Consumer complaint received 2021-03-23
Product: Mortgage — FHA mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — 
Company: CITIZENS FINANCIAL GROUP, INC. (SC)

I would like to file a formal complaint concerning my mortgage refinance application being treated unfairly, causing undue harm. 

On XX/XX/XXXX, I submitted an application for mortgage refinance with Citizens One XXXX Loans. 

On XX/XX/XXXX, I inquired of the loan officer, XXXX XXXX, as to whether the it is the banks policy to accept actual student loan payment or 1 % of total balance as the basis when calculating DTI. He indicated the former when monthly payments are reported. 

On XX/XX/XXXX, I provided documentation to show the prior 24 months of payment history as evidence of the payment amount and timeliness. I also provided the US Department of Education letter of approval for the payment amount for XXXX. The credit report that they pulled also shows the payment being reported prior to the Presidential Administrative Forbearance. 

In response to Presidential Administrative Forbearance issued due to the Coronavirus, my loan servicer placed my loans in automatic forbearance and stopped reporting to the credit bureaus. This was at no fault of my own nor was this at my request. 
The loan officer has indicated that due to the lack of credit reporting, the underwriting rules require that the 1 % of total student loan balance be used as the basis for calculating DTI. As such, this amount greatly exceeds the allowable ratio for approval. In response to this, he requested documentation to show that my student loans are being paid at a lesser amount. 

On multiple occasions ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX ) I have supplied the requested documentation and repeatedly inquired as to the sufficiency of such. Yet, they are insistent upon using the 1 % approach despite my having provided the requested documentation. 

After numerous calls and emails, the loan officer finally responded on XX/XX/XXXX indicating the application will be denied unless documentation can be provided to show the actual student loan payment. Yet again, I provided the requested documentation. 

This process has caused undue harm and financial loss. Due to the extreme and unnecessary delays the following has occurred : Exceeded the allowable amount of time for credit inquires to be consolidated under mortgage rate shopping provisions. As such, an attempt to apply for refinance with another company would require another credit inquiry, thereby lowering my credit score.

Should I apply for refinance with another company, I would be unable to utilize the same appraisal due to the length of time that it took for them to provide my copy. As such, I would have to purchase another appraisal, thereby causing further financial loss. 
The rate lock period has expired while awaiting the loan officers response to my numerous calls and emails. 
Mental and emotional duress caused by the repeated failures to respond to calls, voicemails, and emails. 

This is by far the worst experience that I have had with a lender, and I deeply regret engaging in this process. However, considering the significant loss that I have already suffered, I feel that I must persevere in an effort to prevent further financial loss by starting the process again with another lender.