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Privileged & Confidential
Attorney-Client Privileged
Attorney Work Product
Investigative Material
MEMORANDUM FOR THE RECORD - MFR
EVENT: Interview with Irma Aninger
TYPE OF EVENT: Phone Interview
DATE OF EVENT: March 3, 2010; 1:25-2:10
TEAM LEADER: Troy Burrus
LOCATION: Phone from FCIC
PARTICIPANTS- NON-COMMISSION:

Irma Aninger

PARTICIPANTS- COMMISSION:

Troy Burrus

MFR PREPARED BY: Troy Burrus
DATE OF MFR: March 4, 2010
This is a paraphrasing of the interview dialogue and is not a transcript and should not be
quoted except where clearly indicated as such.
Summary of Interview
On Wednesday, March 3, 2010, I spoke to Irma Aninger, a former contractor for Clayton
Holdings, Inc. (CHI), regarding her work at CHI. I identified myself to her as an agent working
on behalf of the Financial Crisis Inquiry Commission (FCIC). I asked her if she would be
willing to speak with me regarding her experiences at CHI. She agreed and provided the
following information:
1.

36 CFR 1256.56 - Privacy

She is a former contractor for CHI. She has extensive experience
working in the loan underwriting industry. She worked for CHI from 1995 through 2002.
She had prior underwriting experience with other firms in California. When she started
there in 1995, they only hired people with five years previous experience in the
underwriting business.

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2. She worked as an underwriter and also as a quality control (QC) person at CHI. She
never supervised anyone during her tenure with CHI. The work process changed during
her employment. CHI developed a computer software program (CLAS) to process the
loan packages. She received some training on how to use the program. She received no
formal training in underwriting from CHI, since she was an experienced underwriter.
Starting in 2000, new underwriters were given a two week training course. All of the
information was to be entered into the computer program so that the loans could be
processed. She was never told how many loans to process in a day. It usually took her
30 to 45 minutes to do one loan. She usually worked at the sellers’ job site. When you
arrived at the site, the computers would be setup and connected to a server. Information
would be downloaded from the server to the computers so you could review it, along with
other paper documents. You would then input the information into CLAS. Based on this
information, you would make a determination on the loan, either accepted or declined.
3. Before subprime loans, the market was much different. The loan documents were
entirely paper. There were standards (i.e. 20 percent down payments, wage and income
verification, etc.) applied to all of the loans. Loans that did not meet these standards were
declined outright. If someone did not have a 20% down payment, then you had to have
PMI. The underwriters knew each other and had solid qualifications. When the
subprime mortgages started most of these standards were waived. They were flooded
with loans and CHI started hiring people who had limited education and minimal
training. The volume increased from 100 loans per job to 27,000 loans per job in some
cases. Also, the work hours increased substantially. The typical work day was at least
ten hours. Each job had a lead person who ran the job. They were paid a bonus if the job
was completed early. Quality suffered as the work hours increased. Work conditions
were less than ideal. On one job for New Century they had thirty underwriters in a very
small room, basically sitting on top of each other. CHI did not pay overtime at first and
got into trouble for not doing so. She never spoke to any of the lenders or borrowers. All
communications went through the lead at the site.
4. She would analyze the documents, input the information into the computer and then
based on the data mark the loan as approved or declined. If it was declined, the reasons
for the declination would be noted to the file. She never knew what happened to the
loans once she completed her work on them. She saw loans that had inflated appraisals,
inflated wages and earnings. She would mark these as declined and notate the reason.
She was not given any tools to research issues with the loans. About thirty percent of the
loans she saw were bad or fraudulent. The lead on the job would be the one who made
the decision about whether a loan would ultimately be approved. She was told by
36 CFR 1256.56 - Privacy
once that you could not accuse someone of fraud since they had signed the forms
under penalties of perjury that they were true and correct.

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5. When she worked as a QC, her job was to review the input done by the underwriters. She
would look for input errors regarding dates and numbers. She scrutinized the work of the
less experienced underwriters more heavily. Any mistakes she found, she would correct.
Then she would forward it on to the lead for a final determination. As a QC you did not
change the status of a loan (from accept to decline or vice-a-versa).
6. CHI had rampant nepotism within the management ranks. Most of the QC and lead
personnel were related to each other.
36 CFR 1256.56 - Privacy

7. She also worked for Pennfund and Quickloan Funding. At these firms, 100 percent of the
loans were fraudulent. They were mostly straw buyer loans with inflated appraisals that
were intended to be flipped. The Orange County California register has numerous
articles and stories about Quickloan Funding. The owner, Daniel Sadey was grossing $5
million a month and had approximately 700 employees. She also worked for
Countrywide, which had issues. They had no original documents to review, only copies.
The documents were also in disarray and difficult to review. They spent hours trying to
sort them out and determine what was missing or incomplete. Many of the loans during
2000 through 2002 were “Ninja Loans”. This stands for No Income, No Job or Assets
loans. She could not believe that these loans were being bought and sold by companies.
When you asked for additional documents, you did not get them. Towards the end, the
loans became so poor that buyers started sampling the entire pool of loans. In the past
they would only sample about twenty percent of the loans.
8. She no longer works in this industry due to the crisis. With all of the defaults and
foreclosures there is no market for loan underwriters. She had over twenty-five years
experience in underwriting.
9. I thanked her for the information she provided. I told her that if she thought of anything
else to please give me a call. The interview terminated at this point.

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