Product: Mortgage

I submitted a hardship application to Selene Finance, LP ( " Selene '' ) on XX/XX/2022. By that date, I had been approved in writing as a successor-in-interest on the primary mortgage on my home that was being serviced by Selene, which such home and mortgage were the subject of the above hardship application. After submission of this hardship application, Selene sent a letter to borrower and me providing that XXXX XXXX was designated by Selene as the single point of contact for our loan that they were servicing.

Selene did not complete its review of our hardship application within 30 days and did not notify me in writing of its decision within 30 days, despite confirming to me on three ( 3 ) different occasions that Selene had received all documents it requested with respect to this hardship application. The first such confirmation was on XX/XX/2022 in a phone conversation I had with XXXX from Selene 's Customer Service department ; the second confirmation was on XX/XX/2022 in a phone conversation I had with XXXX XXXX of Selene 's Loss Resolution/Mitigation department wherein XXXX XXXX confirmed all requested documents were submitted to Selene and therefore he was requesting Selene underwriting to move my application " to the next step '' ; and the third confirmation was on XX/XX/2022 in another phone conversation I had with XXXX XXXX XXXX wherein XXXX XXXX informed me that there was no response yet from underwriting, so he resubmitted his request to move my application forward. 

Accordingly, on XX/XX/2022, I called Selene Customer Service and was told XXXX XXXX was busy and unavailable to speak with me, so I left a detailed message for XXXX XXXX to call me back at XXXX. Having not heard from XXXX XXXX, I placed two more phone calls to Selene Customer Service on XX/XX/2022, and was told XXXX XXXX was busy and unavailable to speak with me, so I left a detailed message for XXXX XXXX to call me back at my mobile number ( which I confirmed to the Selene employee taking the message ). Having still not heard from XXXX XXXX, I placed another phone call to Selene Customer Service on XX/XX/2022, and was told XXXX XXXX was busy and unavailable to speak with me, so I left yet another detailed message for XXXX XXXX to call me back at my mobile phone number. Having STILL not heard from XXXX XXXX, I placed two more phone calls to Selene Customer Service on XX/XX/2022, and was told XXXX XXXX was busy and unavailable to speak with me, so I left a detailed message for XXXX XXXX to call me back at my mobile phone number. 

Then later in the month of XX/XX/2022, XXXX XXXX sent a two-page letter to me and the borrower, that failed to acknowledge and ignored each of the six ( 6 ) phone calls and six ( 6 ) messages I left for him. However, XXXX XXXX proceeded to wrongfully deny our hardship application submitted to Selene on XX/XX/XXXX. XXXX  on the ground that " Borrower failed to return completed Financial Workout Package and Supporting Documentation. '' This is complete hypocrisy given the two phone calls XXXX XXXX conducted with me on XX/XX/2022 and XX/XX/2022, wherein he confirmed to me that Selene did in fact have all documents necessary to support our hardship application and that XXXX XXXX was recommending to move our application forward to the next step. 

Moreover, each of my conversations with Selene employees described above were recorded by Selene. I placed Selene on notice in writing to preserve for any and all future litigation each of the above recorded conversations. 

XXXX XXXX never stated that any additional documents were necessary to complete the application, which Selene would have been required to request before denying the application on the ground of failure to submit completed application. See 12 CFR Section 1024.41 - Loss Mitigation Procedures. Selene and XXXX XXXX failed to exercise reasonable diligence to obtain documents and information from me/borrower that Selene required to evaluate me as to all loss mitigation options available to me. Selene failed to identify any stale or invalid document that needed to be updated pursuant to 12 CFR Section 1024.41 ( b ) ( 2 ). Selene failed to promptly request additional information or corrected document ( s ) after each conversation with me on XX/XX/XXXX, XX/XX/XXXX and XX/XX/XXXX pursuant to its reasonable diligence obligation. 

Furthermore, Selene failed to contact borrower before the end of the Covid-19 forbearance period to work with borrower on all available options to avoid foreclosure. Selene failed to offer either borrower or me a trial plan to make payments on the Loan, which if successfully made would institute a loan modification to bring the Loan current ( and out of foreclosure ). Selene failed to work with either borrower or me regarding all options available to help me avoid losing my home through foreclosure. 

On XX/XX/2022, I sent by Priority Mail to Selene, Qualified Written Requests identifying the above errors and applications. Selene failed to acknowledge receipt of these Qualified Written Requests and failed to act on them. I tracked this Priority Mail package and confirmed it was received by Selene. Selene has continued to fail to correct any of the above-described notices of error and simply ignores all of my communications to it.