Wallace v. Nationstar Mortgage LLC d/b/a Mr. Cooper
In an FHA foreclosure bench trial, Nationstar proved compliance with the 24 CFR § 203.604 face-to-face-meeting condition precedent solely through a 'F2F Results' document created by a fourth-party field-services vendor (JMA) hired by the prior servicer. The Second DCA held the document was not admissible under the business records exception because the successor servicer's generic boarding-process testimony did not establish trustworthiness of a non-numeric, event-documenting record created by a vendor whose practices the witness knew nothing about. Judgment reversed with directions to enter judgment for the borrowers.
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