11.  Plaintiffs purchased a single-family home in San Marcos, California, with  the transaction closing on or about October 19, 2018.   12.  At around the same time and in connection with their purchase, Plaintiffs  entered into a mortgage loan agreement with lender loanDepot.com, LLC (the “2018  Mortgage”).  That loan funded on or about October 18, 2018.   27.  Plaintiffs bring this lawsuit under Federal Rule of Civil Procedure 23(a),  (b)(1), (b)(2) and/or (b)(3) on behalf of themselves and as representatives of the  following class:  All borrowers on mortgage loans for a one- to four-family  residence located in California and maintained or serviced by  Nationstar (including its subsidiaries, successors, predecessors,  and other related entities) who paid money into an escrow  account for the purpose of paying taxes, insurance, or other costs  associated with the mortgaged property and did not receive  interest thereon.  The following persons and entities are excluded from the class: Nationstar and its officers,  directors, employees, subsidiaries, and affiliates; all judges assigned to this case and any  members of their immediate families or chambers staff; and the parties’ counsel in this  litigation. Plaintiffs reserve the right to modify, change, or expand the class definition  based upon discovery and further investigation.   28.  Numerosity.  The members of the class are so numerous that their  individual joinder is impracticable.  Nationstar is one of the country’s largest servicers of  residential mortgages, and the class includes at least thousands of members.     29.  Typicality.  Plaintiffs’ claims are typical of the claims of each class  member.  All class members have been subjected to Nationstar’s systematic and  unlawful failure to pay interest on escrowed funds and have sustained damages as a  result.   34.  Plaintiffs incorporate by reference and re-allege all paragraphs previously  alleged.   35.  The UCL prohibits acts of “unfair competition,” including any “unlawful  [or] unfair . . . business act or practice.”   36.  Due to Nationstar’s unlawful and unfair business acts or practices,  Plaintiffs, class members, and the public at large have suffered and continue to suffer  irreparable harm for which there is no adequate remedy at law.  Unlawful   37.  Nationstar is a “financial institution” as defined in Civil Code section  2954.8(c).   46.  Plaintiffs incorporate by reference and re-allege all paragraphs previously  alleged.   47.  Nationstar entered into binding mortgage loan agreements with Plaintiffs  and class members that require Nationstar to comply with applicable law, including state  laws requiring the payment of interest to borrowers on their escrowed funds.   48.  Plaintiff and class members fulfilled or substantially fulfilled all obligations  to Nationstar under the relevant mortgage loan agreements.   49.  Through its failure to pay interest to Plaintiffs and class members on their  escrowed sums, Nationstar breached its contractual obligation to them to comply with  applicable law, including state laws that require paying interest to borrowers on such  escrowed funds.  Nationstar’s nonpayment of interest violates section 2954.8 of the  California Civil Code.   50.  As a result of Nationstar’s breaches of contract, Plaintiffs and class members  have been harmed in an amount to be determined at trial.  A.  Plaintiffs’ Mortgage Loan Agreements   Breach of Contract   Violations of Cal. Bus. & Prof. Code § 17200 et seq. (“UCL”)  