Product: Mortgage

Around roughly XXXX XXXX XXXX I went under contract for the purchase of a home in XXXX, XXXX  and began my search for the best rate by finding an appropriate mortgage broker. I came across Groves Capital and decided to reach out for a rate. I was contacted by XXXX XXXX XXXX) (XXXX XXXX Loan Originator License: XXXX). Upon speaking to XXXX I explained that I was seeking to purchase a home in Tennessee. I explained that the purchase was for a property originally listed for XXXX XXXX but that I had been able to reduce the price to XXXX with XXXX in seller credits ($XXXX). She assured me that Groves Capital and herself were licensed in Tennessee so she would be able to get us the best rates for this transaction as she had an expansive network of banks she could reach out to for the best rates. I saw her emailed noted We are licensed in: AR, AZ, CA, CO, FL, HI, IA, ID, IL, MD, MI, NJ, OH, OR, PA, SC, TN, TX, VA, WA, WY. Pending Licenses in:  LA, MN, NC, NV, IN. However, I also noted that her email noted that they were in the Top 1% of brokers, fastest growing loan officers, and featured on several news articles such as XXXX and XXXX XXXX XXXX as well as XXXX XXXX However, I noted the email also stated that they had an A+ rating on the XXXX but they were not XXXX rated when clicking on the link and had a 3 out of 5 star rating. 

I let her know that I wanted to use the seller credits to pay for the closings costs and to buy down the rate and asked for a temporary buy down such as a 3-2-1 buydown. She stated no lender offered temporary buydowns such as a 3-2-1 buydown for this type of loan at this price point but that I could do a permanent buydown and reduce the interest rate as much as I wanted to given that I would have roughly XXXX XXXX left over after closing costs. I let her know we could do that as it would essentially reduce my rate a couple of percentage points and allow me to keep the mortgage for longer. She let me know that it was a mathematical equation to reduce the rate by a certain amount and we would just do so at the closing once we had all the lender fees - essentially we would just apply these left over credits to the interest rate at the closing table. Subsequently, she asked me to submit an application and get a credit report and discussed some rates she had received and sent me a quote via email for 8.35% or 7.75% with roughly XXXX in points buydown and a 15% down payment. I noticed her email stated The rate CANNOT be locked until we have an appraisal and initial underwriting approval from lender. Initially, this later disclaimer was concerning as I was aware rates can be locked even before receiving the loan estimate and do not require an appraisal or initial underwriting approval. However, I decided to disregard this and proceed in good faith.
 
Subsequently, I got in contact with her and she advised me the rates had increased dramatically. She advised me that rates were now at almost 9% for a 15% down payment mortgage and advised in getting a mortgage at 20% down payment which would bring the rates back down to the 7.75% range with no points. I let her know that I did not have 20% available for this property which would be roughly XXXX She asked if I had any other properties and I let her know I had an apartment that was currently rented and the home I was living at. She asked whether these had any equity and I let her know they should. She advised me to take out a HELOC on a property in order to have more cash available for a down payment which would reduce my mortgage rate and subsequently refinance a few years down the road once I had gained some equity. She sent me a quote for this via email which was at 9.8% with XXXX points cost for a XXXX of XXXX  She explained that the overall payment would actually be lower if I took this out as it would reduce the main rate for the larger mortgage and stated that her lender was perfectly fine with taking out a XXXX and using that for a down payment. I let her know that that was a good idea and I would consider it.
 
After considering this, I reached out to her and let her know we could proceed as she had advised and to please send the Loan Estimates for both the mortgage and the XXXX. She let me know that she was out of the office and would do so when she had a chance. She sent me a link on XXXX XXXX XXXX  XXXXo send her all of my documents such as my income and identity documents. On XXXX XXXX XXXX I reached out again regarding the loan and was advised that rates had gone up again and that the XXXX she was offering was now roughly from 10.75% to 13.375%. On XXXX XXXX XXXX she advised me via email she was trying to get a lock at 13.375% and that there would be fees such as appraisal and title fees but that she could not receive an estimate. I told her that I would be flying to Tennessee for the property inspection but to please send me the loan estimates for the mortgage and XXXX. Once I landed, I again asked for them and she wrote me via email that they had not made the loan estimates yet and that they had three days to make them but she had locked the rate. I asked to please be sent all numbers so I could be sure about the fees and especially in regards to the mortgage, which I had been told that they could beat 7.75% if I went with them. By the end of the day, I still had not received any official documents and grew worried about the rate as I was now paying 7.75% for a 20% mortgage instead of a 15% mortgage and having to take a HELOC to cover this expense and I did not want rates to jump again on me. I decided to call XXXX  who let me know that she had the rate locked at 7.625% and sent me a snipping of the lock and stated that XXXX would honor it in their loan estimate but that they were doing a manual lock so it was taking longer to send the loan estimate but assured me not to worry. She sent me several snippings and emails confirming that we were good to go and things would not change including forwarding an email from XXXX  saying the rate was locked.

