BACKGROUND OF LOAN : The subject loan was a Home Equity Line of Credit issued by Citibank. Loan Number : XXXX It was in the amount of {$640000.00} with a starting rate of 8.25 %. The Closing Date of the loan was XXXX XXXX, XXXX. 

The loan was an Interest Only Payment loan for the first 10 years. After 10 years, the loan would reset. When it reset, the loan would become a Fully Amortizing Loan, with payments of principal and interest required. 

In XXXX of XXXX, Borrower : XXXX was notified by letter that the loan was resetting. The monthly payment on the loan would increase effective XXXX XXXX, XXXX, to {$4400.00}, from the previous payment amount of {$1700.00}. XXXX realized that he would be unable to make the new payment and would face defaulting on the loan. In XXXX XXXX, he contacted Citibank about workout options so as to not default on the loan and initiated a hardship request. 

XXXX XXXX, XXXX, a letter was mailed to XXXX from Citibank acknowledging receipt of his hardship request. He was advised of numerous options, none of which mentioned loan modification or settlement possibilities. At the time, he was also advised that his application was incomplete and documents would be needed. 
In XXXX, XXXX enlisted the aid of XXXX XXXX to assist him in working with Citibank to achieve a workout resolution in the form of a Settlement Offer to pay off the loan. 

On XXXX XXXX, XXXX, an RMA Residential Mortgage Application was sent to Citibank consisting of 257 pages. The documents would allow Citibank to make a decision on whether to accept a Settlement Offer, or offer another type of workout solution. 
On XXXX XXXX, XXXX, Citibank had the property appraised. It had a value of {>= $1,000,000}, far in excess of what was owed on the first and second on the property. 

On XXXX XXXX, XXXX, XXXX was sent a Letter of Denial of the Settlement Offer. He was advised that the offer was denied due to the large amount of equity on the property. The only option provided to him was to payoff the loan. It was not processed for other loan workout options, and the loan modification option was denied due to HTI Ratio pertaining to his 1st lien of which borrower was approved for hardship loan modification with that mortgage servicer, XXXX XXXX XXXX based on the same hardship. 

Since XXXX XXXX, XXXX, XXXX and XXXX have engaged Citibank on a continuous basis attempting to negotiate a loan modification. Every step of the way, they have met with delays that has caused XXXX to fall further behind on the amount owed on the property. He now faces the prospect of foreclosure on the property. This matter has not been discussed at this time. The denial reason is also inaccurate under the guidelines of Citi 's Supplemental 2nd Lien program requirements that are not specific nor is the ( HTI ) Ratio, Housing to Income as it pertains to the 1st mortgage lien. 

The transparency of Citis efforts to delay, mis-represent, mis-communicate and deny this 2nd lien modification approval is solely based on the Equity of the property and Citis decision to reach a Foreclosure option based on the 10 months of non-payment while undergoing the loan modification review process in expectation that any delinquent payments experienced under this home preservation option would be deferred. The borrower was lead to believe that Citi would assist this borrower, by attempting to lower his monthly mortgage payments through a Loan Modification Review. It has been 13 months since Citi was engaged in the request for mortgage assistance. All Financial Packages were submitted in compliance with every request and in timely manner over ( 1 ) one year of effort. 

XXXX XXXX XXXX, CEO of the Citi Group was emailed on 3 separate occasions, informing him of the egregious nature of mis-conduct in the processing of this request for a loan modification. XXXX XXXX was also informed that in XXXX, Citi was attempting to Wrongfully foreclose on this property alleging 9 years of non-homeowners insurance payments, of which were dismissed only 2 days prior to the foreclosure sale date as all payment recipes of such home owners insurance payments were provided for verification of these payments being made by the borrower. 

At this time, Citi is showing a " Pattern '' of foreclosure attempts on this loan. The mis-conduct of the servicing and processing of this loan and it 's financial documents have repeatedly been subject to never have been delivered. All emails for 13 months can be provided for verification of this mis-conduct. 

A Formal Letter of Appeal was issued to Citi Mortgage today as this Complaint is being filed to the CFPB. The Appeal letter is required to be submitted 30 days from the day of the Denial letter of XXXX/XXXX/XXXX. Due to the emails that were submitted to XXXX XXXX XXXX of the Citi Group, it is suspected that XXXX XXXX requested another reconsideration of the approval of this loan modification, and in ( 1 ) one day, the reconsideration was denied again? 

All email copies to XXXX XXXX and to Citi banks Single Points of Contact can be submitted upon request for verification. 

Summary Review of the documents provided for the XXXX loss mitigation process reveals that Citibank has engaged in conduct that fails to follow CFPB rules and guidelines for engaging in loss mitigation practices. The failure to properly process the loan for modification opens Citibank up for liability under various different legal theories as cited under the COMPLIANCE ISSUES UNDER THE CFPB. 

Citibank has been recognized to have engaged in such practices over the years, and has been severely reprimanded by both the DOJ and the CFPB for amounts in the billions of dollars. Yet, Citibank continues to engage in such practices, without concern for the outcome to the consumer who has a mortgage loan with them. 

Included are 5 attachments : 1. - Citi Denail Letter # 1 2. - Citi Denial Letter # 2 3. - Letter of Appeal to Citi from Borrower " XXXX '' 4. - Letter to President Donald Trump and cc : copy to Acting Director of CFPB XXXX XXXX XXXX. 
5. - Email copies submitted to XXXX XXXX XXXX XXXX, CEO of the Citi Group