Consumer complaint received 2020-07-31
Product: Mortgage — Conventional home mortgage
Issue: Closing on a mortgage — 
Company: PNC Bank N.A. (TX)

Two escrow accounts were established by PNC Bank Mortgage for the Conventional loan. 
1. Initial escrow account beginning XX/XX/XXXX XXXX. Escrow/Shortage Account beginning XX/XX/XXXX The results of the Aggregate analysis conducted " before establishment '' for the Initial Escrow Disclosure Statement as required by Federal Regulation 12 CFR 1027.17 affirmed by the Federal Deposit Insurance Corporation ( FDIC ) compliance manual is requested.

Disbursements for the initial escrow computation year period XX/XX/XXXX thru XX/XX/XXXX estimated XXXX Unimproved Property Taxes {$320.00} Hazard Insurance {$1200.00} estimated XXXX Improved Property Taxes of {$6600.00} Please provide the " periodic payment '' calculations ( {$440.00} ) by the Aggregate Analysis and the " amount to be deposited '' ( {$1000.00} ) before establishing the escrow account with supporting source documents. 

XX/XX/XXXX the Initial Escrow Computation Year Period by Federal Regulation ( 12 CFR 1024.17 ( b ) was unlawfully REDUCED by PNC Bank Mortgage from twelve ( 12 ) months to five ( 5 ) months and a new escrow computation year period began XX/XX/XXXX thru XX/XX/XXXX for 12 months. 
The Escrow Analysis and Trial Running Balance is requested which INCREASED the Total actual improved XXXX property taxes from {$2600.00} t the loan settlement to {$3300.00} as the alleged new Total ACTUAL annual improved property taxes disclosed to be disbursed XX/XX/XXXX. 

The monthly property tax escrow DEPOSITS were REDUCED although the TOTAL CHARGES for annual AND XXXX estimated improved property taxes INCREASED. 
THE WRITTEN EXPLANATION IS REQUESTED. 

To VERIFY the above changes in the escrow account PNC Bank Mortgage processed a {$1300.00} refund from the escrow account. 

XXXX XXXX the escrow account was INSUFFICIENT {$3600.00} AND WOULD XXXX EACH ESCROW PERIOD FOR 30 YEARS AS INACCURATE INSUFFICIENT MONTHLY DEPOSITS WERE DISCLOSED BEFORE THE LOAN, T SETTLEMENT, IN SERVICING THE LOAN AND AFTER THE ACCOUNTING ERRORS WERE DISCOVERED XXXX XXXX XX/XX/XXXX WITHOUT DISCLOSING THE ACCOUNTING AND LOAN DOCUMENT ERRORS TO CONSUMERS APPARENTLY BY THE AUTOMATED LOAN AND DISCLOSURE COMPUTER SYSTEM OF PNC BANK MORTGAGE. 
Disclosed inaccurate XXXX and XXXX annual property taxes estimated and actual disclosures to Consumers prior to the loan, for loan settlement documents, Aggregate Accounting document ( not disclosed to consumers ) Initial Escrow Disclosure Statement, the HUD-1 Settlement Statement of alleged ACTUAL BEST AVAILABLE PROPERTY TAX CHARGES AT THE LOAN SETTLEMENT BY EVIDENCE HAD BEEN INACCURATE PROPERTY TAX CHARGES INCORRECTLY DISCLOSED ON ALL LOAN DOCUMENTS BEFORE THE LOAN SETTLEMENT.

Why was the escrow account INSUFFICIENT and monthly escrow deposits INCREASED {$1100.00} PER MONTH WITHOUT EXPLANATIONS- THE PROPERTY VALUE HAD DECREASED, THE EXEMPTIONS HAD INCREASED TO BENEFIT CONSUMERS, THE FIVE TAX RATES WERE VIRTUALLY UNCHANGED. NOT PAYMENT SHOCK AS DEFINED BY HUD/CFPB. 

XX/XX/XXXX THE ESCROW/SHORTAGE ACCOUNT was established by PNC Bank Mortgage. 

The results of the Aggregate ANALYSIS conducted apparently " BEFORE THE ESTABLISHMENT '' OF THE NEW Escrow -Shortage Account as required by Federal Regulation 12 CFR 1024.17 as affirmed in the FDIC compliance manual is requested y the consumer for EACH ESCROW PERIOD as it appears EXCESSIVE FEES were UNLAWFULLY EMBEDDED IN THE ESCROW SHORTAGE ACCOUNT. The accurate completion of the Aggregate Analysis and Aggregate Trial Balance will disclose the accounting Violations The Aggregate Analysis and Aggregate Trial Balance Statement is requested for each change in monthly escrow required deposits for the loan.

{$700.00} = 1 periodic escrow computation period payment {$640.00} = 7 periodic escrow computation period payments {$980.00} = 3 periodic escrow computation period payments {$980.00} = 7 periodic escrow computation period payments Intention Violation of 12 CFR 1024.17 and 12 U.S.C. 2609 ( a ), ( c ) ( 2 ) ( A ).