I am writing to file a complaint against XXXX XXXX XXXX, and XXXX XXXX XXXX XXXX , XXXX ( XXXX ) My wife and I have a 15 year mortgage with TD Bank since XX/XX/XXXX. For less complex mortgage payments and lower costs, we chose to purchase our property insurance independently without the use of an escrow account. Beginning in the fall of XX/XX/XXXX after the annual XX/XX/XXXX renewal of our insurance policy, there has been a growing pattern of harassment by TD Bank to not accept or lose the submissions of the proof of our insurance while threatening to force place escrow-based insurance on our property. Every fall, we and our insurance agency, XXXX XXXX XXXX XXXX, must submit the insurance policy multiple times while TD Bank continues to mail first and second warnings of no insurance coverage and threats to force place insurance.

This fall, the harassment was so blatant that I could only suspect that there were other motivations at work. I initially thought nothing of it when the banks administrative address for the mortgage moved from XXXX, Maine to XXXX, Ohio. When my insurance agency demanded to have confirmation of reception from TD Bank on XX/XX/XXXX, the emailed confirmation came from a XXXX  email address. When, on XX/XX/XXXX, I received an escrow analysis dated XX/XX/XXXX, a full six business days after proof of reception of our insurance, I began investigating what could be causing this.

This is when I now discovered a troubling relationship and is the basis of this complaint. XXXX XXXX , XXXX . has outsourced their mortgage administration to a company called XXXX XXXX XXXX XXXX , XXXX The outsourcing of this administration is not problematic. That this third party not only performs mortgage administration but also serves as an insurance company for escrow-based insurance is extremely problematic. This also appears to explain the growing pattern of harassment by TD Bank / XXXX to continually lose submitted proof of insurance by independently insured mortgagees. The recent move of the administrative address from XXXX, ME to XXXX, OH, the same city as XXXX indicates that XXXX  now has full rein of the process with no supervision. If I were elderly or timid, the path of least resistance would be to submit to escrow-based insurance at more than three times the price. It appears that only after I began filing complaints with regulatory bodies and contacting my lawyer that the force placed insurance was vacated the following day.

I strongly feel that consumers are being hurt and taken advantage of by this egregious conflict of interest. In the fall of XX/XX/XXXX, I fully expect this harassment to recommence. This practice is becoming tiresome and is transparently corrupt. This conflict of interest needs to be investigated and stopped and those clients who have been coerced into more expensive escrow-based insurance placed by XXXX need to be compensated.

It was only through the confirmation email coming from a XXXX domain email address that I was able to discover the presence of this third party company that TD Banks clients are unaware of and the motivations for this behavior. During a phone call with my lawyer to XXXX XXXX XXXX XXXX , XXXX personnel, they only admitted to not be TD Bank personnel under duress and sounded quite uneasy with the admission. When further questioned about the insurance aspect of their company, they became even more uneasy and obviously wished to conclude the phone call quickly.

I include copies of information of my situation. I ask that you please investigate this relationship and put a stop to this practice.

Thank you for your help.

Former Administrative Address : XXXX XXXX , XXXX . XXXX XXXX XXXX XXXX, ME XXXX Current Administrative Address : TD Bank Its Successor and/or Assigns As Their Interests May Appear XXXX XXXX XXXX XXXX, OH XXXX Address of XXXX : XXXX XXXX XXXX XXXX , XXXX XXXX XXXX XXXX XXXX, OH XXXX XXXX XXXX XXXX