The I am filing this complaint stating with all supporting evidence that the firm known as Reverse Mortgage Solutions , Inc. ( RMS ) a.k.a. XXXX. has violated both State and Federal mortgage servicing laws by the abusive employment of known deceptive practices to fraudulently increase the " security interest '' by adding expenses, fees and legal costs in making an unjust and undue demand for immediate full payment of the Plaintiff 's mortgage loan, which is in the process of being refinanced with another firm, to provide a complete payoff of the entire loan amount, however due to the circumstances of legal timing this transaction can not be completed prior to XXXX XXXX, XXXX or thereabouts, a fact which was clearly expressed in the written correspondence and also conveyed in several telephone conversations with specific RMS employees.The point of contention between the parties is that a remaining equity was less than the total property costs, and despite payment from the equity available, an overage in the total available equity line extended in the original mortgage agreement was agreed to be provided by RMS specifically utilized to pay for insurance and taxes, which were due on XXXX XXXX of XXXX and was paid towards the property for the year. RMS did in an extreme act of Bad Faith, subsequently after making payments as were authorized by the Plaintiff, did then make a false and unsupportable claim that a default of the loan note occurred due to non payment of taxes in XXXX of XXXX, this assertion claimed in the " notice '' is fraudulent and misleading when it states { " the taxes and insurance have/has not been paid on the property '' } ; which is not true or accurate as the taxes were paid on time as indicated above, and the Plaintiff 's remaining available equity line was also included in the payment ( s ). Further, the letter reiterates the verbal agreements made prior to XXXX XXXX, XXXX wherein I did request the advance be made under agreement that the extended monies would be repaid at the closing of the refinance. RMS accepted the requests and made both such requested payments, one for taxes and another for insurance upon my verbal approval knowing the funds would be returned at the refinance closing date. RMS now has made further false claims that no repayment of the overage was made, nor any arrangements agreed to provide such repayment. In fact, that is not possible as the closing date pending for XXXX of XXXX has yet to arrive. However, I did request a full payoff of the loan and clearly indicated in correspondence to RMS the exact terms of repayment and to which RMS by acting on the request did " accept by performance '' that this payoff figure was to be paid at the closing, when they delivered the exact payoff figure to me in a payoff statement. 
THEREFORE ; I was assured that " all was well '' and that the loan payoff amount is reliable and due at the refinance closing date, until the receipt on XXXX XXXX, XXXX of the due and payable notice dated XXXX XXXX, XXXX stating that RMS intends to file a foreclosure against me to collect the entire amount immediately for a default claim stated to be caused by my non payment of the taxes and insurance, which is a fraudulent claim intended only to drive up the cost of my closing expenses of the refinance loan set to occur after XXXX XXXX, XXXX. Thereby RMS, is attempting to pre-empt the closing date with a fraudulent foreclosure claim against me to complicate and charge addition costs not owed or allowable under the current payoff which they have already submitted. RMS is also known to be part of XXXX who recently settled a $ XXXX dollar " false claims act '' fraud case with the Department of Justice , and it appears they learned very little from this settlement as the actions of RMS in this case indicate a continued violation.