Proposed SCRA Servicing Agreement with Wells Fargo Bank

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USDOJ Servicemembers Civil Relief Act Settlement Provisions:

Wells Fargo Bank, N.A. and Wells Fargo & Company

In exchange for a full release of the United States’

potential civil claims under the

Servicemembers Civil Relief Act (“SCRA”), 50 U.S.C. app. § 501, et seq., arising prior to the

date of this agreement against Servicer

with respect to the servicing of residential mortgages,

under the provisions of the SCRA related to (a) mortgage foreclosure and (b) the prohibition

against charging more than 6% interest on SCRA-covered mortgaged debt after a valid request

by a servicemember to lower the interest rate and receipt of orders, Servicer agrees to the

provisions set forth below.

I. Servicer shall comply with all the “Protections for Military Personnel” provisions in the

Settlement Agreement (“Article V”). In addition, Servicer shall undertake additional

remedial action and agree to the policy changes set forth below.

II. Compensation for Servicemembers and Co-Borrowers

a. Violations of Sections 533 and 521 of the SCRA related to completed

foreclosures on active duty servicemembers: Servicer will engage an independent

consultant whose duties shall include a review of all completed foreclosures from

January 1, 2006 to the present to evaluate whether the completed foreclosures

were in compliance with Sections 533 and 521 of the SCRA. Servicer shall

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The following claims are specifically reserved and not released: Any action that may be taken by the appropriate

Federal Banking Agency (FBA), as defined in 12 U.S.C. § 1813(q), against Servicer, any of its affiliated entities,

and/or any institution-affiliated party of Servicer, as defined in 12 U.S.C. § 1813(u), pursuant to 12 U.S.C. § 1818,

and any action by the FBA to enforce the Consent Order issued against Servicer by the FBA on April 13, 2011.

For purposes of the agreement in this exhibit, “Servicer” shall mean Wells Fargo Bank, N.A. and Wells Fargo &

Company, and their successors and assignees in the event of a sale of all or substantially all of the mortgage

servicing related assets of (1) Wells Fargo Bank, N.A. or Wells Fargo & Company, or (2) any of Wells Fargo Bank,

N.A. or Wells Fargo & Company’s division(s) or major business unit(s) that are engaged in servicing residential

mortgages.

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propose an independent consultant and submit the independent consultant’s

proposed methodology to DOJ for approval within 30 days after the entry of this

agreement. The independent consultant shall begin its review within 30 days after

receiving the above-referenced approvals by DOJ. The independent consultant

shall submit the results of its review to DOJ within 150 days after it receives the

data necessary for its analysis from the Department of Defense’s Defense

Manpower Data Center (“DMDC”) providing relevant periods of military service

of borrowers for completed foreclosures from January 1, 2006 to present. Based

on the information gathered by the independent consultant, information submitted

by Servicer, and DOJ’s independent investigation, DOJ shall make the

determination reasonably based on the information it has received and its

investigative conclusions whether or not a completed foreclosure was in

compliance with the SCRA. In the event Servicer disagrees with the DOJ’s

determination, Servicer shall be afforded 30 days to produce evidence of

compliance, which DOJ shall consider in good faith. Where DOJ determines that

a foreclosure was not in compliance with the SCRA, Servicer shall compensate

the borrowers (i.e., any individual(s) who signed the note with respect to a

foreclosed property) by providing:

(1) an amount of $116,785.00 to the servicemember-borrower or an amount

consistent with what was provided under the OCC Consent Order Independent

Review Process for similar violations of Sections 533 or 521 of the SCRA,

whichever is higher;

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(2) any lost equity in the foreclosed property, as calculated by: subtracting:

(a) any outstanding principal, interest, and other amounts owing by the

borrowers (excluding any fees associated with foreclosure) plus any

junior liens at the time of foreclosure and any disbursements made to

the servicemember or a third party other than a junior lien holder from

the proceeds of the foreclosure sale (exclusive of any fees associated

with the foreclosure) from

(b) Either:

i. a contemporaneous appraisal reflecting the value of the

home at the time of foreclosure;

ii. a BPO or other desktop determination of property valuation

that results in property valuations reasonably consistent

with those contained in contemporaneous appraisals; or

iii. a retroactive appraisal reflecting the value of the home at

the time of foreclosure; and

(3) interest accrued on this lost equity, calculated from the date of the foreclosure

sale until the date payment is issued, at the rate set forth in 28 U.S.C. § 1961.

