We represent a client for purposes of providing homeowners insurance as a licensed brokerage in the State of New Jersey. Recently we submitted an invoice to Selene Finance, LLC for LOAN # XXXX. Selene Finance has an extraordinarily expensive force placed insurance policy for this client. We submitted an invoice and a properly signed, fully conforming, client signed application to Selene Finance for payment in lieu of the force placed policy. In addition the client telephoned Selene Finance and verbally authorized the payment of the insurance policy. 
Selene has refused to pay the invoice without justifiable reason. The client telephoned and indicated that Selene was difficult to deal with ( the client has difficulty with English ) and that they would not provide a justifialbe reason. 
Selene has a very expensive and very lucrative force placed policy for this client. Attempts to resolve the matter with Selene resulted in an impasse and once again, no legitimate, legal justifiable reason for denial of payment of the policy. 
Upon information and belief Selene is engaging in Gate Keeping activities and placing illegal, illegitimate and fraudulent and abusive artificial impediments to borrowers who have force placed policies in order to reap a greater financial benefit. The force placed policy in question here is exorbitantly expensive, offers little or no protection to the homeowner or their possessions, solely covers Selene and in the event of a catastrophic occurrence or claim would benefit Selene Finance more than the homeowner. When it was indicated that complaints would be filed unless the matter was resolved Selene employees replied " You have to do what you have to do '' and patently refused to pay the invoice. 
The seminal reason for Selene 's denial is a handwritten note on the insurance application which Selene claims violates its internal standards. The application itself is not for Selene, is superfluous to the process for Selene and is for the carrier, and conforms in all ways with federal and state laws, and with carrier guidelines. The submission of the application was solely to demonstrate the clients authorization to place the policy. Once again the client phoned in and verbally authorized the payment of the insurance. 
It is clear that Selene 's artificial impediment is intended to delay placement of force placed policies, wherein the financial benefit of these extremely expensive policies would yield to their benefit. Quite simply, Selene is abating the client 's clear verbal and written authorization to their own financial benefit. This qualifies as fraud, waste and abuse, is of the worst business practices, is a violation of federal and state standards and because it was stated that this is Company policy it is clear that there is a pattern and practice of deceptive acts and practices being committed by this financial institution. Please address this immediately as the estimated cost to the American consumers at large may be XXXX dollars due to an ongoing deceptive act and practice. The financial injury to this client continues to mount each day the policy is not placed for non payment due to the direct and fraudulent acts of Selene Finance, LLC, its agents and assigns. Thank you for your kind attention to this matter.