Consumer complaint received 2016-06-14
Product: Mortgage — Home equity loan or line of credit
Issue: Loan servicing, payments, escrow account — 
Company: JPMORGAN CHASE & CO. (OR)

In XXXX, I obtained a HELOC from the former WAMU which was then assumed by Chase during the banking crisis. During this time, my HELOC was suspended. I think this was due to a decline in my credit score. However, my credit score declined due to a rise in revolving credit line balances and not because of any past due payments with any creditor. As of today, Chase continues the suspension of the HELOC. I believe the Bank has violated many consumer lending regulation such as XXXX, Regulation Z and XXXX. It does not appear the Bank adopted best practices for working with borrowers who experienced a financial hardship as a result of the suspension of HELOCs. I believe the HELOC credit privileges should have been reinstated due to the following items. 
The Bank unfairly suspended the HELOC account as the Bank did not provide a designated Reg Z circumstance in any communication with me. I was unable to determine if my property value was calculated, or if the analysis of my financial condition was based on a factual basis and applied consistently. 
Credit privileges were not reinstated in a timely manner when those apparent circumstances ceased. 
The Bank did not monitor affected lines of credit frequently enough to assure the condition permitting the suspension continues to exist. 
I was unable to locate documentation which required me to request reinstatement of the credit privileges. 
Regulation Z prohibits a creditor from changing any term of a HELOC account, except in these certain circumstances : Value of the collateral declines significant below the appraised value. The property did not decline significantly by 50 % or more. Unable to determine if the bank had a sound factual basis for this conclusion. 
Creditor believes the borrower will be unable to make payments as agreed because of a material change in financial circumstances. Although there was a decline in my credit score, I did not have past dues over 30 days on any debt. I did have late payments on this credit line, but none had been over 30 days, except for XXXX which I had disputed with Chase after the takeover of WAMU and I made a payment in-person at the branch location. I was later informed that branch payments take several days to post and that was why it appeared as a 30 days past due. Unable to determine if the Bank documented that I had a " material '' change in financial condition and if they had a reasonable belief that I would not pay as agreed. Both the conditions of material change AND reasonable belief of default must be present for the creditor to claim this exemption. 
Consumer is in default on material obligation of HELOC Agreement. There was no material default in the agreement, no default payments, no intervening liens, and I still reside in the dwelling. 
There is an additional issue which also impacts the principal balance and interest charges. 
Several times I have inquired with Chase regarding the principal balance calculation. Since approximately XXXX XXXX I had made monthly payments in a round sum, in excess of the interest only payment. In some months, the additional monies exceeding the interest amount were applied to principal and other times it was not. Although I paid these bills through my on-line bill payment, the Bank stated I had to write on the check that I wanted the additional to be applied to principal since the standard procedure was to apply the entire payment to interest. It appears this issue was corrected around XXXX XXXX, but the Bank did not retroactively readjust the principal balance figures.