Product: Mortgage

Borrower procured the loan for an amount of XXXX [ XXXX XXXX Dollars ] through XXXX XXXX XXXX XXXX XXXX, located at XXXX XXXX XXXX, # XXXX XXXX, NJ XXXX and subsequently this loan was bought by Wells Fargo Bank who is the current Lender. This is a 10 year period loan ending on XX/XX/XXXX. 

The current outstanding balance as of XX/XX/XXXX is US Dollar XXXX XXXX XXXX XXXX XXXX XXXX XXXX and XXXX cents only ] after making the XX/XX/XXXX payment. Please refer to Exhibit A Mortgage Statement summary as of XX/XX/XXXX. 

The monthly payment for the above loan is XXXX which I have been paying on a regular basis without fail. Pursuant to Mortgage terms and conditions, Petitioner is responsible for making the payment towards the Property Tax and Home owners Insurance. The Property Tax for the year XXXX is paid in full and a valid current Home owners Insurance Policy is in effect. 

There was a lapse in the Insurance coverage from XX/XX/XXXX to XX/XX/XXXX [ roughly 8 months ] caused by the cancellation from the Service Providers end. This was not intentional from the borrowers side, caused by the stringent policies and procedures adapted by Insurance providers throughout XXXX Florida in view of the wide spread claims caused by hurricanes in the past. 

Pursuant to the letter received from the Wells Fargo Bank dated XX/XX/XXXX - Exhibit B, Petitioner managed to secure Home Owners Insurance Policy from XXXX XXXX XXXX XXXX, Policy Number XXXX and provided the proof of Insurance to Wells Fargo Bank on XX/XX/XXXX. A copy of the Proof of Insurance is attached herewith and shown as Exhibit C. 

Borrower managed to procure the Home Owners Insurance Policy based on the 4 Point Inspection Report and the Permit approval for the partial roof repairing job from the XXXX XXXX XXXX Department dated XX/XX/XXXX. A Copy of the Permit approval from the XXXX XXXX XXXX Department Permit Number # XXXX, Exhibit D, is attached herewith which clearly proves the details regarding the job including the Cost which is self-explanatory. 

Borrower received another letter from Wells Fargo Bank dated XX/XX/XXXX demanding proof of Insurance from the Service provider for the lapsed period, i.e. from XX/XX/XXXX to XX/XX/XXXX and the failure to provide proof of Insurance may result in charging an amount of {$3100.00} to my Mortgage account. A copy of the same is attached herewith and shown as Exhibit E. 

As I understood from my Insurance Provider it is not possible to purchase an Insurance Coverage for an earlier period in the State of Florida. 

Borrower received another letter from Wells Fargo Bank dated XX/XX/XXXX demanding proof of Insurance from the Service provider for the lapsed period which is attached herewith and shown as Exhibit F. 

Borrower repeatedly objected to Lenders intention to unilaterally enforce the Lender placed insurance for the lapsed period from XX/XX/XXXX to XX/XX/XXXX while the Borrower did manage to procure the Insurance and initiated the Roof repairing job at Borrowers own expense. Attached herewith is a copy of the letter provided by the Borrower which is self explanatory and shown as Exhibit G. 

On XX/XX/XXXX, Borrower demanded the Payoff statement and till date [ XX/XX/XXXX ] didnt receive any response from the Lender. A copy of the same is attached herewith and shown as Exhibit H. 

Borrower received another letter from Wells Fargo Bank dated XX/XX/XXXX in response to the Payoff statement requested by the Borrower. Copy of the same is attached herewith and shown as Exhibit I. 

Petitioner noticed various irregularities and discrepancies in the letters dated XX/XX/XXXX, XX/XX/XXXX and the final letter dated XX/XX/XXXX regarding the lapsed period and the Lender placed Insurance Premium amount the lender is planning to enforce with effect from XX/XX/XXXX onwards. 

Under the pretext of lapsed period XXXX XX/XX/XXXX to XX/XX/XXXX XXXX Lender is engaged in a covert attempt in unilaterally enforcing additional principal amount to my existing balance and thereby intending to cause an additional burden of {$3100.00} to the Borrower which is clearly evident from the above 3 letters. 

Lender is totally reluctant in providing a Payoff Statement and intending to prolong this process indefinitely. 

The outstanding Mortgage balance as of XX/XX/XXXX is US Dollar XXXX [ XXXX XXXX XXXX XXXX XXXX and XXXX cents only ]. Please refer to Exhibit A Mortgage Statement Summary as of XX/XX/XXXX Borrower managed to procure the partial Roof repairing job Permit during the Lapsed period at my own expense which is amounting to XXXX Dollars. 

Under the above circumstance Borrower is not agreeing to pay any additional amount as coverage for the lapsed period and being an individual, I do not enter into a legal dispute with the Lender or the Insurance Service provider. 

An abstract of the Mortgage Note signed by the Borrower is attached herewith and shown as Exhibit I. 

Receipt for the Property Tax paid by the Borrower for the year XXXX is shown as Exhibit J.