While the amount described in subsection (1) shall be paid entirely to the

servicemember-borrower on the note securing the mortgage, the amounts

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Before Servicer may rely on a BPO or desktop determination for purposes of this subsection, Servicer must first

obtain DOJ approval that the methodology for the BPO or desktop determination results in property valuations

reasonably consistent with a contemporaneous appraisal. DOJ shall not unreasonably withhold such approval.

The independent consultant shall calculate the lost equity and interest described herein as part of its review.

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described in subsections (2) and (3) shall be distributed among all owners

(including non-servicemember owners) on the deed.

In cases where Servicer has

already taken remedial actions with respect to a foreclosure which DOJ

determines did not comply with Sections 533 or 521 of the SCRA, DOJ shall

consider such remedial actions and adjust the compensation to be awarded to the

subject borrower or mortgagor.

DOJ will submit lists or electronic links to, the

Servicer identifying servicemembers or co-borrowers to be compensated, and

Servicer must notify each identified servicemember or co-borrower (using best

efforts to locate each person) by letter (using Exhibit 1 or a modified version

mutually agreeable to Servicer and DOJ) within 45 days of receiving this list.

Any letters returned with forwarding addresses must be promptly mailed to the

forwarding address. Servicer shall issue and mail compensation checks no later

than 21 days after receipt of a signed release from the servicemember or co-

borrower aggrieved person. Every 6 months for a period of two years following

entry of this agreement, Servicer shall provide the DOJ with an accounting of all

releases received, checks issued (including copies of issued checks), credit entries

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If information is available regarding percentages of ownership interest in the subject property, the amounts

described in subsections (2) and (3) will be distributed in amounts proportionate to the ownership interests.

Otherwise, amounts described in subsections (2) and (3) will be distributed equally among owners.

In determining the amount of compensation due to any servicemember or co-borrower pursuant to Subsection II.a,

DOJ will credit any monetary compensation or other remediation efforts, including returning the home to the

borrower, already provided to any servicemember or co-borrower for alleged compliance issues pursuant to Sections

533 or 521 of the SCRA and arising from the same mortgage. In the event that a servicemember located through

the OCC Independent Consultant review process elects to receive the return of his or her home in lieu of a flat fee

damages payment pursuant to the OCC Consent Order remediation plan (which payment shall not be less than the

amount provided in Section II.a.(1))for violations of Sections 533 or 521 of the SCRA and arising from the same

mortgage, the servicemember shall be compensated pursuant to the terms of the OCC Consent Order remediation

plan rather than Section II.a of this agreement.

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repaired, and notifications without responses or that were returned as

undeliverable.

b. Violations of Section 527 of the SCRA related to failing to limit interest rates to

6% on SCRA-covered mortgage debt: Servicer will engage an independent

consultant whose duties shall include a review of either all or a sample of

mortgage loans where a borrower on the note securing the mortgage submitted a

request either orally or in writing for protection under Section 527 of the SCRA

from January 1, 2008 – present to evaluate whether the Servicer complied with

Section 527 of the SCRA. The DOJ shall determine whether a sample or a

comprehensive review, or some combination thereof, would be more appropriate

to locate potential violations by the Servicer. The consultant’s methodology must

be submitted to DOJ for approval within 60 days after entry of this agreement.

DOJ’s approval of the methodology will be based on, among other things, DOJ’s

evaluation of the Servicer’s SCRA policies in and around the time period in

question, Servicer’s search capabilities for determining which individuals

requested, either orally or in writing, interest rate protections based on their

military status, the servicing platform, and the number of individuals who

requested such protection. The consultant shall submit the results of its review

within 180 days after DOJ’s approval of the methodology. Based on the

information gathered by the consultant, information submitted by the Servicer,

and DOJ’s independent investigation, DOJ shall make the determination,

reasonably based on the information it has received and its investigative

conclusions, whether or not potential violations of Section 527 occurred. In the

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event Servicer disagrees with the DOJ’s determination, Servicer shall be afforded

30 days to produce evidence of compliance, which DOJ shall consider in good

faith. Where DOJ determines that a mortgage loan was not serviced in

compliance with Section 527, Servicer shall: (1) refund (with interest, as

calculated pursuant to 28 U.S.C. § 1961) all interest and fees charged above 6%;

and (2) provide an additional payment of $500 or triple the amount of the refund

referenced in subsection (1), whichever amount is larger.

The compensation

described in subsection (1) shall be distributed equally among all borrowers

(including non-servicemember borrowers) on the note secured by the mortgage.

