Mr Cooper Group Inc (COOP)

[survivor Spain]

The battle grounds we are not fighting properly.

It seems that WMI fight in the courts is in good progress. We may argue that we still miss proper representation of shareholders in the BK court. I tend to thinks it would be better to be represented by an official comite. But I do understand the doubts of others about this becoming more a burden or delay in the process. I am not sure. However at any rate the fight in the courts is hot and pretty well covered.

However the more I think about it, the more I miss more action in two battle fields:

- Press/Media.
- Regulatory bodies. Specifically the SEC.

The lack of Press/Media attention has been discussed in this board a number of times. Although something is leaking drop by drop it's frustrating to witness what seems to be an orchestrated blackout. Frustrating as it is, I don't have much to contribute here, so I will focus in the next point.

ATTITUDE AND ROLE OF THE SEC. CAN WE DO SOMETHING ABOUT IT?
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At the end, the goal I have in mind is to add more pressure to JPM in order to force a settlement. The most sensitive topic for JPM is its pps and this is closely related to their public information to analysts and investors, as well as the credibility what they report.

One of the key SEC's roles is to grant that JPM's reporting ( as any public company) adjusts to reality. After the ENRON and WORLDCOM scandals the ultimate law regulating this is Sarbanes-Oxley (SOX).

SOX states and enforces very severe requirements in many aspects of the financial reporting. I am here specially interested in the OBLIGATION of companies to report ANY SIGNIFICANT KNOWN CONTINGENCY that may impact negatively the earnings or balance sheets.

Ok, JPM has not reported the 4B as their own, but until now these 4B are still reflected in their books as customer's deposits. I mean, here they are playing safe in their books.

However WMI's claims/counterclaims already involve not just the 4B, but up to 10B if we include the other concepts. It also questioned literally the whole conveyance as possibly fraudulent.

My point:

JPM has not reported to the analysts and to the SEC any contingency in their books for at least these 6B (10-4B=6B). And JPM's can neither deny this is a "significant potential contingency" nor this is "known contingency".

If the BK process wouldn't have matured so fast, then it could be argued that the contingency was not real yet, ... this could be the case in the Texas Action.

However, right now, in theory, a judge has stated clearly that she's entitled to rule on the matter, and in theory she could rule any day that up to 6B in JPM'S books should be in WMI's books. If this is not a relevant contingency, then I am a ballet dancer.

The SEC is supposed to monitor that JPM complies with SOX and reports these contingencies. Ok, let's ask the SEC to do so.

ACTION POINT FOR US:
====================

We can file our concerns to the SEC by email - [e-mail] - or online at:

http://www.sec.gov/complaint.shtml

then, online complains:

http://www.sec.gov/complaint/selectconduct.shtml

then I would chose options 11 or 12 (one of the two about fraud to file proper information ). These are:

http://www.sec.gov/complaint/cf942sec9570.htm

or

http://www.sec.gov/complaint/cf942sec9570.htm


Core of the complaint: "Shouldn't JPM report possible contigencies of several $B, related to WMI's claims in the Delaware BK court?" ... I guess anyone of us could word it as it wants, but in a nut-shell my focus would be around doubts that JPM's is informing properly its investors about the status of the WB affair and its impact in JPM'S earnings.

ANOTHER POSSIBLE SEC's battle fields
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- Did SEC investigated the massive after-market sales of WAMU during the hours previous to the seizure communication? Normal investors were not able to escape, but the aftermarket volume and the price drop showed some insiders did.

- By the SEC short-sales rules applicable during the pre-seizure days all WAMU short positions should have been covered by the end of Sept,24th. Has SEC investigated if this really happened? Who coverd the short positions and who didn't?


Well,... in summary my message here is ... we do have some means to add pressure through the SEC, and we should start using these means.

Cheers...