $185 million settlement over pandemic mortgage servicing. The case is In re Wells Fargo COVID Forbearance Settlement Litigation, Case No. 2:24-cv-01026-MHW-EPD, in the United States District Court for the Southern District of Ohio. Customers alleged that Wells Fargo put their mortgages into COVID forbearance without asking them first. The court granted final approval on December 19 2024. The settlement covers about 300,000 people. It took effect on February 15 2025, and payments began that March.

“A $185 million settlement has been reached in the class action lawsuit In re Wells Fargo COVID Forbearance Settlement Litigation in the United States District Court for the Southern District of Ohio.”

Court-approved settlement administrator, read September 5 2026

Wells Fargo denies any wrongdoing. The settlement ends the case without a finding of liability, and that is how it is recorded here.

That conduct is not the conduct in this record. A forbearance nobody asked for is a different failure from a partial claim nobody could get. What it shows is the scale a court has already put on this class of servicing failure, during the same years, on the same programs.

DOCUMENTED FACT C076 S249

A federal appeals court has settled who owes the escrow duty. In a published opinion the Fourth Circuit held that the duty to make an escrow payment follows the company servicing the loan when the payment comes due. It does not stay with whoever collected the money earlier.

“the person responsible for servicing the mortgage at the time a payment is due must make that payment”

U.S. Court of Appeals for the Fourth Circuit, October 2 2020

The opinion also reads the Regulation X standard at 12 C.F.R. 1024.17(k)(1) so that a payment made in a “timely manner” means on or before the deadline to avoid a penalty. That matters to any family whose property tax exemption was granted and whose escrow kept drawing at the non-exempt rate anyway: the question of which company was responsible has an answer, and the answer is the one servicing the loan that month.

DOCUMENTED FACT C070 S180

Washington’s own regulator has done this before, which makes today a choice rather than a limit. On December 7 2020 the Washington State Department of Financial Institutions announced the finalised multistate resolution with Nationstar Mortgage LLC, doing business as Mr. Cooper: consumer redress approaching $90 million to more than 115,000 consumers in 53 states, plus penalties in excess of $6.5 million. Washington’s own share was $2,117,231 for 4,766 consumers, plus $750,000 in penalties. The conduct named in that release includes missed tax payments from borrower escrow accounts, failure to terminate private mortgage insurance when conditions were met, mishandling of loan modifications and servicing transfers, and wrongful foreclosures. DFI led the investigation alongside 52 state regulators, 51 state attorneys general and the Consumer Financial Protection Bureau.

On April 6 2026 the same department issued a statement of charges against Newrez LLC seeking $4,175,000, alleging among other things failing to mediate in good faith during foreclosure, improperly maintained and serviced escrow accounts involving force-placed insurance, inaccurate credit reporting, and responding to consumer concerns in an untimely manner. It arises from more than 125 consumer complaints over conduct from 2021 to 2026. A statement of charges is an allegation, not a finding.

DOCUMENTED FACT C071 S181 S182

What these do not show. None of the four is a VA loan case. The Massachusetts settlement is under that state’s consumer protection law, binds no other state or company, and a settlement is not an admission. The Fourth Circuit opinion is binding in Maryland, North Carolina, South Carolina, Virginia and West Virginia, and persuasive elsewhere, including Washington. The 2020 multistate resolution and the 2026 Washington charges are licensing and consumer protection enforcement over mortgage servicing generally, and the 2026 charges remain allegations. All four were read against the published documents on August 21, 2026.

If you are trying to work out whether any of this touches your own file, start at Build your case, and file where it counts: the CFPB, the VA Inspector General, and your own state attorney general.

CLAIMS REGISTER AND SOURCE REGISTER

Moved to one page on 2026-09-09

Every claim on this site, what it rests on, and every source with its archived copy now live together on the registers page, so a reader checking a number goes to one place.