The compensation described in subsection (2) shall be paid entirely to the

servicemember. In cases where Servicer has already taken remedial actions with

respect to a mortgage which DOJ determines did not comply with Section 527 of

the SCRA, DOJ shall consider such remedial actions and adjust the compensation

to be awarded to the subject servicemember, borrower, or mortgagor.

DOJ will

submit lists or electronic links to the Servicer of identified servicemembers or co-

borrowers to be compensated, and Servicer must notify each identified

servicemember or co-borrower (using best efforts to locate each person) by letter

(using Exhibit 2 or a modified version mutually agreeable to Servicer and DOJ)

within 60 days of receiving this list of servicemembers or co-borrowers to be

compensated. Any letters returned with forwarding addresses must be promptly

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The independent consultant shall calculate the amounts described herein as part of its review.

In determining whether any compensation is due to any servicemember or co-borrower pursuant to Subsection

II.b, and, if so, ,the amount DOJ will consider the timing of any remedial actions and will credit any monetary

compensation already provided to any servicemember or co-borrower for alleged compliance issues pursuant to

Section 527 of the SCRA and arising from the same mortgage, and/or provided under the OCC Consent Order

Independent Consultant review process for violations of Section 527 of the SCRA and arising from the same

mortgage.

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mailed to the forwarding address. Servicer shall issue and mail compensation

checks no later than 21 days of receipt of a signed release from the

servicemember or co-borrower aggrieved person. Every 6 months for a period of

two years following entry of this agreement, Servicer shall provide the DOJ with

an accounting of all releases received, checks issued (including copies of issued

checks), credit entries repaired, and notifications without responses or that were

returned as undeliverable.

c. Concurrent with providing financial compensation to the servicemember-

borrower, Servicer must request that all three major credit bureaus remove

negative entries for the servicemember(s) and any co-borrower(s) attributable

specifically to the wrongful foreclosure or interest overcharges and Servicer shall

not pursue, and must indemnify the servicemember and his or her co-borrower(s)

against any third-party pursuing, any deficiency that was remaining on the

servicemember’s SCRA-protected mortgage or junior lien after a foreclosure was

completed in violation of the SCRA.

d. Servicer shall have 10 days after DOJ’s final determination that a foreclosure was

not in compliance with the SCRA or a mortgage loan was not serviced in

compliance with Section 527, to seek judicial review on the ground that DOJ

made a clearly erroneous factual determination.

III. SCRA Compliance Policies

a. Servicer shall submit SCRA mortgage foreclosure-related policies to DOJ for

review and approval. If the Servicer decides to make a material modification to

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these policies, Servicer will provide the modified policies for review and

approval. DOJ will advise Servicer of the results of DOJ’s review within 60 days

of receipt of a complete submission of all SCRA mortgage foreclosure-related

policies and any subsequent material modifications. In addition to the areas

covered under the “Protection of Military Personnel” provisions in the attached

document, these policies must address:

i. Prior to referring a loan to foreclosure, the Servicer shall review any orders

it has received from borrowers

and check borrowers’ names and social

security numbers against the DMDC website as provided in the

“Protections of Military Personnel” provisions in the Settlement

Agreement.

ii. If Servicer pursues a foreclosure action in court and the borrower fails to

answer the action, Servicer and/or its agent will file a military affidavit

with the court as required by Section 521(b)(1)(A). After the borrower

fails to answer and prior to seeking entry of default, Servicer and/or its

agent will query the DMDC and review information in its possession or

control for orders to determine if the borrower is on active duty. If

Servicer and/or its agent learns that the borrower is on active duty or was

on active duty at the time of his or her failure to answer Servicer and/or its

agent will file an affidavit stating that “the defendant is in military service”

or “was in military service at the time of his or her failure to answer” prior

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For the purposes of locating orders to be reviewed pursuant to Sections III.a.i and III.a.ii of this agreement, it shall

be sufficient for the Servicer to flag or code accounts upon receipt of orders and rely on that system.

