Consumer complaint received 2023-08-22
Product: Mortgage — Home equity loan or line of credit (HELOC)
Issue: Applying for a mortgage or refinancing an existing mortgage — 
Company: CITIZENS FINANCIAL GROUP, INC. (MI)

I am writing because I believe that I have been discriminated against or wronged in a lending decision made by Citizens Bank. 

I received a home equity loan from Citizens Bank last year in XXXX of XXXX, with a {$50000.00} limit. This XXXX of XXXX XXXX XXXX, a representative of Citizens Bank, contacted me and suggested that I apply for a higher home equity limit, and would receive a lower interest rate on my home equity loan. I explained to him at the time that I didnt think that I would take any additional money, but I would like to receive the lower rate. I sent in my documents as requested, except for my 401 ( k ) income. A drive-by appraisal was completed, I believe the value was $ XXXX, ( I do not have a copy of an appraisal, nor my value in writing ) I owe XXXX on my 1st mortgage and XXXX on the HELOC giving me an LTV of 55 % and my credit score was XXXX. I later received a call from XXXX advising me that I needed to pay off and consolidate additional debt into the new home equity loan so that my debt-to-income ratio would qualify me. I explained to XXXX I did not want to do that because the loans that he suggested for me to pay off had 3 % and zero % rates and therefore was of no benefit to me. I did say that I would consolidate the debts that had higher rates. I then I decided to send my 401k income information, to bring my debt to income within the guidelines. I discussed with XXXX that I sent in the 401k income and asked what the maximum DTI allowed. XXXX stated, my credit score allowed me a DTI of 55 %. XXXX was to get back to me after the underwriter reviewed the additional 401k income information. Instead, I received a denial in the mail stating my debt-to-income ratio exceeded the guidelines. When I asked for a more detailed explanation, such as what debts they were considering and why my 401k income was unacceptable. The response I received was incomplete and inaccurate. They didnt list the payment amount for the debts and didnt include the new HELOC payment, and lied or didnt understand how income is calculated, by stating the withdrawal made in XX/XX/XXXX, should be divided monthly, instead of annually. When I asked for additional clarification, I was sent a letter from XXXX XXXX, Office of the Chairman stating they couldnt use my 401k income, because they didnt receive the information, but if they did receive it since the money came from 2 different 401k accounts it was unacceptable. I know they received the income information because I spoke to the processor, XXXX XXXX to verify that she would submit the income information. I advised XXXX XXXX, Sales Team Leader in my letters that this information was sent and I resent the information. Also in my phone conversation with XXXX XXXX, when I tried to explain my concerns and prior to him sending me the denial letter he stated that he knew nothing about that department, so he could have only stated what they told him. I asked again to have my request answered, via phone and email, and once again was ignored. Im just asking for a reasonable explanation, and they seem unable to provide it. The 401k income per their guidelines stated a 2-year history of receiving 401k income, and sufficient funds for an additional 3 years income, which I have. The use of 2 different accounts makes no sense if a person has had multiple employers. Its the same source of income. It seems like Im being penalized for not consolidating my 401k accounts prior to withdrawing from them... 

Please help. I would like to see the list of payments, including the new HELOC payment used, as well as the guideline that states use of 401k income from multiple accounts is unacceptable. I have attached my correspondence with Citizens. Please let me know if you need any additional information. 

Cordially, XXXX XXXX XXXX