On XXXX XXXX XXXX, she let me know that the rate had now gone up to 7.75% and that they still could not send the Loan Estimate but sent me a Loan Estimate draft. I complained about the rate going up despite being told it was locked at 7.625% and she scheduled a call with XXXX XXXX of XXXX who let me know the issue was that the rate had been manually locked and that the system did not process it and that now the rate was 7.75%. I explained that I had relied on the lower rate to go with them but to please proceed without any other surprises as I wanted this deal to go through without a problem. I was assured I would receive no new surprises and that they would honor the new 7.75% rate without any new surprises. XXXX also sent me a Loan Estimate from XXXX XXXX for a HELOC at 12.625% for a XXXX  of XXXXXXXX   with origination fees to Groves Capital of XXXXXXXX (2%). I complained to her about additional origination fees by Groves Capital when she had advised a HELOC to reduce costs and they were already being paid roughly XXXX dollars for the mortgage and she said she might be able to reduce it to 1% if the HELOC was for a lower amount. 

At this point, I felt that an increase from the initially quoted 9.8% for the HELOC to now a 12.625% with XXXX  in origination costs combined with the frequent changes in rate, inability to receive loan estimates, and increase in rate on the mortgage to buy the property itself was abusive and I had to find an alternative at least for the HELOC itself. I decided to submit my application with various lenders and was able to receive a HELOC for roughly 10% interest and only roughly XXXX in costs. A few days later I let XXXX know I had found another lender for the HELOC and would proceed in that manner. 

Things settled down but now I was a little cautious about how things were going. I proceeded with the lending and was subsequently told by XXXX that the underwriting was going through without any issues and that I had been conditionally approved by XXXX She stated that my income was more than enough for the property and that I had a XXXX of only 17% and we were qualified up to at least 43% XXXX. She stated we were essentially only waiting for the appraisal in order to be able to close. 

I was relieved and allowed roughly a week to pass before looking at things further. However, now that I had seen a few red flags from Groves Capital, XXXX, and XXXX I decided to look into the cost of buying down the rate. I communicated with XXXX regarding increased title costs roughly $4,000 over what was in the loan estimate by the title company. I also discussed the rate buy down and was assured against this would be done at the closing table, would be left to the very end given how the closing costs may change, and that it was a mathematical equation of prepaid interest that every lender charges as you are essentially just prepaying your interest up front. However, roughly around XXXX XXXX XXXX,  I began doing research regarding the rates and began scrolling through XXXX when I found out that buying down the interest rate was not a mathematical equation as I had been told and should not be left to the closing table. In contrast to what XXXX  had told me, lenders can charge any amount they deem fit to buy down the rate as this is not regulated. Moreover, if you do not use the seller credits for closing costs, the seller credits will be returned to the seller. Having found this out, I became hysterical as I would essentially be in a position to lose the roughly XXXX  dollars by it being returned to the seller. Now several weeks had passed and I was unsure if I would be able to get a new lender. Moreover, I had successfully filled my application for a HELOC for roughly XXXX to be able to increase my down payment as suggested by XXXX  and would be in a terrible position if I did not acquire the property. Knowing this, I decided to reach out to XXXX  to send me a rate sheet to be able to calculate how much I would be charged to buy down the interest rate. 

