Mealey's (December 18, 2018, 1:43 PM EST) -- PHILADELPHIA — A panel of the Third Circuit U.S. Court of Appeals on Dec. 13 held that a district court improperly relied on a permanent modification under the Home Affordable Modification Program (HAMP) when deciding to dismiss a breach of contract claim asserted by borrowers, reversing dismissal of the claim in favor of a bank (Stephen Bukowski, et al. v. Wells Fargo Bank, N.A., et al., No. 17-3253, 3rd Cir., 2018 U.S. App. LEXIS 35034)....