BankClassActions.com, Inc.

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50. As indicated hereinabove, because, upon information and belief, CitiBank N.A. has an \\\"affiliated business arrangement\\\" with Defendant, Defendant has breached its obligations referred to in the aforementioned “Consent Order.” FIRST CAUSE OF ACTION: RESPA VIOLATIONS FOR NOT PROVIDING REQUIRED INFORMATION 51. Plaintiff restates, realleges, and incorporates herein by reference, paragraphs 1-50 as if set forth fully in this cause of action. 52. Defendant is, by definition, the loan servicer of Plaintiff’s loan pursuant to 12 U.S.C. § 2605(i)(2).5 53.

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