On XXXX XXXX XXXX  I reached out to XXXX to receive a rate sheet to be able to calculate the interest rate. She told me that she had reached out to XXXX to receive this but that it would take several days to receive as they did not have rate sheets readily available. I felt this was not honest as I was able to pull up rate sheets immediately with several lenders online including XXXX XXXXXXXX XXXX XXXX  and several other lenders I had researched. I decided to give them several days and kept following up to see when I could receive this. However, despite reaching out several times, they would not send a rate sheet or any documentation regarding how much it would cost to reduce the rate with the remaining seller credits. I kept reaching out to XXXX and she kept telling me she could not rush the lender. I told her I was worried that the lender would have another surprise after everything that had happened before and that I needed and official document from them showing what it would cost to buy down the rate. She kept delaying and would not offer me any information regarding how much it would cost. I let her know that I was in a rush as several weeks had passed and the more time progressed the less option I would have with other lenders. However, I could not get any further information to resolve this matter. 

Around XXXX XXXX XXXXXXXX XXXX  let me know that XXXX  would be asking for roughly XXXX  dollars to reduce the rate by 1.25% from 7.75% to 6.5%. I began to investigate whether this amount was a reasonable amount to charge to reduce the price by 1.25% and received several instant quotes from several other lenders including XXXX XXXX XXXX XXXX XXXX Both these lenders quoted only around XXXX dollars to reduce the rate by 1.25% under the same mortgage program - essentially makinXXXX XXXX XXXX  XXXX quote 300% that of any other lender for reducing the price only 1.25%. At this point, I became hysterical regarding this issue as I had had several bait and switch tactics pulled throughout this whole process with this broker and lender. Now, XXXX  and XXXX were essentially letting me know that unless I paid $XXXX to reduce the price only 1.25%, I would either have to pay them that or the excess of XXXX  dollars in seller credits would be returned to the seller. I communicated with XXXX that we would have to find another lender as we had wasted several weeks working with XXXX and that I had been concerned and voiced my concerns regarding their several bait and switch tactics since we had began working with them. However, XXXX insisted there were no other lenders that could help us and that we should not let go oXXXX XXXX as my income had been approved by them and we were almost all set to close. I began reaching out to other lenders and let her know that XXXX XXXX and XXXX XXXX offered a much more reasonable cost to reduce the rate and that XXXX XXXX even offered a 3-2-1 Buydown option which would be much more beneficial as if I refinanced within 3 years, I would be credited back any unused amount of the seller credits. I referred her to them and let her know I had been quoted at 7.75% with no points. I told her I wanted to give her another chance but to please not let me down and she ensured me she would work with these other lenders to get me the best rate and close on time - she let me know by the next day I would receive my new Loan Estimates from these lenders. I had already began the process with XXXX XXXX and XXXX XXXX and had received quotes at 7.75% with reasonable buy down options and she would only have to continue the process. At this point, I did not know whether I could fully trust her or if the lender was the point of issue, I referred her to XXXX XXXX and XXXX XXXX to get alternative lending but I had also reached out to XXXX and decided to keep this to myself to see if she was the cause of the issue of if it was only the lender. 

Within one day of being referred to XXXX XXXX and XXXX XXXX by the very next day of XXXX discussing anything with them, my rate had now increased from these lenders from 7.75% to roughly 8.375%. XXXX  also provided me a Loan Estimate stating it was from XXXX XXXX but I now noticed that the points cost had increased from roughly XXXX XXXX XXXX XXXXo work with XXXXXXXX XXXX instead of XXXX. This was in stark contrast from the quote I had received directly from XXXX XXXX the day prior at 7.75% with no points costs. Moreover, I noticed that the lender on the Loan Estimate stated it was from Groves Capital Inc. with a Tennessee NMLS license of XXXX as the lender instead of XXXX XXXXe and it did not contain any information regarding the Mortgage Broker. I was not only surprised that my rate and points had gone up just one day after letting XXXX  know to pursue this alternate lender, but was also surprised how the Loan Estimate was drafted. I decided to look at this Loan Estimate and compare it to the previous one received from XXXX. I saw that XXXX had been listed as the lender on their Loan Estimate and that the Mortgage Broker as Groves Capital Inc. XXXX License XXXX and XXXX License XXXX and the Loan Officer as XXXX XXXX XXXX License XXXX  and Tennessee License XXXX In no way, shape, or form was XXXX XXXX listed in any of the disclosures. I had not met or ever heard of XXXX XXXX  Moreover, it seemed that XXXX XXXX  was using his Tennessee license to process this mortgage. Moreover, it also seemed like Groves Capital was citing XXXX XXXX license as well as their XXXX License. When I then compared the Loan Estimate I had received when XXXX XXXX quoted the XXXX by XXXX XXXX at 12.625% and roughly XXXX  in points, I also noted this was a Loan Estimate for Florida as the property was located in Florida but again XXXX XXXX  was not mentioned in any part of the disclosure. Instead, XXXX XXXX was again noted to be the Mortgage Officer as follows: LOAN OFFICER XXXX XXXX XXXX XXXX LICENSE ID XXXX. In this case, Groves Capital used a separate license instead of XXXX XXXX in contrast to how they had drafted the Tennessee Loan Estimate as follows: MORTGAGE BROKER Groves Capital, Inc. XXXX LICENSE ID XXXX  

