Brad
Rosa
worked
at
UWM
from
February
2024
to
December
2025
as
in-house
counsel
in
the
company’s
title
review
and
closing
(TRAC)
department,
which
employed
nearly
40
attorneys.
In
his
role,
Rosa
reviewed
public
land
records
and
issued
AOLs
for

conventional
refinance
loans
under
UWM’s
TRAC
program.

The
lawsuit
was
filed
Tuesday
in
the

Superior
Court
of
the
State
of
California
for
Orange
County.
Eric
B.
Kingsley,
the
plaintiff’s
attorney
and
a
partner
at

Kingsley
Szamet
Employment
Lawyers,
also
shared
comments
with
HousingWire.

“The
benefit
to
the
company
(UWM)
would
be
the
ability
to
lower
its
labor
costs,”
Kingsley
wrote
in
an
email.
“By
using
their
own
out
of
state
lawyers
the
company
would
not
need
to
retain
lawyers
in
the
state
in
question.
This
is
just
a
corporation
cutting
corners
and
ignoring
ethical
and
legal
restrictions
to
enhance
profits.”

Lawsuit
details

Rosa
alleges
that
this
past
fall,
the
TRAC
AOL
program
was
replaced
by
a

TRAC+
Title
Standing
Letter
(TSL)
program.
During
this
transition,
“ghostwriting”
—
defined
in
the
complaint
as
preparing
title
opinions
that
were
then
signed
by
attorneys
licensed
in
the
relevant
state
—
was
a
common
practice
at
the
company.

Under
the
revised
program,
AOLs
were
rebranded
as
TSLs,
but
“the
substance
and
purpose
of
both
remained
the
same,”
according
to
the
lawsuit.
Rosa’s
responsibilities
also
remained
unchanged.
He
issued
legal
assessments
of
title
status,
identifying
defects
or
“clouds,”
and
evaluating
whether
a
new
mortgage
would
obtain
first-lien
priority.

But
the
lawsuit
claims
attorneys
were
informed
they
would
eventually
be
required
to
sign
TSLs
for
properties
located
in

states
where
they
were
not
licensed.
Concerns
with
the
move
were
addressed
in
a
12-page
document
sent
to
management,
as
well
as
during
a
meeting
held
in
October
involving
all
TRAC
attorneys
and
managers,
per
the
complaint.

Rosa
said
his
own
research
showed
that
some
states
address
the
issue
through
statutes,
while
others
rely
on
ethics
opinions
or
case
law.

In

Texas
—
a
state
where
he
allegedly
ghostwrote
several
letters
—
Rosa
said
an
exception
existed
only
if
legal
services
were
provided
solely
to
the
company
or
its
affiliates.
But
TSLs
were
shared
with
mortgage
brokers
to
clear
titles,
potentially
falling
outside
that
exception.
Also,
Rosa
claims
he
and
others
were
not
registered
as
in-house
counsel
as
the
work
involved
state-specific
title
opinions,
not
Michigan
or
federal
matters.  

According
to
the
complaint,
UWM
formally
changed
its
policy
in
November
to
require
corporate
title
attorneys
to
sign
TSLs
for
properties
in
states
where
they
were
not
licensed.
Attorneys
who
refused
to
do
so
10
times
would
have
their
refusal
treated
as
a
resignation.

The
new
policy
recognized
that
signing
such
letters
without
a
license
was
explicitly
prohibited
in
several
states,
including
Alabama,
Arizona,
California,
Florida,
Kentucky,
Louisiana,
New
Jersey,
Ohio,
Pennsylvania
and
South
Dakota.

“The
remaining
approximately
twenty-seven
states
where
the
program
was
active
did
not
expressly
prohibit
the
conduct,
but
also
did
not
affirmatively
authorize
it,”
the
complaint
states. 

Rosa
alleges
the
policy
change
was
driven
by
a
backlog
of
approximately
20
ghostwritten
files
that
lacked
signatures
by
Nov.
28.
He
claims
he
offered
to
sign
filings
in

California
and

Massachusetts,
where
he
was
licensed,
and
to
continue
ghostwriting
documents
for
other
states,
while
making
clear
he
did
not
intend
to
resign.

But
according
to
the
lawsuit,
Rosa
was
terminated
on
Dec.
3
during
a
phone
call.

The
UWM
spokesperson
said
in
a
statement
that
the
lawsuit
“directly
reflects
the
resistance
that
can
come
when
longstanding
industry
practices
and
large
insurance
companies
are
challenged.
“

“Unfortunately,
innovation
often
brings
scrutiny,”
the
spokesperson
added.
“UWM
will
continue
to
focus
on
doing
what’s
right
for
consumers
while
defending
its
position
both
in
this
lawsuit
and
on
behalf
of
its
mortgage
broker
clients.”

Rosa
is
seeking,
among
other
things,
compensatory
damages,
past
and
future
wages
and
bonuses,
and
civil
penalties
for
alleged
violations
of
the
California
Labor
Code.
He
is
also
demanding
a
jury
trial.