Consumer complaint received 2018-09-22
Company: JPMORGAN CHASE & CO.
State: VA
Product: Mortgage
Sub-product: Conventional home mortgage
Issue: Trouble during payment process

Complaint:
I believe that my Servicer ( Chase ) and loan provider ( XXXX XXXX ) are not being transparent and may intentionally be misleading consumers/borrowers  regarding their rights to waive/cancel PMI under the HPA and that they may not be following HPA which from what I've found specifies an 80 % LTV ratio on  conventional loans. 

I received a letter/disclosure from Chase regarding the Homeowner 's Protection Act ( HPA ) for Borrowers with PMI, which states that for loans closed after XXXX, PMI can be canceled if, " 1 ) the date the principle balance of your loan is first scheduled to reach 80 % of the original value of the property, OR 2 ) the date the principle balance actually reaches 80 % of the original value of the property ''. After further inquiry about canceling my PMI in XX/XX/XXXX, I received a letter from Chase on XX/XX/XXXX outlining further conditions required to cancel PMI : - Less than 2 years : 75 % LTV ratio or lower with significant improvements - 2 to 5 years : 75 % LTV ratio or lower - 5 or 5 years : 80 % LTV ratio or lower I called Chase on XX/XX/XXXX at XXXX to gather more information about canceling PMI and was told, that 1 ) I did not need an appraisal on my property if I made a lump sum payment to my principle based on the current assessment/appraisal value ( $ XXXX ) with the LTV Ratio at 78 %. I called Chase at XXXX and spoke with XXXX who mentioned that I may or may not need an appraisal if I paid a lump sum to have my LTV lower that 75 % against the original amount of the loan ( $ XXXX ). Additionally XXXX mentioned that I could try that ( i.e., lump sum on the original loan amount to have LTV lower than 75 % ) and " see if Chase would cancel/waive my PMI '' but that she was not sure so " it's best to try it and see what Chase decides ''. 

I was then transferred to XXXX, a PMI supervisor, who directed me to the above conditions laid out in the letter I received from Chase on XX/XX/XXXX. When I asked where I could find information to substantiate this, he mentioned that this can be found on " government sites ''. When I probed further, given I hadn't been able to find those specifications/conditions on any government sites, he then directed me to XXXX XXXX XXXX XXXX  XXXX : Termination of Conventional Mortgage Insurance ( XX/XX/XXXX ). Which states, " the LTV ratio eligibility criterion is met on the date the mortgage loan balance actually reaches 75 % of the original value of the property, if the mortgage loan is seasoned for two or more years, even if the original specified term has not elapsed. '' XXXX also mentioned that the initial letter I received from Chase laying out the 80 % LTV ratio was for " conventional loans ''. I then asked him whether my loan was conventional. He said it was but that the 80 % still did not apply to my loan.

This guidance differs from the information I received 1 ) during the closing process on my house, 2 ) the letter I received from Chase about my rights as a borrower under HPA, 3 ) the two previous phone calls I made to Chase about my loan/PMI on XX/XX/XXXX, and 4 ) any and all open source information I was able to find on CFPB and Federal Reserve Board websites laying out the conditions of the HPA. 

I, as a consumer, should be informed of the conditions required to cancel PMI under HPA before accepting the terms of the specific loan that applies to me ( e.g., conventional ). After going through all of my closing paperwork, I was only able to find information that states that PMI can be canceled after reaching 80 % LTV. This is confusing to consumers at best and intentionally misleading at its worst. Personally, I would like to pay a lump sum now to get my loan to 80 % LTV, canceling my PMI, without having to pay for an appraisal ( {$510.00} ), that is setup by a Servicer I don't trust ( Chase ), based on guidance from a loan provider ( XXXX ) that three Chase agents couldn't even interpret. If those customer service agents can't even understand the guidance, what hope is there for everyday consumers to understand it.

Company response to consumer: Closed with explanation