Consumer complaint received 2020-03-21
Product: Mortgage — Home equity loan or line of credit (HELOC)
Issue: Applying for a mortgage or refinancing an existing mortgage — 
Company: TFS FINANCIAL CORPORATION (NC)

I. ECOA Regulation B, Section 701 ( e ) appraisal discrimination, II.  Equal Credit Opportunity Act ( ECOA ) 15 U.S.C. 1691et seq, III. HUD Regulations, IV. Consumer Credit Protection Act. 

1. Income : Debt To Income ratio ( DTI ) is within parameters, 2.  Bankruptcy, was voluntarily dismissed, XXXX 13. It was unnecessary, inadvertent and voluntarily dismissed, with no charge off or debt liquidation, 3. Collateral-Value of property. Tax record values are not considered valuations. 12 CFR 1002.14 ( b ) ( 3 ) ( ii ) 700. ... significant upgrades of 95 % of home and approximately 600 square feet were added in XXXX. A higher equity stake is plausible and realistic. Improbable pricing would remain at the same market value of XXXX, market comparables are available, 4. Credit Bureau XXXX , discretionary value and counter offer is available for lenders, depending on DTI XXXX actual value and repayment of {$120.00} ... see : XXXX XXXX file, online file # XXXX, 5. Denial Letter, Part 1, Credit bureau score does not meet underwriting guidelines for product requested. At no time was any other conforming product offered. Language is ambiguous and indicates other products are available. Denial was based on the singular request. Other products are available to an applicant, then deliberately concealed = discrimination. they do not want the loan for reasons other than underwriting criteria. 
6. Student Loan is being paid, as agreed ( has never been late, credit reporting is erroneous ), and is paid on an Income Based Repayment plan. [ Footnote : XXXX is being sued and challenged across the country, for its dubious, unfair collection practices and misleading credit entries. Applicant has every check from early XXXX for payment : production on request ]. 

The applicant reiterates and accuses, Third Federal SavingXXXX and Loan of willful and intentional discriminatory practices, misconduct. The facts do not support Third Federal 's Credit decision-denial. 

Discussion Factors such as, value, Debt To Income ratios and credit scores are not insurmountable for the lender. The applicant alleges, Third Federal deliberately, with intent, determined the applicants application as insufficient, and never requested clarification, or independent verification of any of the criteria used in the declination, refusal of credit. 

Initial review included a credit check. The credit check was run upon checking the box, in the online application. The credit profile was available almost immediately, the day of application, XXXX XX/XX/XXXX. Yet, they waited until Wednesday XXXX XX/XX/XXXX to call me and indicate they could not move forward with my request and created a letter-communication based off the initial contact ( XXXX XX/XX/XXXX ),  with insufficient information, based on a cursory review of the applicant 's age, race, gender and automated underwriting determinations. Third Federal never said the applicant didn't qualify for a loan, they said : she didn't qualify for the product requested, two very different things. 

Further, FACTORS AFFECTING THE XXXXREDIT SCORE : FALSE AND MISLEADING Medical Bills ... seasoned 3-5 years Number of accounts with delinquency ... questionable Established accounts ... supersede delinquencies Bankruptcy dismissed ... .inadvertent, unnecessary, interpreted by lender The applicants contention is Third Federal looked into any permissible reason to reject the application, and to find reasons to deny the application, beyond facts that could have been ascertained. Discrimination is present and evidenced in correspondence, file, and Third FederaXXXX applicable-underwriting guidelines.