Consumer complaint received 2015-05-08
Product: Debt collection — Mortgage
Issue: Disclosure verification of debt — Not given enough info to verify debt
Company: Real Time Group, Inc. (CA)

There is a XXXX lien attached to my property which is currently owned by XXXX XXXX XXXX ( XXXX ) and being serviced by a third party collection company by the name of Real Time Resolutions ( RTR ). On XXXX XXXX, XXXX, I issued a qualified written request ( QWR ) to RTR under Section XXXX of the Real Estate Procedures Act ( RESPA ). Once RTR exceeded the 30 day allotment of time in which to provide a complete response to my QWR they were contacted on multiple requests, to no avail.Finally on XXXX XXXX, XXXX, I received an incomplete response to my original QWR request from XXXX XXXX, XXXX. The incomplete documents that 've been supplied with have since been reviewed and raise a number of questionable elements in relation to the origination of my loan. The issues that were identified questions the very foundation of the originator 's intent to embody integrity, fiduciary responsibility and overall preservation of net tangible benefit to me and the future of my property.In fact, it appears that my loan was originated just weeks before a highly publicized XXXX XXXX Mortgage XXXX XXXX XXXX XXXX XXXX of XXXX, CA, closed its doors due in part to increasing extensive legal fees, and pending litigation cases for the origination of thousands of fraudulent residential mortgage loans. I have expressed my concerns with RTR and in turn they 've consulted with the lienholder XXXX. However, no consideration has been communicated to me from either organization in regards to these unbeknownst issues ; or what appears to be intentional egregious underwriting errors. According to the Truth in Lending Act ( TILA ) a creditor may also violate TILA by engaging in fraudulent, misleading, and deceptive practices that conceal the TILA violation occurring at the time of closing. Like many other homeowners and consumers, I did not discover any violation until after these illegal practices were already imposed by GPMF. These practices are publicly noted and play a key role in this country 's foreclosure process.Concern # 1 ~ Inflated Appraisal According to the ( XXXX ) Uniform Residential Loan Application, there is a claim that my home was worth {$1.00} Million at the time of closing. This amount is grossly inflated, apparently in order to be able to fit it into legal Loan to Value ( LTV ) limits. I have verified with local relators that my particular home has not exceeded more than $ 800k, even at the height of the housing market XXXX and XXXX. My home was purchased in XXXX in the amount of $ XXXX and it is highly unconceivable that there were gains in upwards of an additional $ 700k to support such a claim by XXXX Clearly this is a Home Ownership and Equity Act ( HOEPA ) and US Federal Trade Commission Act 15 U.S.C. 45 violation.Concern # 2 XXXX Failure to Provide Appraisal There is no Appraisal Report in which to analyze, nor to support the estimated value of {$1.00} Mil. Further questioning is whether or not XXXX placed any adherence to LTV underwriting guidelines at the time of closing. RTR advised there is no appraisal within their possession upon questioning the incomplete QWR response.Concern # 3 ~ Equity Stripping Due to my loan value being grossly inflated by XXXX, my home was stripped of future equity gains and my LTV was immediately forced into the negative as far as value was concerned ; once the consummation of the loan was final. OCC Advisory Letters XXXX and XXXX as well as XXXX CFR part XXXX, subpart C strictly prohibiting equity stripping ; and the Interagency Appraisal and Evaluation Guidelines, OCC Advisory Letter XXXX ( XXXX XXXX, XXXX XXXX .Concern # 4 ~ Failure to Provide Allonge to Evidence Transfers RTR and BAC have also failed to provide the Allonge to evidence original and all subsequent transfers from GPMF XXXX XXXX ( XXXX ) and from XXXX to XXXX. Also, there has been no Allonge to evidence transfer to RTR for servicing rights and collection purposes.