Brad Rosa worked at UWM from February 2024 to December 2025 as an in-house counsel in the Title Review and Closure (TRAC) department, which employs approximately 40 attorneys. In her role, Rosa reviewed public land records and issued AOLs for general loans under UWM’s TRAC program.
The case was opened on Tuesday in court Superior Court of the State of California for the County of Orange.
Case details
Rosa suspects that this past fall, the TRAC AOL system was replaced by the TRAC+ Title Standing Letter (TSL) system. During the transition, “ghostwriting” — described in the complaint as preparing deed opinions that were then signed by attorneys licensed in the appropriate state — was common at the company.
Under the revised plan, AOLs were rebranded as TSLs, but “the substance and purpose of both remained the same,” according to the lawsuit. Rosa’s ties also remained unchanged. He issued legal examinations of the state of the title, identifying defects or “clouds,” and assessed whether a new loan would be a priority.
But solicitors have been informed that they will eventually be required to sign TSLs for premises in unlicensed areas. Concerns about the move were addressed in a 12-page document sent to management, as well as in an October meeting involving all TRAC attorneys and management, according to the complaint.
Rosa said that her own research shows that some states deal with this issue through laws, while others rely on moral opinions or case law.
In Texas – the state where he is accused of writing several letters – Rosa said the exception was only if legal services were provided only to the company or its officers. But TSLs are shared with real estate buyers to clear titles, which may fall outside that exception. Also, Rosa says she and others were not registered as in-house counsel since the work involved opinions on a specific topic, not Michigan or federal issues.
According to the complaint, UWM officially changed its policy in November to require corporate attorneys to sign TSLs for properties in states where they were not licensed. Lawyers who refuse to do so 10 times will refuse to be considered for resignation.
The new policy saw that signing these letters without a license was expressly prohibited in several states, including Alabama, Arizona, California, Florida, Kentucky, Louisiana, New Jersey, Ohio, Pennsylvania and South Dakota.
“The approximately twenty-seven remaining states where the program was in effect did not expressly prohibit the practice, but neither did they strictly approve it,” the complaint said.
Rosa says the policy change was prompted by a flood of nearly 20 ghostwritten files that lacked signatures on Nov. 28. She says she promised to sign the papers in California and Massachusetts, where she is licensed, and continue ghostwriting documents in other states, while making it clear she had no intention of resigning.
But according to the case, Rosa was terminated on December 3 when she received a phone call.
A UWM spokesperson said in a statement that the case “exemplifies the resistance that can exist when long-standing industry practices and large insurance companies are challenged.”
“Unfortunately, innovation often brings scrutiny,” the speaker said. “UWM will continue to focus on doing the right thing for consumers while defending its position in this case 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 also wants this case.
