Consumer complaint received 2024-10-10
Product: Mortgage — Home equity loan or line of credit (HELOC)
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: CITIZENS FINANCIAL GROUP, INC. (FL)

Sometime in XXXX i got a letter saying my home is in XXXX XXXX effective XX/XX/XXXX after XXXX update. XXXX on XX/XX/XXXX i got the letter from my XXXX XXXX ( Citizens ) that i need to purchase XXXX XXXX. The letter is called " Your immediate Attention is required '', it does not specify if this is the XXXX notice, XXXX notice, etc. Also in the letter we can see the words " recently you received a letter '' without specifying the exact date when any other letters were sent. The letter contains the language " if we did not received proof of flood insurance coverage within 45 days of the date of the letter '' which for me as a borrower means from the date of the current letter, than they gon na purchase a XXXX insurance. So, i started imediatelly check on the quotes and provided the XXXX XXXX, issued on XX/XX/XXXX, effective XXXX. According to the agent we could'nt make it effective XX/XX/XXXX since this is not a purchase and the zone just changed, so the insurance companies requires 30 days in order go into effect. I was very surprised when i saw that Citizens purchased a Forced -placed insurance for me wich is 4 times more cost than the one i have. When i called them today to figure out about the whole situation, i was told that they mail me a letter sometime in XXXX and the 45 days expired on XX/XX/XXXX the date they purchased the Force-placed insurance.The customer service along with the supervisor were saying it is not our fault you did not get your letter in XXXX. Also regarding the letter i got in XXXX without any dates on it, their explanation was, if something was not clear you suppose to call. 
Dear Servicer, when a mortgage servicer sends a notice for flood insurance, they are legally required to include specific details about the force-placed insurance, including the date when the force-placed coverage will take effect if the borrower does not provide proof of adequate flood insurance. This requirement is set forth under the Flood Disaster Protection Act of XXXX, as amended by the Biggert-Waters Flood Insurance Reform Act of XXXX and further clarified in Regulation X ( Real Estate Settlement Procedures Act, RESPA ) and Regulation Z ( Truth in Lending Act, TILA ). According to these regulations : The servicer must send the borrower a notice at least 45 days before force-placing the insurance. 
The notice must include the effective date of the force-placed insurance if the borrower fails to purchase their own flood insurance during that XXXX period. 
Failure to comply with these notification requirements can result in penalties for the servicer. 

Unfortunatuly the letter i got on XX/XX/XXXX does not include the date of previous letter, does not specify if this is the XXXX, XXXX, or final notice, does not include the date when the force-placed will be purchased. I do not think the borrower is responsible to pay any lapse without proper information provided. Also, im not responsible to cover any aditional interest for XXXX month only because you decided to purchase the insurance on my behalf. 
My main servicer on the mortgage got my renewal without any issues. We are talking about the same house, same address. I'm really dissapointed of your service.