LOS ANGELES - Although it is too late for a homeowner to pursue a California unfair competition law (UCL) claim against a bank based on loan origination for a refinancing deal, the homeowner still may be able to adequately allege a violation of the UCL based on a dual tracking theory of the bank's foreclosure practices, a state appellate court held April 30 in reversing and remanding the trial court's grant of judgment on the pleadings to the bank (Anatoli Kouzine v. Countrywide Home Loans, Inc., et al., No. B249022, Calif. App., 2nd Dist., Div. 8; 2014 Cal. App. Unpub. LEXIS 3122).