XXXX XXXX XXXX XXXX XXXX XXXX, which is the most recent servicer of my loan has demanded payment from me for a number of years from me, regarding what appears to be somewhat of a phantom debt. This debt has been long disputed multiple times with multiple servicers with relation to the origination of my predatory loan. My loan which was conceived as a XXXX XXXX Bank XXXX XXXX XXXX line of credit of {$70000.00}, with a rate of 9.5 % interest and placed me at great risk based upon complete disregard for my Tangible Net Benefit and ability to repay. At the time my loan was originated with XXXX, failed to protect my future financial interests and ultimately forced my loan into foreclosure as a result of ignoring basic underwriting guidelines as well as violations to The Real Estate Settlement Procedures Act ( RESPA ) which prohibits unfair lending practices. Furthermore, there has been unfounded and incomplete evidence provided by SLS surrounding that the above mentioned loans origination, chain of title and assignments are unclear. 
SEE EXHIBIT " A '' XXXX INCOMPLETE QWR RESPONSE Due to the XXXX, failed response to my issues, I 'm considering raising this matter in the Court as I feel it may be the proper venue for action under XXXX UXXXX XXXX, because XXXX or more of the Defendants maintains executive offices in or conducts business in the district relevant to where real estate is located in this concern. 
The interagency Statement on XXXX enumerates certain tactics that may indicate predatory lending. Nonprofit groups have also published widely accepted guidance on these kinds of practices that may constitute predatory lending. Predatory loans typically combine risky loan features, thereby placing the borrower at an excessive risk of default or foreclosure. 
For purposes of this Complaint, " Combined-Risk Loans '' are loans that meet the definition of high-cost loan under XXXX. XXXX, which is an extension of The Home Ownership and Equity Protection Act ( HOEPA ) and enacted in XXXX as an amendment to the Truth in Lending Act ( TILA ) to address abusive practices in refinancing and home-equity mortgage loans with high interest rates or high fees. Loans that meet HOEPA 's high-cost coverage tests are subject to special disclosure requirements and restrictions on loan terms, and borrowers in high-cost mortgagesXXXX have enhanced remedies for violations of the law. 
XXXX XXXX Bank XXXX XXXX XXXX, was incorporated under the laws of the State of Delaware. In subsequent paragraphs of this complaint, XXXX XXXX Bank will be referred to as " XXXX, '' " the lender '' or " the defendant. " XXXX 's business includes engaging in residential real estate-related transactions and regularly extending credit to persons. XXXX, as an entity whose business includes engaging in residential real estate transactions -- including home equity lending as well as home purchase and refinancing lending -- is subject to the requirements of the Fair Housing Act, as amended, XXXX XXXX XXXX. XXXX XXXX is also a creditor as that term is defined by section XXXX XXXX XXXX XXXX of the ECOA, 15 U.S.C. 1692a ( e ), and is, therefore, subject to the requirements of the ECOA and its implementing Regulation B, as amended, 12 XXXX XXXX, in effect on or after XXXX XXXX, XXXX. 
The provisions of TILA, including HOEPA, are implemented in the Bureau 's Regulation Z. and also contain XXXX or more of the following high risk terms : ( a ) the loan was issued based upon the " stated income, '' rather than the verified income, of the borrower ; ( b ) the debt-to-income ratio exceeds 55 % ; of the actual income ( c ) the loan-to-value ratio is at least 125 % based on the values at time of closing ; ***SEE CONT. COMPLAINT PART XXXX VIA ATTACHMENTS***