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to seeking default judgment and attaching the most recent certificate of

service from the DMDC or a copy of the military orders.

iii. If Servicer initiates and pursues a waiver under a written agreement as

provided in Section 517 of the SCRA, Servicer must initiate the waiver

process with the servicemember at least 30 days in advance of any

anticipated foreclosure sale date by sending a notice and a copy of the

proposed waiver to the servicemember. To the extent Servicer exercises

this right, Servicer shall utilize a notice and proposed waiver in the form

attached as Exhibit 3. This provision may be modified based on changes in

servicing requirements from government-sponsored entities or the

Department of Housing and Urban Development.

b. Servicer shall submit SCRA mortgage loan interest rate-related policies to DOJ

for review and approval. If the Servicer decides to make a material modification

to these policies, Servicer will provide the modified policies for review and

approval. DOJ will advise Servicer of the results of DOJ’s review within 60 days

of receipt of a complete submission of all SCRA mortgage loan interest rate-

related policies and any subsequent material modifications. In addition to the

areas covered under Article V of the Settlement Agreement, these policies must

address:

i. Servicer shall accept servicemembers' requests for reduced mortgage

interest rates pursuant to the SCRA via electronic mail, facsimile, U.S.

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Mail, Federal Express or other overnight/express delivery to facsimile

numbers and addresses designated by the Servicer. Within six months after

entry of this agreement, Servicer shall also accept servicemembers’

requests for reduced mortgage interest rates pursuant to the SCRA via in-

person delivery at the Servicer’s full-service branch locations, should the

Servicer maintain branch locations.

ii. When a servicemember requests interest rate relief under the SCRA,

Servicer shall accept orders as defined in the Settlement Agreement or any

other document that the DOD shall deem sufficient as a substitute for

official orders.

iii. Servicer shall seek only orders identifying the beginning date of the

applicable period of military service from the requesting servicemember

and may not condition providing SCRA benefits on the servicemember

submitting orders that include an end date.

iv. Before concluding that the SCRA permits raising the interest rate on the

servicemember's loan higher than six percent, the Servicer shall access the

DMDC website to determine the dates, where available, of active duty

military service of those servicemembers who request reduced interest rates

pursuant to the SCRA. If DMDC indicates that the individual is still on

active duty, the Servicer must continue to limit the charges pursuant to

Section 527 of the SCRA.

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v. For those servicemembers who request a reduced interest rate pursuant to

the SCRA, but are determined not to be eligible for the reduced rate,

Servicer shall notify the servicemembers in writing of the reasons for the

denial and that they may provide additional documentation or information

to establish eligibility for the reduced interest rate.

c. In the event that DOJ requires a change or modification pursuant to this

agreement that is in conflict with a policy required by the appropriate Federal

Banking Agency (FBA), as defined in 12 U.S.C. § 1813(q), under the Consent

Order issued against the Servicer by the FBA on April 13, 2011, and the FBA will

not consent to the change, DOJ shall meet and confer with the FBA to resolve the

conflict. Nothing in this agreement prevents DOJ from requiring Servicer to

adopt policies that provide additional protections beyond the policies required by

the FBA.

IV. Training and Monitoring Program

a. Within 45 days after entry of this agreement, Servicer shall provide its proposed

training on the SCRA and this settlement to DOJ for approval. After receiving

DOJ’s approval, Servicer shall provide and require training on the SCRA and this

settlement for employees (including management officials): (1) providing

customer service to servicemembers, (2) involved in mortgage servicing,

including adjusting interest rates for mortgage loans, or (3) with significant

involvement in the foreclosure process, within 60 days of DOJ’s approval (if

already employed in such a position), or within 30 days of his or her hiring,

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promotion, or transfer. Servicer shall also obtain confirmation from third-party

vendors, law firms, and/or trustee companies involved in conducting foreclosures

that their employees who are involved in the foreclosure process have been

trained on their obligations to comply with this settlement and the SCRA.

b. Servicer shall implement a monitoring program approved by DOJ designed to

ensure compliance with this settlement and the SCRA. At a minimum,

monitoring will include a quarterly report to be submitted to DOJ

within 60 days

after the end of each quarter containing an analysis of a sample of foreclosures

and a sample of mortgages where a borrower or mortgagor submitted orders

seeking protection under Section 527 of the SCRA to determine compliance with

the SCRA and this settlement. If Servicer learns that despite the policies required

by Section III a violation of Section 521, 527 or 533 has occurred, Servicer will

take corrective action as set forth in Section II of this agreement.

V. Term of Agreement

This agreement shall retain full force and effect for three and one-half years from

the date it is entered (the “Term”). Servicer’s obligation pursuant to Section III to

submit quarterly reports and DOJ’s review of the same shall continue for the six

months following the Term, after which time Servicer shall have no further

obligations under this agreement.

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All materials required by this Order to be sent to the Department of Justice shall be sent by commercial overnight

delivery service addressed as follows: Chief, Housing and Civil Enforcement Section, Civil Rights Division, U.S.

