Defendants are therefore a commercial creditor holding securities

1. Plaintiffs claims cite the mortgage lender as the principal party "beneficiary" entitled to the mortgage receivable as a present value and future value consideration holding plaintiffs servicing rights. 
2. Defendants are a collaborate electing to liquidate it's asset "holdings" in favor of a private offering "registration" of common stock that early discovery demonstrates is concurrently placed into certain depositors paid in capital account. 
3. The controversy argues the subject mortgage given in good faith by plaintiff to defendants is used to construct the "creditors" pledge account . 
4. Defendants collaborate as a banking commercial creditor, subject of controversy for bond holder claims. Defendants are a banking commercial creditor,affirmed not to be one in the same with the beneficial interest in title held of record. The creditor interests is enforceable  by UCC filings provide by obligors for balance used to finance a securities offering. 
5. Defendants are therefore a commercial creditor holding securities financed by satisfaction of the mortgagors subject loan , the obligation outstanding due by the obligors for funds originally delivered at closing into settlement.     
6. Defendants are identified as a failed and liquidated mortgage platform for the FDIC member bank under the OTS  regulatory scheme. Allegations are the parties of interest fail in a conventional foreclosure relying on the  electronic reconciliation and recording of satisfaction found under it nominee Mers Corp 
7. Mers Corp records are prima fascia to arguments demonstrating satisfaction for all outstanding balances due under the plaintiffs promissory note and deed of trust "Aka" Mortgage. 
8. Defendants are a collaborate facing a historically unprecedented dilemma offering domestic and international problematic issues at law which prohibit 1) servicing rights, 2) satisfying a request for demand, 3) calculating per Diem interest and 4) initiating or conveying offers to modify debt that was satisfied 
9. Further, the civil code of procedures are clearly absent the non juridical allowances for power of sale whereby an alleged "deed for bond" cannot be restored barring a novation. Therefore an economic hurdle emerges by operation of law that demands any and all financial precedence for restoring liquidated values to coincide with a servicing agents claims calling to a conventional foreclosure under a bond issuer's default. 

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