On XX/XX/XXXX we closed on a purchase of the Property. XXXX was the mortgage broker for a loan funded by XXXX XXXX XXXX and advised us regarding the documents and insurance needed to fund the loan. 

In an email dated XX/XX/XXXX at XXXX XXXX, XXXX XXXX of XXXX informed the us that, in addition to other documents, that we would need to obtain an XXXX insurance policy on the Property prior to closing. In an email dated XX/XX/XXXX at XXXX XXXX, we responded to XXXX XXXX email regarding the documents needed. In his email, we asked Can you clarify why an XXXX is required? We noticed the last company sent us an XXXX policy and are unsure of the differences. We replied to them asking them to adjust. At XXXX XXXX on the same day XXXX XXXX replied to the us as follows : The XXXX policy is for condos only. Since this property is deeded as a condo, you only need walls-in coverage because you pay the monthly HOA dues which includes additional insurance. Does that make sense? 

Later in the day on XX/XX/XXXX, I replied to XXXX XXXX as follows : After speaking with the insurance agent she said because the community does not have a master association that we would actually need an XXXX policy. Will you please re-confirm what policy we need because every " we are receiving is an XXXX. Thank you. At XXXX XXXX, XXXX XXXX again responded as follows : The association does have a master policy. I have requested this from the HOA. The mortgage paperwork indicates that XXXX and XXXX XXXX XXXX  processed the loan as if the property was a condominium with exterior insurance coverage provided by the association. 

Based on the representations made by XXXX and the repeated confirmation from XXXX XXXX of XXXX, we purchased a XXXX policy with XXXX XXXX XXXX XXXX ( XXXX ) instead of an XXXX policy. Unfortunately, shortly after we closed on the Property, XXXX XXXX hit the coast and damage to the Property was sustained. Specifically, we had significant roof damage, among other damage sustained. 

Due to the damage sustained by XXXX XXXX, the Property was partially exposed to the elements. We diligently acted to protect the Property by contacting the insurer and the association and proceeding to try to have the Property repaired. However, when they undertook this endeavor they were informed that, in fact, there was no blanket master policy for the Propertys association, the property is not part of a condominium and that they should have obtained exterior insurance coverage ( contrary to the repeated representations of LCA ). 

Due to the incorrect and negligent representations of XXXX and XXXX XXXX XXXX, we and out XXXX young children are currently displaced from their home and without insurance coverage for the damage that was sustained to the roof. Although we took diligent steps to make sure the property was properly insured, the continued negligence and misrepresentations of XXXX cause them to be uninsured for the exterior of their home. XXXX improperly advised us, against repeated question, that the policy needed to properly insure the Property was an XXXX and not an XXXX. 

We are now left displaced with our XXXX young boys and both banks are continuing to point the fingers at each other for weeks while no resolution is in sight.