Department of Justice, 1800 G Street NW, Washington, D.C. 20006, Attn: DJ 216-16-4..

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EXHIBIT H - 1

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[SCRA NOTIFICATION LETTER FOR SECTION 533 SERVICEMEMBER]

Name of Servicemember

123 Main Street

City, State Zip code

Re: Loan Number [Insert]

Dear [Servicemember]:

We write to inform you that ________________ (“the Bank”), entered into a settlement on

_______________, with the United States Department of Justice regarding alleged violations of

the Servicemembers Civil Relief Act (“SCRA”). This settlement resolves the Department of

Justice’s allegations that the Bank foreclosed on properties without approval by a court when the

SCRA required that the foreclosures be approved by a court.

In connection with this settlement, the Department of Justice identified you as a person

who may be eligible for financial compensation with respect to your loan [add loan number(s)].

Please read and carefully review the declaration attached to this letter. If it is accurate, please

sign and return to us the release and declaration attached to this letter in the enclosed postage

paid envelope. After we receive these documents, we will send you a check in the amount of

[insert amount]. This amount includes any equity remaining in your home at the time of the

foreclosure and monetary damages. In addition, the Bank will request that all major credit

bureaus remove any negative entries on your credit report resulting from the foreclosure. This

release and declaration must be returned by __________.

You should be aware that the money you are eligible to receive may have consequences

with respect to your federal, state, or local tax liability, as well as eligibility for any public

assistance benefits you may receive. Neither the Bank nor the Department of Justice can advise

you on tax liability or any effect on public assistance benefits. You may wish to consult with a

qualified individual or organization about any possible tax or other consequences resulting from

your receipt of this payment.

If you have any questions concerning the declaration, release or settlement or if anyone

seeks to collect a debt arising from your mortgage, please contact [Insert Independent Consultant

Name] at [Insert Contact Information including a phone number].

We deeply appreciate your service to our country. We are committed to serving the

financial needs of our customers who serve in the military, and we regret any error that may have

occurred on your account.

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Sincerely,

[Name]

[Title]

Enclosures: Release and Declaration

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RELEASE

In consideration for the parties’ agreement to the terms of the Consent Order entered

in_________________________________ , and the Defendant’s payment to me of

$______________, pursuant to the Consent Order, I hereby release and forever discharge all

claims, arising prior to the entrance of this Order, related to the facts at issue in the litigation

referenced above and related to the alleged violations of Section 533 of the Servicemembers

Civil Relief Act, that I may have against the Defendant, all related entities, parents, predecessors,

successors, subsidiaries, and affiliates, and all of its past and present directors, officers, agents,

managers, supervisors, shareholders and employees and their heirs, executors, administrators,

successors or assigns.

Executed this day of , 20 .

Signature

Print Name

Address

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[SCRA NOTIFICATION LETTER FOR SECTION 533 CO-BORROWER]

Name of Co-borrower

123 Main Street

City, State Zip code

Re: Loan Number [Insert]

Dear [Co-borrower]:

We write to inform you that ________________ (“the Bank”), entered into a settlement on

_______________, with the Department of Justice regarding alleged violations of the

Servicemembers Civil Relief Act (“SCRA”). This settlement resolves the Department of Justice’s

allegations that the Bank foreclosed on properties without approval by a court when the SCRA

required that the foreclosures be approved by a court.

In connection with this settlement, the Department of Justice identified you as a person

who may be eligible for financial compensation with respect to your loan [add loan number(s)].

If you sign and return to us the release attached to this letter in the enclosed postage paid

envelope and your co-borrower signs and returns the declaration and release that will be sent

separately to your co-borrower, we will send you a check in the amount of [insert amount]. This

amount represents your portion of any equity remaining in your home at the time of the

foreclosure. In addition, the Bank will request that all major credit bureaus remove any negative

entries on your credit report attributable to the foreclosure.

To receive this payment, you must return the attached release within six months of the

date of receipt of this letter. The release, if signed, releases any claim to lost equity that you may

have under Section 533 of the SCRA; however, it does not release any other claim you may have

under the SCRA, including Section 533, or other laws.

You should be aware that the money you are eligible to receive may have consequences

with respect to your federal, state, or local tax liability, as well as eligibility for any public

assistance benefits you may receive. Neither the Bank nor the Department of Justice can advise

you on tax liability or any effect on public assistance benefits. You may wish to consult with a

qualified individual or organization about any possible tax or other consequences resulting from

your receipt of this payment.

