43.  On or about December 15, 2000, Plaintiffs entered into a mortgage agreement with  Pinnfund USA.    44.  On or about January 1, 2007, Plaintiffs fell behind on their mortgage payments.   45.  On May 16, 2008, foreclosure proceedings were initiated against Plaintiffs  Fourteenth Judicial District, Rock Island County Illinois, case number 2008 Ch 226.    46.  On January 19, 2009, to save their home, Plaintiffs filed for Chapter 13  bankruptcy, Case No. 09-80141 (Bankr. C.D. Ill.).   47.  At the inception of the bankruptcy, Plaintiffs’ mortgage was serviced by Saxon  Mortgage Services.   48.  Plaintiffs’ amended Chapter 13 plan was confirmed by the bankruptcy court on  July 23, 2009.  The arrears to be paid on the mortgage was found to be $15,819.50.   49.  Plaintiffs successfully made their Chapter 13 payments to cure their arrears.    50.  During the course of the bankruptcy, on March 14, 2012, Saxon filed a notice of  transfer of servicing rights to Ocwen.  Ocwen thus acquired the servicing rights to Plaintiffs’  mortgage while the loan was in default.   52.  Plaintiffs were granted a discharge on March 25, 2014.   53.  On June 4, 2014, the bankruptcy court ordered (“Order on Final Cure”) that  Plaintiffs mortgage was deemed current as June 3, 2014, and that Ocwen had waived any right to  claim any additional payments or charges due from the Plaintiffs.   54.  At the completion of their bankruptcy, Plaintiffs owed $52,729.05 on their loan.   55.  Shortly after the bankruptcy ended, Ocwen dismissed the long-standing  foreclosure suit.   56.  In or around July 2014, Plaintiffs requested that Ocwen provide Plaintiffs with a  pay-off quote.   57.   On July 10, 2014, via U.S. Mail, Ocwen sent Plaintiffs a “Payoff Quote” that  stated that Plaintiff owed $84,447.58 on their mortgage, including $28,391.00 in interest that had  accrued during the bankruptcy, $2,248.85 for “Fee/Cost Adjustment,” and $738.35 in “Late  Charges.”  This was a materially false statement and an attempt to obtain monies from Plaintiffs  that they did not owe as a result of the Notice of Final Cure Payment and Order on Final Cure.    58.  Ocwen knew the charges were unlawful because it had received the Notice of Final  Cure Payment and the Order on Final Cure.  Further, Ocwen dismissed the foreclosure action,  which demonstrated that Ocwen was aware that the mortgage was current.   59.  In reliance on Ocwen’s fraudulent misrepresentations, Plaintiffs entered into a loan  modification agreement in September 2014 that increased the principal balance on Plaintiffs’ loan  to $82,112.07 – i.e., approximately $30,000 more than Plaintiffs actually owed.  By increasing the  principal balance of the loan, Ocwen unjustly increased its compensation in servicing the loan.   61.  Ocwen has also been misreporting the status of Plaintiffs’ loan on Plaintiffs’ credit  reports.  The amounts owed on the mortgage that Ocwen has reported to credit reporting agencies,  including to TransUnion regarding Plaintiff Robin Taylor, are inaccurate and do not account for  the outcome of the bankruptcy proceedings.   62.  By disregarding the bankruptcy proceedings and through its illegal, deceptive, and  fraudulent acts, Ocwen has enriched itself at the expense of Plaintiffs and denied them the fresh  start that Plaintiffs earned by successfully completing Chapter 13 bankruptcy.   63.  Ocwen’s actions violated RICO, the FDCPA, the ICFA and the Illinois common  law of unjust enrichment.  64.  Plaintiffs bring this action, on behalf of themselves and all others similarly  situated, as a class action under Rules 23(a), (b)(2) and (b)(3) of the Federal Rules of Civil  Procedure.   66.  Ocwen services thousands of mortgages that have been through Chapter 13  bankruptcy proceedings.  Therefore, the proposed Classes are so numerous that joinder of all  members is impracticable.   68.  Plaintiffs’ claims are typical of the claims of the Class and do not conflict with the  interests of any other members of the Class in that the Plaintiffs and the other members of the  Class were subject to the same wrongful policies and practices by Defendant.   70.  The prosecution of separate actions by individual members of the Class would  create a risk of adjudications with respect to individual members of the Class which would, as a  practical matter, be dispositive of the interests of other members of the Class who are not parties  to the action, or could substantially impair or impede their ability to protect their interests.    71.  The prosecution of separate actions by individual members of the Classes would  create a risk of inconsistent or varying adjudications with respect to individual members of the  Classes which would establish incompatible standards of conduct for the parties opposing the  Classes.  Such incompatible standards and inconsistent or varying adjudications, on what would  necessarily be the same essential facts, proof and legal theories, would also create and allow to  exist inconsistent and incompatible rights within the Plaintiff Class.    72.  Class certification is appropriate under Fed. R. Civ. P. 23(b)(2) because the  Defendant has acted or refused to act on grounds generally applicable to the Class making final  declaratory or injunctive relief appropriate.    74.  A class action is superior to other available methods for the fair and efficient  adjudication of the controversies herein in that:   a.  Individual claims by the Class members are impractical as the costs of   pursuit far exceed what any one individual Plaintiff has at stake;   b.  As a result, individual members of the Class have no interest in   prosecuting and controlling separate actions;  c.  It is desirable to concentrate litigation of the claims herein in this forum;   d.  The proposed Class action is manageable.   75.  Plaintiffs are not aware of any difficulties that will be encountered in the  management of this litigation which should preclude its maintenance as a class action.  76.  Plaintiffs repeat and re-allege the allegations contained in paragraphs 1-75, above,  as if fully set forth herein.   77.  Plaintiffs brings this cause of action on behalf of themselves and the members of  the Nationwide Class.   78.  Defendant is a “person” under 18 U.S.C. § 1961(3).    80.  Plaintiffs and Class members are “person[s] injured in his or her business or  property” by reason of Defendant’s violation of RICO within the meaning of 18 U.S.C. § 1964(c).   Violations of the Racketeer Influenced and Corrupt Organizations Act  (18 U.S.C. §1962(c))  On Behalf of the RICO Class  