Mortgage Servicing Fraud
occurs post loan origination when mortgage servicers use false statements and book-keeping entries, fabricated assignments, forged signatures and utter counterfeit intangible Notes to take a homeowner's property and equity.
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In a very nice concise opinion citing Schwartzwald and a post-commencement FDIC assignment in favor of OneWest, the Ohio Court of Appeals for the Sixth District reversed and dismissed a summary judgment:

Onewest Bank v. Yevtich, 2012-Ohio-6246 (Ohio 6th District, December 31, 2012)

Though not authoritative in other jurisdicitons, perhaps this decision can be a helpful and instructive decision to cite by a defendant facing a similar post-commencement FDIC assignment into OneWest!
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