If you have any questions concerning the release or settlement or if anyone seeks to

collect a debt arising from your mortgage, please contact [Insert Independent Consultant Name]

at [Insert Contact Information including a phone number].

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We are committed to serving the financial needs of our customers who serve in the

military, and we regret any error that may have occurred on your account.

Sincerely,

[Name]

[Title]

Enclosure: Release

H - 19

________________________________________

Case 1:12-cv-00361-RMC Document 1-2 Filed 03/12/12 Page 297 of 314

RELEASE

In consideration for the parties’ agreement to the terms of the Consent Order entered

in_________________________________ , and the Defendant’s payment to me of

$______________, pursuant to the Consent Order, I hereby release and forever discharge any

claim under Section 533 of the Servicemembers Civil Relief Act for lost equity in the property

related to the litigation referenced above and arising prior to the entrance of this Order, that I

may have against the Defendant, all related entities, parents, predecessors, successors,

subsidiaries, and affiliates, and all of its past and present directors, officers, agents, managers,

supervisors, shareholders and employees and their heirs, executors, administrators, successors or

assigns.

Executed this day of , 20 .

Signature

Print Name

Address

H - 20

Case 1:12-cv-00361-RMC Document 1-2 Filed 03/12/12 Page 298 of 314

[SCRA NOTIFICATION LETTER FOR SECTION 521 SERVICEMEMBER]

Name of Servicemember

123 Main Street

City, State Zip code

Re: Loan Number [Insert]

Dear [Servicemember]:

We write to inform you that ________________ (“the Bank”), entered into a settlement on

_______________, with the United States Department of Justice regarding alleged violations of

the Servicemembers Civil Relief Act (“SCRA”). This settlement resolves the Department of

Justice’s allegations that the Bank foreclosed on servicemembers through default court

proceedings without filing accurate affidavits notifying the court of the servicemembers’ military

statuses.

In connection with this settlement, the Department of Justice identified you as a person

who may be eligible for financial compensation with respect to your loan [add loan number(s)].

Please read and carefully review the declaration attached to this letter. If it is accurate, please

sign and return to us the release and declaration attached to this letter in the enclosed postage

paid envelope. After we receive these documents, we will send you a check in the amount of

[insert amount]. This amount includes your portion of any equity remaining in your home at the

time of the foreclosure and monetary damages. In addition, the Bank will request that all major

credit bureaus remove any negative entries on your credit report resulting from the foreclosure.

This release and declaration must be returned by __________.

You should be aware that the money you are eligible to receive may have consequences

with respect to your federal, state, or local tax liability, as well as eligibility for any public

assistance benefits you may receive. Neither the Bank nor the Department of Justice can advise

you on tax liability or any effect on public assistance benefits. You may wish to consult with a

qualified individual or organization about any possible tax or other consequences resulting from

your receipt of this payment.

If you have any questions concerning the declaration, release or settlement or if anyone

seeks to collect a debt arising from your mortgage, please contact [Insert Independent Consultant

Name] at [Insert Contact Information including a phone number].

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Case 1:12-cv-00361-RMC Document 1-2 Filed 03/12/12 Page 299 of 314

We deeply appreciate your service to our country. We are committed to serving the

financial needs of our customers who serve in the military, and we regret any error that may have

occurred on your account.

Sincerely,

[Name]

[Title]

Enclosures: Release and Declaration

H - 22

________________________________________

Case 1:12-cv-00361-RMC Document 1-2 Filed 03/12/12 Page 300 of 314

RELEASE

In consideration for the parties’ agreement to the terms of the Consent Order entered

in_________________________________ , and the Defendant’s payment to me of

$______________, pursuant to the Consent Order, I hereby release and forever discharge all

claims, arising prior to the entrance of this Order, related to the facts at issue in the litigation

referenced above and related to the alleged violations of Section 521 of the Servicemembers

Civil Relief Act, that I may have against the Defendant, all related entities, parents, predecessors,

successors, subsidiaries, and affiliates, and all of its past and present directors, officers, agents,

managers, supervisors, shareholders and employees and their heirs, executors, administrators,

successors or assigns.

Executed this day of , 20 .

Signature

Print Name

Address

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Case 1:12-cv-00361-RMC Document 1-2 Filed 03/12/12 Page 301 of 314

[SCRA NOTIFICATION LETTER FOR SECTION 521 CO-BORROWER]