Late last year, the country's bank regulators launched a massive program to evaluate millions of foreclosure cases and compensate homeowners who fell victim to the banks' flawed or illegal practices. Regulators dubbed it the "Independent Foreclosure Review" to emphasize that the banks would not be making key decisions about loans they had made or serviced.

But a raft of evidence -- internal Bank of America memos and emails obtained by ProPublica, interviews with two bank staff members who have worked on the review, and little-noticed documents released late last year by a federal banking regulator -- throw the independence of the review into serious doubt. Together, they indicate that Bank of America -- the financial giant with the largest number of homeowners eligible for the program -- is performing much of the work itself.

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