Consumer complaint received 2016-11-12
Company: KEYCORP
State: NY
Product: Mortgage
Sub-product: Home equity loan or line of credit
Issue: Loan modification,collection,foreclosure

Complaint:
Key Bank and CFPB have used its response to complaint, case number XXXX, to respond to my XXXX/XXXX/16 complaint to the NY State Attorney General for my request for mediation with an empowered Key Bank representative who " can do deals '' pursuant to the NY State Attorney General 's mediation program. Other than representing that Key Bank received the complaint from the NY State Attorney General on XXXX/XXXX/16, I have received no response to this request from Key Bank or a forwarded response from the State Attorney General. Key Bank has also used its response to the specific request of case number XXXX to further respond to my complaint, case number XXXX. I will briefly respond to XXXX XXXX representations as a way of moving case resolution forward and may make a more formal complaint at a later date, because based on my research and discussion with the president of XXXX of what Key Bank 's representatives have misrepresented to me, I believe Key Bank is violating sections of Dodd-Frank and federal and New York State UDAP ( Unfair or Deceptive Acts or Practices ) statutes. XXXX XXXX divided her response into sections that she numbered one through five. I will reply to these responses in order : # 1 Request for loan modification options for estate : XXXX XXXX represents, arguably misrepresents, that " due to federal regulations, Key Bank can only offer a loan modification to the liable signer '' and then misrepresents that the estate is not the legal equivalent of the now deceased ( I 'll use its argument in foreclosure! ). I request that Key Bank identify what federal regulations to which XXXX XXXX is referring. I ask the relevant regulator reviewing this case to ask why a federal regulation allows for a bank to ignore its STATUTORY ( my emphasis ) obligations under Dodd-Frank and federal and New York State statutory UDAP provisions. 
# 2 Request for use of exchanging services as part of workout. I ask XXXX XXXX, again, to identify what federal regulations she is referring that " requires us to lend consistently among qualified individuals. '' I am familiar with the relevant sections of Dodd-Frank that require nondiscrimination in lending, based on the typical bases " race, gender '' and etc., " e.g. source of income. '' I am unfamiliar as to why these sections would prohibit a bank from offering barter as a mechanism for workouts with other borrowers or why XXXX XXXX representation allows Key Bank to avoid certain workout requirements of Dodd-Frank. I ask the relevant regulator to ask the same question, and, especially to recognize how, if Key Bank follows this policy, how it is violating public policy considerations as expressed statutorily by federal and state statutes, how much unnecessary injury it is causing to its borrowers, and how its loan collection policy might be viewed as " unfair '' or " predatory, '' as those terms are defined in law. 
# 3 Deed-in-lieu : I have spoken to XXXX XXXX who was kind enough to explain how Key Bank has conducted the transfer of deeds in lieu of foreclosure in the past. During the conversation, when I discussed the necessity of Key Bank to provide the value of the positive equity in the property as a term of the transfer because transferring the property and walking away from {$200000.00} in equity would be, to use my term, " insanity, '' as Key Bank was offering, XXXX XXXX agreed. 
# 4 XXXX XXXX misrepresents what I told XXXX XXXX in a phone conversation of XXXX/XXXX/16 regarding that I believe Key Bank is violating Dodd-Frank in its conduct of this case. It is not because Key Bank has chosen not to lend to estates ( although its misrepresentations that this is because of federal regulation was a source of mirth to the president of the XXXX ) but that it is not complying with D-F 's workout provisions. A workout is not a new loan. 
# 5 : Thank you.

Company response to consumer: Closed with explanation