Consumer complaint received 2016-10-19
Company: BWW Law Group, LLC
State: MD
Product: Mortgage
Sub-product: Conventional adjustable mortgage (ARM)
Issue: Loan modification,collection,foreclosure

Complaint:
This is a complaint against BWW Law Group which is a debt collector and as such is liable under the CFPB for it 's actions. 
I received from BWW Law Group letters dated XX/XX/XXXX, and XX/XX/XXXX, denying my application for a loan modification. I timely appealed the denial, but, to date, BWW Law Group has not responded to my appeal of the denial. Nonetheless, mere days after the XX/XX/XXXX appealed denial, BWW Law Group via its letter to me dated XX/XX/XXXX, solicited me to submit another application for a loan modification. BWW Law Group advised, on page XXXX, that " We will review your completed application for assistance, which must include all required forms and financial documents, even if a foreclosure sale date is scheduled within 30 days. '' Mindful of BWW Law Group 's language, I submitted XX/XX/XXXX, a loan modification application via USPS certified mail/return receipt # XXXX , of which BWW Law Group confirmed its receipt XX/XX/XXXX. 
I have not since XX/XX/XXXX received any communication from BWW Law Group advising that additional documents to the application are required in accordance with the Consumer Protection Bureau, ( " CFPB '' ), despite the fact that BWW Law Group had 5 business days from the date of receipt to notify me of any additional required documents. As BWW Law Group has not timely requested additional documents, I reasonably assume that BWW Law Group continues to review my application as a " full package ''. 
BWW Law Group has not denied my XX/XX/XXXX, application nor has it requested additional information, but BWW Law Group did schedule my home to be sold at foreclosure auction on XX/XX/XXXX. This act demonstrates dual-tracking by BWW Law Group, which BWW Law Group attempted to undertake also on both XX/XX/XXXX and XX/XX/XXXX. These attempts to conduct a foreclosure sale of my property while my loan modification application undergoes review is in direct violation of Regulation X, 12 C.F.R. 1024.41 ( g ) and ( j ). It is also a covered error under Regulation X 1024.35 ( b ) ( 10 ), as is a servicer 's failure to provide accurate loss mitigation and foreclosure information. 
Also, although BWW Law Group claims that the Pooling and Servicing Agreement ( PSA ) dictates the terms of the modification insofar as how many loans in the subject pool may be modified, BWW Law Group also disregards the CFPB in failing to provide proof of this purported reason for a denial of any of my loan modification applications. BWW Law Group provided only a singular letter relating to the investor guidelines, and it predates my submission of a complete application for a loan modification. In it, BWW Law Group suggests that the claimed investor issued a " denial '' of my incomplete application package for a loan modification. 
Despite BWW Law Group 's claim that pursuant to the PSA the investor will not modify any additional loans in the alleged subject pool, BWW Law Group 's numerous letters soliciting me to submit an application for a loan modification obviate BWW Law Group 's claim that no more loans from the subject pool can be modified. As a result, the existing basis for my being denied a loan modification derives not from an alleged lack of income or any other qualifying criteria, but rather from BWW Law Group 's meaningless claim alleging that the investor limit for modifications has been reached pursuant to the PSA. In any event, I did not sign or agree to the PSA and I am therefore not a party to the PSA, which also governs the requirements for the very " conveyance of the mortgage loans '' into the " pool '' or trust. Yet, BWW Law Group has denied me a loan modification based on a document to which I am not a party. Perhaps it is this contradistinctive situation which owes to BWW Law Group 's perennial issuance of loan modification invitations to me. 
The XXXX XXXX

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation