Editor:

The ink is barely dried on the Consent Judgment, and already it appears Bank of America has engaged in unfair, deceptive and fraudulent actions against its customers.

After 49 state attorneys general and the federal government sued the five largest loan servicers (Ally/GMAC, Bank of America, Citi, JPMorgan Chase and Wells Fargo), a Joint State-Federal Mortgage Servicing Settlement was reached in the largest consumer financial protection settlement in U.S. history, providing $25 billion in monetary sanctions and relief to homeowners.

Bank of America has the largest financial obligation under the settlement at $11 billion. During negotiations, however, Bank of America insured that it minimized its responsibility under the agreement by apparently moving (without consent or knowledge) the loan mortgage of qualifying clients to Green Tree Finance, a carefully concealed subsidiary.

As a result, Bank of America reduced the number of customers eligible for mortgage relief and will not provide refinancing services to former clients under a key provision of the settlement: Refinancing of Underwater Homes.

To assist homeowners who are not delinquent on their payments but cannot refinance to lower rates because of negative equity, the banks must offer refinance programs totaling at least $3 billion. The banks will be required to notify eligible homeowners of the availability of these programs. To be eligible, a borrower must be current on mortgage payments, have a loan-to-value ratio in excess of 100 percent, and must have a current interest rate in excess of 5.25 percent. The refinanced rate must reduce monthly payments by at least $100.

Walter Investment Management owns Green Tree Finance, while Walter Investment Management is owned by Bank of America. Through a complicated web of ownership, Bank of America owns Green Tree Finance and, therefore, should provide eligible ex-customers with mortgage relief required by the settlement.

The settlement does not provide immunity or release for criminal conduct, and complaints for wrongdoing by the banks may be filed with California Attorney General Kamala Harris.

Cynthia Ruehlig, Antioch