Consumer complaint received 2016-08-15
Product: Mortgage — Other mortgage
Issue: Loan servicing, payments, escrow account — 
Company: BANCO POPULAR DE PUERTO RICO (NC)

Since XX/XX/XXXX I have been requesting a copy of my mortgage servicing file in accordance with Part 1024 of the Real Estate Settlement Procedures Act ( Regulation X ) XXXX - Requests for information. Finally after several attempts, the bank responded improperly denying the requested indicating that was b overbroad and unduly burdensome. Based on that response I submitted a complaint through the CFPB and the bank responded providing limited information. However, their response provided false and misleading information that raises more issues than originally presented. 

I responded requesting additional information and clarification of the issues misrepresented in their response to the CFPB, however, the bank ignored to the address the issues and to this date has not provided any information. Copied below is a letter I sent the bank and copy of that letter was sent to CFPB ( who failed to include that response in the original complaint ) : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, NC XXXX XXXXXXXXXXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX Team Supervisor Mortgage Servicing Division XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX : CFPB Complaint XXXX I make reference to your letter dated XXXX XXXX, XXXX in response to my complaint to the CFPB referenced above. 

I will address each of your responses in the order presented in your letter. 

Document requested : Change of ownership I have received and appreciate the copy provided ; however, to this date, the XXXX has not made the change of ownership. I understand that the problem could be the XXXX and not the responsibility of the bank ; however, I do n't understand why I keep receiving letters from the bank asking me to file the change of ownership. Since the bank, as servicer of the loan, has the original copy and it is aware that the form has been filed with the XXXX, then the bank should re-submit this to the XXXX. 

Forced place hazard insurance policy from XXXX of XXXX to XXXX XXXX. 

During the above cited period the insurance premiums were not paid. On the modification closed on XXXX XXXX, XXXX we paid {$3600.00} for hazard insurance which is the equivalent of 28 months of hazard insurance premiums. This amount represents insurance premiums for the period of approximately XX/XX/XXXX to XX/XX/XXXX. Since you indicated that there was no forced placed insurance, please let me know if that amount was charged by mistake, and if so please refund the amount paid. Otherwise please provide evidence for the amount paid during the period previously cited. XXXX, the insurance company that issued the policy indicated that insurance was obtained by XXXX XXXX , XXXX, a subsidiary of the bank, and that XXXX XXXX received a commission for placing the insurance. I do n't understand why XXXX XXXX is acting on our behalf. I have reviewed the mortgage and promissory note and there is nothing in those documents that would give XXXX XXXX , XXXX the authority to act in our behalf. The insurance could have been obtained directly by BPPR, as the servicer of the loan, and would have resulted in a lower cost to us. See the modification closing statement dated XXXX/XXXX/XXXX. 

If the bank placed the insurance pursuant to CFR 1024.37 - Force-placed insurance, then the bank failed to comply with the notification requirements of the regulations. Those regulations provide the specific notification required before and after the insurance is placed. In addition, the servicer is required to comply with certain requirements established by XXXX. Since the loan was a XXXX loan, at least through period to ending with the modification, the servicer was required to comply with those requirements too. If we have known that the bank was going to use an intermediary, which result