When I discovered thaXXXX XXXX XXXX had notified XXXX other lenders, and brokers that I was seeking new financing options, it was clear that she had communicated with other parties involved in the transaction, which negatively impacted my interests. I had already noticed several red flags and decided not to pay an exorbitant fee of XXXX  to lower the interest rate, choosing instead to find another lender. I referred XXXX XXXX  to two online lenders, but after she spoke to them, they suddenly found issues with my income and refused to extend credit. Not deterred, I approached another lender on my own, who conditionally approved me swiftly, signifying that I could have closed on the property.

However, once XXXX XXXX learned that another lender might be involved, she told the listing agent that I wouldn't qualify due to supposed income issues. This unwarranted interference weakened my bargaining position considerably. Following her remarks, the seller's agent came back to me to renegotiate the purchase price by approximately XXXX threatening not to close on the property unless I stuck with the original lender and adhered to the initial closing date. This put me in a precarious situation, limiting my financing options, binding me to the original lender, and putting my XXXX XXXXn escrow at risk.

After refusing to pay the fee to buy down the rate, I began encountering problems with XXXX, the lender I was conditionally approved with. They suddenly became unable to verify my income, claiming it was declining and that I'd need to pay a higher rate. I clarified that my income had been consistent, with an increase in the last quarter. Despite this, XXXX  changed their requirements, asking for a XXXX and then for bank statements, including sensitive business information.

I fulfilled over 25 conditions set forth by XXXX XXXX anXXXX XXXX who continued to request more documentation. Even after being told I had met all conditions and just awaited the final investor signature, nothing progressed. I repeatedly requested the closing disclosure to meet the deadline, concerned that these delays were a ploy to let the rate lock expire and incur higher fees.

The night before closing, XXXX and XXXX  sent me a counteroffer: I was denied the initial loan product but approved for another, which would now cost me an additional XXXX for the same rate, with the possibility of more conditions. This came after I had repeatedly sought updates and expressed concerns that this delay might be a strategy to justify higher fees.

In the end, I was left with a stark choice: either accept the increased fees or risk losing my XXXX escrow deposit. This was because I couldn't officially claim that the financing contingency hadn't been met without a formal denial, which they refused to provide. It was a concerted effort to delay the closing, avoid providing disclosures or formal denials, and ultimately, it seemed they intended to charge me higher fees under pressure. XXXX counteroffer required additional payments and higher rates, raising suspicion of intentional delay and a bait and switch tactic. These actions seem clearly in conflict with regulations protecting consumers. 

I was forced to back out of the deal. Even then, XXXX and XXXX  refused to issue me a formal denial letter so that I would not be able to get back my XXXX XXXXn escrow payment. THE HOME WENT BACK ON THE MARKET AND SOLD FOR XXXX MORE THAN I HAD IT UNDER CONTRACT FOR. THIS CAUSED ME A TREMENDOUS FINANCIAL LOSS. I AM SEEKING YOUR HELP IN HOLDING THESE PEOPLE ACCOUNTABLE FOR THEIR CLEAR VIOLATIONS. 



FACTS:
Introduction of Parties:
Complainant: XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXXl, with a distinguished career in financial law.
Respondent: XXXX XXXX, a mortgage broker affiliated with Grove Capital and XXXX, falsely claiming to be licensed in Tennessee at the time of initiating the transaction.
The Contract and Negotiation:
	XXXX XXXX  secured a purchase contract for a home, reducing the price from XXXX XXXX XXXX XXXX XXXX negotiating 6% in Seller Credits, bringing the net to approximately XXXX XXXX.
	XXXX XXXX engaged XXXX XXXX  services as a mortgage broker to find a suitable lender. XXXX misled XXXX XXXX by claiming she was licensed in Tennessee and qualified to handle the deal.
Licensing Irregularities and Misrepresentation:
	XXXX XXXX falsely stated her licensing in XXXX, despite being only licensed in XXXX as of XXXX. After several weeks and several red flags, the complainant reviewed his disclosures and found out that XXXX XXXX was not licensed in Tennessee but rather was using a colleagues license, XXXX XXXX, who the complainant never met or spoke to and who was listed on the Loan Estimate and Disclosures. 
	Investigations into Grove Capital revealed licensing suspension in California due to non-payment of dues (subsequently, re-instated) and permanent revocation in Georgia due to providing false statements.
	The loan estimate did not mention XXXX but rather XXXX XXXX  an unknown party to XXXX XXXX
	Even the lender selected by XXXX XXXX XXXX, seems to have a questionable background. Investigation into the Loan Processor at XXXX, XXXX XXXX shows his license and ability to work in the mortgage industry was suspended for 5 years in XXXX state for working without a license. 
Seller Credits & Rate Buy-Down Misconduct:
	Initially, the complainant informed XXXX XXXX that he had gone into contract for the purchase of the property with 6% seller credits which were essential to use to buy down the rate given the current high interest rates. XXXX XXXX  stated this would not be an issue. Upon getting an initial quote, XXXX XXXX let the complainant know that he was locked at 7.625% with no points. After repeatedly requesting the Loan Estimate, the complainant was told that he would not receive it until the 3 day mandatory deadline but that he should not worry because the rate was locked. However, upon receiving the Loan Estimate, the rate was now 7.75%. The complainant was contacted by XXXX XXXX XXXXnd XXXX XXXX of XXXX who let the customer know it was an issue due to a manual lock procedure and could not be honored at the lower rate but this would not happen again. This was one of the first red flags noticed by the complainant. XXXX XXXX misled XXXX XXXX about the ability to use seller credits to buy down the rate, both in writing and verbally. She initially advised the complainant that buy down the rate was a mathematical equation for prepaid interest and would be the same charge by all lenders. She stated this could be left until the closing after all closing fees were accurately specified by the title company  applying the left over seller credit to the rate buy down. 
	After several red flags, the complainant decided to request a rate sheet to assess the exact cost of buying down the rate. He was not provided this for several days. Once provided, XXXX provided an outrageous quote of XXXX  to buy down the rate, roughly 300% of the market standard, against XXXX XXXX clearly stated intention in the contract. The complainant verified this previously undisclosed amount was exaggerated by receiving two quotes from two other lenders who quoted roughlXXXX XXXX for the same buy down amount offered by XXXX for XXXX. 
HELOC & Interest Rate Misguidance:
	XXXX  repeatedly proposed a second mortgage or HELOC with over 12% interest rates, despite XXXX XXXX  concerns over the increasing debt burden. The complainant was advised this would be the only real way to obtain the primary loan as it would allow the complainant to put down a down payment of 20% and lower the interest rate from almost 10% for the primary loan. He was assured this would not affect the ability to secure the primary loan regarding income and that the lender had approved this transaction for the primary mortgage on the new property and did not care about the borrower obtain such a loan. XXXX XXXX XXXXecured a XXXX at 10% interest rate for roughly $XXXX dollars after XXXX  persistent misguidance, expressing concerns over her increasing interest rates.
Confidentiality Breach & Interference: XXXX communicated with other parties, such as the listing agent and other lenders, damaging XXXX XXXX  interests. After the complainant began seeing many red flags and was asked for XXXX  dollars to buy down the rate, the complainant decided to seek financing from another lender. The complainant referred XXXX  to two lenders he had found online. However, despite being conditionally approved with XXXX without income issues to that point, after speaking to XXXXXXXX, those two lenders found issues with the complainants income and would not extend credit. The complainant decided to reach out to one lender independently to see if he alternative financing was possible with XXXX interference. This lender quickly conditionally approved the complainant and would have been able to close on the property. However, once XXXX  learned of the competing lender when contacted by the listing agent arranging the new lenders appraisal, she informed the listing agent that the complainant would not be able to qualify due to income and had several issues with his financing. 
	Evidence of this includes statements from the listing agent and possible texts from XXXX highlighting a clear breach of confidentiality.
