Consumer complaint received 2020-10-28
Company: WELLS FARGO & COMPANY
State: MI
Product: Student loan
Sub-product: Private student loan
Issue: Struggling to repay your loan
Sub-issue: Can't temporarily delay making payments

Complaint:
Wells Fargo responded to complaint XXXX stating that the periods beyond the terms as outlined in the original MPN for my private student loan were under their " payment deferral '' program. In complaint XXXX I stated that no such " payment deferral '' program was disclosed to me and that my understanding was that all prior granted forbearance were cited as granting in-school forbearance. 

Wells Fargo 's own documentation agrees with my my assertions as their communication with me dated XXXX XX/XX/XXXX with a subject " Forbearance Processed '' informs me to see the attached " Forbearance Summary Statement '' for specifics regarding the forbearance. The Wells Fargo Forbearance Summary Statement identifies the account number and loan number I am disputing and lists the " Forbearance Type '' as " In School. '' Furthermore, Wells Fargo identifies their relief for the SARS-CoV-2 pandemic as " payment deferral. '' Finally, WF response to XXXX does not list any relief available for COVID-19 and instead lists provisions for relief due to declare disasters.

Now WF insists that I used up the maximum forbearance time, yet a forbearance was granted beginning XX/XX/XXXX thru XX/XX/XXXX. This implies that every other period past the maximum forbearance time, but prior to the forbearance granted beginning XX/XX/XXXX per the XXXX XX/XX/XXXX communication was an in-school forbearance request as well. What this implies is that XXXX is using the " maximum forbearance time '' provision to shield their actuarial decision to try and force me into immediate repayment using adverse credit reporting as leverage. With the WHO not declaring the SARS-CoV-2 outbreak as a pandemic until XXXX XX/XX/XXXX, it seems all but certain that WF was more than willing to grant an in-school forbearance request when SARS-CoV-2 was not perceived as a serious issue, but by XXXX XX/XX/XXXX that viewpoint changed to the extent that they now view me as a serious risk if they were to grant me an additional in-school forbearance for the period of XX/XX/XXXX thru XX/XX/XXXX, despite the fact that I am working on the completion of the final degree for which they granted the forbearance request effective XX/XX/XXXX and end XX/XX/XXXX. 

Now, Wells Fargo Underwriting can at minimum infer my age from the loan origination date. They can take that inference, combine it with other biographical information such as my sex, and compute a perceived risk level in terms of likelihood of repayment while the SARS-CoV-2 continues to be an issue. They also have knowledge, per my prior dispute that I am student with a documented learning XXXX and am a minority. 

Now, from the WF Q3 earnings call their own CEO stated that interest income was down YoY. WF has every incentive in the world to manipulate and discriminate to shore up their bottom line -- they've done so in the past with their mortgage business. WF stated to the CFPB that I was in a " payment deferral '' rather than an in-school forbearance, knowing that what they were stating to the CFPB was false. The attached document shows that I have been in an in-school forbearance status for their periods WF claims I was in a " payment deferral '' status. They stated that I was in " payment deferral '' to hide a prior history of granting an in-school forbearance so that they could force me into repayment on terms that were more favorable to their bottom line during the pandemic. They provided inaccurate information to the CFPB and made a statement regarding " maximum in-school deferment time used, '' to conceal the tactics WF is using to shore up the revenue streams because of the uncertainty surrounding the COVID-19 pandemic and the effect it has had on their income. 

The question that needs to be asked is WHAT has changed in their evaluation of me and granting an in-school forbearance AFTER XXXX XX/XX/XXXX? According to their statements maximum deferral time had already been used YEARS before. None of my identifiable information changed after that date, but the level to which WF has subsequently viewed me as a risk is all but clear : the pandemic. 

As far as Wells Fargo is concerned, it is safer for them to force me to work during the pandemic and increase the likelihood of me being exposed to SARS-CoV-2, and possibly succumbing to the virus, than it is to grant an additional in-school forbearance for XX/XX/XXXX thru XX/XX/XXXX because they will have been paid something in an instance if my untimely death. 

By claiming " maximum time used '' and providing false information to the CFPB, Wells Fargo is attempting to hide their arbitrary and capricious, discriminatory practices, hoping that I, nor the CFPB, nor the public, would catch on.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation