Consumer complaint received 2016-12-13
Product: Mortgage — Reverse mortgage
Issue: Application, originator, mortgage broker — 
Company: WELLS FARGO & COMPANY (MA)

I would like Wells Fargo to explain my ALLEGED request for information concerning my intent to purchase an annuity as part of my Reverse Mortgage Transaction. 
The Truth in Lending Act requires that we ( the lender ) provide Total Annual Loan Cost Rate disclosures in reverse mortgage transactions. These disclosures include a " good faith projection '' of the total cost of credit, reflecting all costs and charges to me, including the costs of any annuity I purchase as part of the loan transaction. 
The old Reverse Mortgage Products Scam certainly was part of the overall FRAUD perpetrated by Wells Fargo. 
Effective on XX/XX/2010, the Office of the Comptroller of the Currency ( OCC ), the Board of Governors of the Federal Reserve System ( FRB ), the Federal Deposit Insurance Corporation ( FDIC ), the Office of Thrift Supervision, Treasury ( OTS ), and the National Credit Union Administration ( NCUA ) ( collectively, the " Agencies '' ), in conjunction with the State Liaison Committee of the Federal Financial Institutions Examination Council ( FFIEC ), published final guidance in the Federal Register ( Volume 75, Number 158, Pages 50801-50812 ) entitled " Reverse Mortgage Products : Guidance for Managing Compliance and Reputation Risks '' ( " interagency guidance '' ). The interagency guidance applies to all banks and their subsidiaries, bank holding companies ( other than foreign banks ) and their nonbank subsidiaries, savings associations and their subsidiaries, savings and loan holding companies and their subsidiaries, credit unions, and U.S. branches and agencies of foreign banks engaged in reverse mortgage transactions. 

Recognizing that the federal guidance does not cover all reverse mortgage loan originations, the Division of Banks ( the " Division '' ) has developed parallel guidance for licensed mortgage brokers and mortgage lenders in Massachusetts. The Division strongly supports the purpose of the guidance adopted by the Agencies and is committed to promote the uniform application of consumer protections for all borrowers. 

This guidance is intended to promote consistent regulation in the reverse mortgage market and clarify how licensed mortgage brokers and mortgage lenders ( collectively referred to as " Licensees '' ) can offer reverse mortgage products in a way that addresses the unique consumer protection concerns raised by reverse mortgage products. 

In order to maintain regulatory consistency, this guidance substantially mirrors the interagency guidance, except for the deletion of sections not applicable to non-depository institutions and the addition of information relative to Massachusetts specific laws and regulations. 

For these and other reasons, reverse mortgages present substantial risks both to Licensees and to consumers, and, as with any type of loan that is secured by a consumer 's home, it is crucial that consumers understand the terms of the product and the nature of their obligations. While this guidance addresses consumer protection concerns that raise compliance and reputation risks, the Division recognizes that reverse mortgage products may present other risks to mortgage lenders, such as credit, interest rate, and liquidity risks, especially for proprietary reverse mortgage products lacking the insurance offered under the federal Home Equity Conversion Mortgage ( HECM ) program. ( A HECM is a reverse mortgage product insured by the FHA, part of HUD, and is subject to a range of consumer protection and other requirements. See 12 U.S.C. 1715z-20 ; 24 CFR 206. A lender making a HECM loan may assign it to HUD when the outstanding balance reaches XXXX % of the maximum claim amount. See 24 CFR 206.107 ( a ) ( 1 ). ) As explained in further detail below, the complex nature of reverse mortgages presents the risk that consumers will not understand the costs, terms, and consequences of the products.