Consumer complaint received 2015-12-18
Product: Mortgage — Home equity loan or line of credit
Issue: Application, originator, mortgage broker — 
Company: PNC Bank N.A. (NC)

I spoke with a PNC banker about a home equity line of credit in the middle of XXXX. The banker informed me that during the application process the following would be required for underwriting : the last two years of XXXX, the last two months ' paystubs, the balance of my mortgage, and proof of home owner 's insurance. These requirements mirror the requirements that PNC advertises on its website ( information available at : XXXX last accessed XXXX XXXX, 2015 ). 
PNC contacted my company ( via a public information submission form on the company website ; I note this is hardly an appropriate way to request financial information on an employee ). An executive at my employer verified my employment ( he provided me with a copy of the form he submitted XXXX. On XXXX XXXX, 2015 I received from my PNC Loan Analyst that my employment status was verified. 
Per PNC 's published standards, this should have resolved the documentation I would be required to submit to the underwriter. 
On XXXX XXXX I emailed my Loan Analyst asking for an update on my application. She informed me that the underwriter was requiring that I submit information regarding my equity in my employer. As this asset ( and all assets per PNC 's requirements as stated on their website ) are not required for a Home Equity Line of Credit, I declined to provide this information. I then emailed the Loan Analyst 's supervisor to express my concern about a request that contradicted PNC 's published guidelines. The supervisor wrote back and reiterated that the underwriter was requiring that I submit information about my equity holding. 
PNC has publicly available content that markets the HELOC in a particular way. I met the standards of documentation per these guidelines and PNC confirmed my employment status. To request information that is not included in published information raises several problems. 
1 ) The information advertised on PNC 's website does not match the standards that have been applied to my application during underwriting. Given that I was " sold '' the loan with this information ( in that the information was an incentive to select PNC for its streamlined underwriting process ), the hidden requirement seems to violate Regulations Z and N of the TILA. 
2 ) Frankly, my application is being subject to moving standards during underwriting. I received confirmation of my status and, therefore, the standards by which the application should be judged. A month later, a new set of standards is being applied. It is hard to believe that my application is being assessed fairly if PNC 's underwriting is quietly applying new standards when assessing my application. 
3 ) I expressed concern about this to a supervisor and the supervisor sided with the underwriter. As such, I can not believe that this shift in standards is a misunderstanding or an error made in good faith. When I raised the concern initially, a separate PNC employee reiterated that I was expected to comply with a request that contradicted published information.