Currently, borrower has no loan status, due date or location for payments despite repeated requests. Full discussion of complaint points contained in the attachments to complaint along with support documents. 

In part, this complaint will cover : Servicer requiring the borrower be in default to discuss foreclosure alternatives despite being named in multi-state litigation, brought, in part to halt this practice ( XXXX Reasonably Foreseeable or Imminent Default ). Failure of servicer to discuss all loss mitigation options with borrower ; failure to communicate with XXXX-certified housing counseling agency, or, borrower 's attorney, Dual Tracking. 

Borrower was not allowed to review the terms of a XXXX or Forbearance Plan Notice ( FPN ), before agreeing, sight unseen, to terms and making the first payment over the phone. Servicer refused to allow borrower to receive terms via email or seek legal advice. Borrower was told decision must be made " now '' or " lose '' the plan, forcing borrower to rely solely on servicer 's oral representations. There was no obvious choice presented to the borrower, given the choice of accepting an XXXX UP sight unseen OR entering foreclosure and risking loss of a primary residence with meaningful equity. Borrower was unable to reasonably avoid injury due to servicer 's actions. These actions hindered the borrower 's decision making in part, by not allowing the borrower access to information needed to assess available alternatives. ( XXXX XXXX, UDAAP ; XXXX guidelines XXXX ; Section XXXX FTC XXXX : Deceptive Acts or Practices ) Servicer failed to honor total amount due estimate in issued XXXX UP Forbearance Plan Notice ( FPN ) at end of forbearance plan term requesting an amount that was a 44 % increase over the estimate contrary to XXXX servicing guidelines section XXXX. No explanation for the increase was given despite repeated requests. After months of requests regarding reinstatement Servicer claimed the amount given on FPN was NOT the accrued but unpaid balance as required, undisclosed amounts were now due. XXXX servicing XXXX : Forbearance Plan Notice requires the FPN [ must include ] " Estimate of the ACCRUED BUT UNPAID BALANCE that will be due at the end of the UP forbearance period if the borrower makes required forbearance plan payments on a timely basis '' ( emphasis added ). Adding amounts after the fact violates the letter of and spirit of XXXX, FTC XXXX Sec. XXXX, HAMP XXXX and assertions by Ocwen 's representatives. 

Failing to get accurate accounting from servicer, borrower applied for XXXX XXXX XXXX. Servicer failed to calculate XXXX XXXX step properly, follow and document waterfall steps resulting in an improperly denied XXXX XXXX modification in XXXX. Ocwen continued to affirm its incorrect calculation, refusing to re-evaluate or consider actual numbers from borrower and a XXXX XXXX ( XXXX servicing guidelines ). 

After months of litigation over the FPN, XXXX XXXX, XXXX, borrower 's legal counsel received an offer of XXXX Streamline ( TPP ) from servicer 's counsel who refused to draw up documents unless borrower agreed to the modification WITHOUT SEEING THE FULL TERMS. This establishes a pattern with servicer 's process, force the borrower to accept obligations without seeing the terms, a clear violation of the spirit of XXXX, XXXX, XXXX XXXX, FTC regulations. 

Borrower completed the TPP, Ocwen 's counsel sent a one-line statement denying the permanent modification. Borrower received no written notification of denial ; followed one month later by an approval. Modification documents promised from servicer never arrived. Documents provided by counsel were faulty carrying both a fixed and variable term, counsel refused to reissue, correct or allow time for correction of conflicting terms, insisting borrower sign documents that clearly violate XXXX XXXX, FTC and XXXX.