Consumer complaint received 2015-12-03
Company: WELLS FARGO & COMPANY
State: CA
Product: Mortgage
Sub-product: Conventional adjustable mortgage (ARM)
Issue: Loan modification,collection,foreclosure

Complaint:
To the Intergovernment Team, Office of Consumer Response CFPB Complaint # XXXX ( XXXX/Senator XXXX XXXX ) new actionable Wells violationsThanks for the interest you have taken in my case and your hard and diligent work together on my behalf. I am responding to your letter from XXXX XXXX inquiring if I was satisfied with my bank 's response. Sadly, I am not in the least satisfied with my bank 's response, because it is filled with untruths and violations of Dodd-Frank as well as new misinformation and infractions, which I will list in detail. At this point, Wells is still crafting their response to my charges by " XXXX XXXX '' which in itself is a violation of Dodd-Frank because they have a XXXX XXXX sale date on the house and Dodd-Frank could hardly state more clearly : " If evidence identifies material inaccuracies in the NPV input values, a foreclosure sale can not be conducted until the inaccuracies are reconciled. '' This is as you know from the Dodd-Frank Act section on NPV Notices, Supplemental Directive 1-15 as of XXXX XXXX, 2010 Section XXXX Disputed Property Value Input from page XXXX. I 'm not surprised XXXX runs roughshod over homeowners but I am somewhat surprised by their recalcitrance not to mention how easily they think they can bamboozle you, the CFPB. As Judge XXXX XXXX XXXX of Missouri 's XXXX XXXX XXXX said of Wells for their pursuit of illegal foreclosure, their " deceptive and intentional conduct displays a complete and total disregard for the rights of homeowners. '' You asked that I reply to your XXXX XXXX letter if I was not satisfied so here is my response. The most egregious thing Wells is doing on my account is inaccurately running NPV -- they also crafted the deception -- and falsely told YOU in their CFPB response ... that the only NPV inputs that can be disputed are property value ( though they then go on to say they do n't need to consider the homeowner 's appraisal ) and NPV " score. '' Which is simply not true. In fact, Dodd-Frank could hardly state more clearly, " If evidence identifies material inaccuracies in the NPV input values, a foreclosure sale can not be conducted until the inaccuracies are reconciled. '' This is from the Dodd-Frank Act section on NPV Notices, Supplemental Directive 1-15 as of XXXX XXXX, 2010 Section 2.3.4 Disputed Property Value Input from page XXXX. And that Wells routinely and deliberately misinforms those in their modification program is a violation of not only Dodd-Frank but also TILA and RESPA, not to mention the California Homeowners B.o.R. On XXXX XXXX I pointed out to Wells that their NPV was inaccurate when they did n't even re-run the NPV with their own new, lower appraisal. BUT THERE ARE MANY MORE NPV INPUTS WELLS USED THAT ARE ARE WILDLY INACCURATE : ( 1 ) The FICO score they used is far lower than any FICO score I 've ever had, and my FICO is sent to me monthly by my credit card ( 2 ) the property value they used is high, and Wells did n't even re-run the NPV test with their new lower appraisal. ( 3 ) the advances/escrow input -- Wells never sent the PAYMENT TRANSACTION REPORT requested so I could check their work. I have to check their work because Wells often fictionalizes. In fact Wells has an internal XXXX-page manual ( Wells Fargo Home Mortgage Foreclosure Attorney Procedure Manual, Version XXXX ) that explains to their employees how to fabricate missing documents in the interest of accelerating a foreclosure. 
( 1 ) Dodd-Frank states a foreclosure sale can not be conducted until NPV inaccuracies are reconciled. So Wells needs to lift the sale date on my home while they educate themselves on how to run an accurate modification. ( 2 ) Now that I 've finally extracted, thanks to the CFPB, my NPV data inputs Wells needs to correct my NPV and re-run it as per Dodd-Frank.

Company public response: Company chooses not to provide a public response
Company response to consumer: Closed with explanation