Product: Mortgage

- Refinance application was originally submitted on XX/XX/XXXX and was intended as a cash-out, conventional, refinance [ subject to appraisal ] with the removal of PMI. 
- Credit was originally pulled on XX/XX/XXXX. 
- Conditional Approval was received on XX/XX/XXXX. 
- Property appraisal was requested on XX/XX/XXXX and Borrower was charged a standard {XXXX} appraisal fee. 
- Additional appraisal fee of {$150.00} was requested on XX/XX/XXXX. Interfirst stated that additional charge was because the property was waterfront, as fact of which was known in XXXX when the original fee was requested. 
- Final appraisal was provided to the Interfirst Underwriting team on XX/XX/XXXX. 
- Property did not appraise as Borrower expected ; Interfirst and Borrower agreed to continue process as a conventional refinance at a lower rate ( without cash-out ) so Borrower could capitalize on the removal of PMI and a lower rate. 
- Interfirst proceeded to work with secondary lien holder to subordinate a HELOC existing on the property. 
- At this time, Borrowers credit was pulled a second time due on XX/XX/XXXX. 
- Note : between Conditional Approval on XX/XX/XXXX and the second credit pull on XX/XX/XXXX, Borrower continued to proactively contact Interfirst to garner status updates and to ensure the file was moving forward appropriately. During this time, Loan Officers assigned to the file were changed a total of 3 times. All communication was via the Interfirst Portal and/or via email during this time. 
- Interfirst worked with insurance company to adjust lien holders through the month of XX/XX/XXXX. 
- Closing disclosures were received on XX/XX/XXXX. 
- Closing was scheduled for XX/XX/XXXX at XXXX EST [ Borrowers business trip was cut short to accommodate ]. 
- Notary arrived on XX/XX/XXXX with entirely different Closing Disclosures [ e.g. XX/XX/XXXX Closing Disclosures stated {XXXX} owes to Borrower at closing and an APR of 2.888 % where the New Closing Disclosures had Borrower owing {XXXX} at closing and an APR of 2.896 % ]. 
- Borrower refused to sign on XX/XX/XXXX until confusion was rectified. 
- Notarys company contacted Borrower to understand why the closing did not go ahead. They stated they only received the final numbers late the previous evening themselves. 
- Interfirst [ Retail Sales Manager ] emailed on XX/XX/XXXX [ PM ] stating that he had tried to provide final Closing Disclosures but was unable to contact. Note : this was the Borrowers first encounter with this individual and no phone call or email was received with revised Closing Disclosures after the receipt of the XX/XX/XXXX disclosures. Similarly, no revised Closing Disclosures were provided in the Interfirst portal, where all disclosures and documents were provided up until then. All communication to date was completed via the Interfirst Portal and via email with the assigned Loan Officer. 
- Borrower requested a call with the Retail Sales Manager to understand the disconnect ; Retail Sales Manager and Borrower agreed to discuss at XXXX EST on XX/XX/XXXX to accommodate Borrowers work schedule. 
- Phone call was not received until after the agreed-upon time on XX/XX/XXXX. No voicemail was left and no further contact has been attempted by Interfirst. 
- Receiving Closing Disclosures that are considered Final by an originator less than 3 days prior to the scheduled close date represents a violation of of the TILA-RESPA 3 day rule [ 1026.19 ( f ) ( 1 ) ( ii ) ) ]. 
- At this time, Borrower has waited ~5.5 months for a conventional refinance, had their credit pulled twice and has been unable to move forward with scheduled home improvement efforts while the process continues. 
- While Borrower has become accustomed to receiving a less than acceptable customer experience from Interfirst [ multiple Loan Officers, lack of responsiveness, a lack of basic professional etiquette in email correspondence, etc. ], this, coupled with the blatant and unapologetic violation of customer protection regulations has rendered this complaint necessary. 
- At the time of this complaint, the rate environment has changed considerably since Borrowers original application. 
- Borrowers ability to re-enter the market with an alternate provider at a rate competitive with that provided with their original application [ ~5 months ago ] is now non-existent. 
- Interfirsts inability to close this refinance within a reasonable timeframe and in a regulatorily compliant manner has resulted in both realized and future financial impacts to Borrower. 
- Borrower expects these impacts to be appropriately and proportionately mitigated by Interfirst.