Consumer complaint received 2019-05-28
Company: Specialized Loan Servicing Holdings LLC
State: FL
Product: Mortgage
Sub-product: Conventional home mortgage
Issue: Trouble during payment process

Complaint:
This is a follow-up complaint to the previously filed CFPB Complaint XXXX. This is being submitted as the Specialized Loan Services ( SLS ) response on XX/XX/19 to my initial complaint XXXX was inadequate, did not address my concerns, and did not respond fully to questions in the complaint. As such, I have detailed specific questions to which SLS should provide a thorough response. 
In your response to Complaint XXXX, you state that SLS can not comment to transaction that occurred with XXXX XXXX XXXX   XXXX XXXX. Further SLS was not involved with the origination of the loan and can not comment on any aspect of the origination. I find this as an unacceptable answer to me or to any consumer which may have such a complaint. First of all, your response is actually based on origination documents so you are actually contradicting yourself. Ironic to say the least. I ask the following questions that I expect to be answered in your response to both me and the CFPB : 1. Did you make any attempt to discuss this matter and my concerns with XXXX XXXX XXXX XXXX XXXX? Any good faith effort to understand what transpired in the origination? 
2. Do you believe that it is appropriate to not further investigate my concerns/complaint? I would think that as a servicer at the minimum you would need to demonstrate that you performed a reasonable investigation. In addition, you also have a duty to the loan investors and I believe it is your responsibility to properly address any concerns with their investment. 
Now, your response to Complaint XXXX also did not address the concerns I expressed in which I believe SLS violated the Dodd-Frank Wall Street Reform and Consumer Protection Act, specifically with requirements in which SLS should refrain from committing unfair, deceptive, or abusive acts or practices. In my initial complaint, I stated clearly that SLS force placed an HO-6 insurance policy on my loan on the premise that it was required by Florida law as SLS representatives stated in a voicemail message which I saved, previously provided to SLS, and have attached again to this complaint. Although I asked many times during multiple phone calls to SLS to provide the citation of Florida law that established such requirement, SLS NEVER provided the information. Furthermore, during my discussions ( phone calls ) with SLS, the SLS representatives NEVER mentioned that the HO6 policy would be required by the loan documents. If they would have said so, then I would have asked for that information/evidence. The fact of the matter is that in all the communications is had with SLS representatives prior to this complaint, SLS only stated that HO6 is required by Florida law. As such, the actions of SLS were DECEPTIVE and misleading. If SLS would have taken the appropriate actions and provided and disclosed to me the full and accurate information with respect to the HO6 insurance either from the loan documents or the Florida law, then I would have had the complete information to make an informed decision. Unfortunately, SLSs lack of transparency, lack of knowledge of laws, and omission of material information resulted in my not being able to make a fully informed decision. ALL of my decisions in this matter were based on the fact tha

t SLS representatives continuously communicated to me that the HO-6 insurance policy requirement was based on State of Florida law and didnt refer to anything else. I ask that in your response you answer the following questions. 1. Do you agree or deny that your SLS representatives on multiple occasions stated to me that the HO6 insurance was required by State of Florida law? 2. Can you provide a citation from Florida law that was EFFECTIVE AT THE TIME OF OUR COMMUNICATIONS that specifically and clearly states that HO6 insurance was REQUIRED? 

In my initial complaint XXXX I also stated that SLS actions were UNFAIR in that The force placed insurance caused me direct and substantial injury since my monthly payment immediately increased by {$1200.00} ( 77 % ) per month and I had to eventually get my own HO-6 policy which I was not required to obtain based upon the  representations that it is required by State of Florida it was not avoidable by me ; even though I attempted to resolve the matter with SLS prior to the force placement, SLS did not act appropriately, did not provide complete and accurate information that I requested, and continued with the erroneous force placement ; furthermore, if I did not pay the increased escrow amount, then SLS would have reported negatively and incorrectly to the credit bureaus which would have created yet another regulatory violation ( of FCRA ) on their behalf my financial injury was in no way outweigh by any benefit of having the HO-6 policy ; in fact, the first policy was retroactive 11 months from the date it was purchased ; since I had no events or claims during those 11 months then the benefit of the policy was solely for SLS, NOT the customer ; in addition, since the HO-6 policy is not a legal requirement, then I do not believe the benefits of the policy costing approximately 89 % more than the typical market price outweigh its costs. 

I ask that in your response you respond to my aforementioned comments that the actions of SLS were UNFAIR. 

In my initial complaint XXXX I also stated that SLS actions were ABUSIVE in that I placed reliance on SLS to act in my best interest and to provide me with accurate and complete information that I could use to make a decision. However, SLS did not adequately perform its responsibilities in understanding State of Florida law and did not provide me with the evidence and citation of the Florida law SLS referred to in its voicemail probably because the requirement does not exist ; SLS was in a position to take advantage of me as I felt I did not have any other avenue to gain clarity on the matter and resolve it except for getting my own legal advice. 

Given the clear violations of the Dodd-Frank Act and UDAAP guidance from the CFPB, I believe SLS take remediation action to make me the customer whole again. I should be reimbursed for the insurance that was force placed plus any interest. 

I hope we can resolve this matter and come to an agreement.

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