LOS ANGELES - A lender's alleged failure to work with a customer in a mortgage forbearance agreement does not permit a California unfair competition law (UCL) action where the borrower cannot show a sufficient link between the conduct and foreclosure on his home, a state appeals court affirmed Feb. 7 (Marvin Baldwin v. Bank of America, N.A., No. B243789, Calif. App., 2nd Dist., Div. 4; 2014 Cal. App. Unpub. LEXIS 934).