	This interference affected the negotiation and financial aspects of the transaction, as XXXXs comments to XXXX  led to a weakened bargaining position for XXXX XXXX Subsequent to XXXX  statements, the sellers agent communicated with the complainant and asked to renegotiate roughly XXXX XXXXXXXX that had been reduced from the purchase price of the property or the seller would not close on the property. The seller insisted he would not extend the closing date due to XXXX comments and would decline the deal should the complainant not proceed with the original lender and meet the original closing date. This caused great harm to the complainant as it limited his financing options with the new lender, limited his time to be able to secure financing, bound the complainant to the original lender, and put the complainants XXXX in escrow at risk if he made any misstep until closing. 
Replacement Cost Estimator (RCE) Request:
	XXXX XXXXs request for an RCE raises questions about her awareness of Florida's legal regulations. XXXX repeatedly asked for a RCE despite being informed by the complainant that the insurance company could not provide one as he was a Florida resident and Florida law made it illegal for a lender to ask for an RCE or condition the loan on receiving an RCE. XXXX  responded stating she knew of the law but if the complainant would not provide it, he would have to increase his insurance almost by three-fold.
	Her response indicates knowledge of Florida's legal changes, proposing options for the loan amount or insurance agent collaboration to meet agency guidelines. This occurred despite the recent change in XXXX XXXX XXXX XXXX XXXX - Solicitation of Replacement Cost Estimators and Other Proprietary Information - pp. 3435, 626.9551, F.S. -Prohibits a person (or entity) from requiring an insurance agent or agency to provide the replacement cost estimator (RCE) or other proprietary underwriting information of an insurer as a condition precedent to or subsequent to lending money or extension of credit secured by real property. The bill also prohibits an insurance agent or agency from providing such information.
Loan Program Switch & Additional Fees:
	The original loan program was a 7.75% loan on 80% of XXXX loan amount, with no discount points and a 1% mortgage broker compensation fee. XXXX XXXX and XXXX  initially promised 7.625% rate and sent documentation that this rate was locked, which later changed to 7.75%.
	The issue escalated with various miscommunications and delays, leading to a sudden change in the loan program.
	Despite being conditionally approved for several weeks, once the complainant refused to pay XXXX  dollars to buy down the interest rate and after XXXX  closed the alternative lending options, the complainant began having issues with XXXX. Suddenly, they were unable to verify his income. Initially, the complainant was advised that he had declining income and as such he would have to receive and exception and pay a higher rate. However, the complainant explained that the last 3 quarters his income had been roughly the same with an increase the last quarter. Nonetheless, the complainant was advised that bank statements may not be used to verify his income now and he would have to submit a XXXX which would be used to verify income. The complainant submitted a XXXX provided by his accountant. However, the issues continued. XXXX continued asking for bank statements and documentation regarding the bank statements including confidential and proprietary business information. XXXX  continued asking for conditions to be met which totaled over 25 conditions. Despite this, the complainant was assured that he had now met all conditions, had been signed off and cleared by underwriting, and that all that was left was the final investor signature. This was roughly 3-4 days before the closing and the complainant repeatedly asked for the closing disclosure in order to meet the closing deadline and explaining that the closing date could not be extended due to the issues caused by XXXX disclosures to the listing agent. Despite this and the complainants statements he was worried about this being a delay to allow the lock rate to expire, the complainant was assured final signature would be received by the investor and he would be approved. XXXX XXXX XXXX and XXXX still refused to send out any disclosures. They also communicated with the title company asking for 100% XXXX disclosures and various other documents with terms not previously agreed upon. However, the complainant was still assured the final step was investor signature and the property would close. He was subsequently assured the investor had signed off and approved the loan  however, everyone went silent and would not respond to the complainant. Nonetheless, the night before the closing, the complainant received a counteroffer from XXXX and XXXX stating that he had been denied for the initial product but approved for another one and if he wanted to proceed it would now cost him roughly XXXX XXXXor the same rate and he still had to meet some conditions and other conditions may arise. This was despite the complainant repeatedly emailing both XXXX XXXX XXXX, and Groves Capital requesting updates and stating that he hoped this was not a tactic to delay the closing to charge higher fees. Nonetheless, these entities and individuals conspired to delay the closing, not provide disclosures, not provide any forma denials, and delay the closing to such an extent despite previously assuring approval such that they would be able to charge higher fees. Moreover, they refused to send a formal denial letter to the complainant leaving it clear that the complainant could either 1. Accept the increased fees or 2. Lose his $XXXX  escrow deposit as he c