Consumer complaint received 2021-01-02
Product: Mortgage — Conventional home mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — 
Company: WELLS FARGO & COMPANY (CT)

The purpose of this note is to submit my formal complaint of Wells Fargo Home Mortgage unethical practices, the existing lender of my current mortgage. I applied for a refinance loan on XX/XX/XXXX. The loan officer I worked with was XXXX XXXX. He requested the typical documentations required to complete the application including : an appraisal report, which I paid for upfront out of pocket, my credit report, income verification, W2s, and my most recent tax returns. 

I requested a lock rate of XXXX which was approved with an expiration date of XX/XX/XXXX. The standard practices in the industry to request and evaluate borrowers credit score is to request the credit report from all three credit bureaus ( i.eXX/XX/XXXX andXX/XX/XXXXXXXX. My score at each were XXXX, XXXX and XXXX, respectively. Wells Fargo used their own proprietary vendor to determine the middle score, which is different from what other lenders typically do. They used a vendor called Core Logic, which showed my middle credit score significantly lower at XXXX. Because the XXXX is lower than XXXX which is what they considered their benchmark score, I was required to provide 6 months reserve of PITI ( i.e., Principal, Interest, Taxes and Insurance XXXX. The monthly amount was set at {$2100.00}. This {$2100.00} x 6 month equated to {$12000.00}. XXXX XXXX came back to me and requested that I provide a liquid account to show enough reserve of that {$12000.00} figure. 

XXXX indicated that my 401K account would qualify as a liquid asset should I be able to provide and show enough to cover that {$12000.00} figure. I then requested from XXXX, my retirement brokerage, my two most recent statements and a letter outlining what I contributed todate and what my employer contributed to date. The total balance in my retirement account as of XX/XX/XXXX showed a total of {$22000.00}. Of that amount my employer contributed {$11000.00} and I contributed {$11000.00}. XXXX came back and indicated to me that his underwriting team could only use 55 % of what my employer contributed of the {$11000.00} equaling {$6200.00} plus 100 % of what I contributed {$11000.00} for a total of {$17000.00}. At this new calculated amount for the reserve, my total is showing 40 % above and beyond what I am required of the {$12000.00}. 

XXXX XXXX and his manager, XXXX XXXX came back and said that their underwriting team can only use 70 % of my total {$17000.00} total due to market volatility and covid 19 which shows a new total of {$12000.00}. This amount now shows that I am artificially short by {$250.00} of the required {$12000.00} reserve. At this point, I indicated to XXXX XXXX that my retirement account is funded every two weeks and that I would have enough funding in my retirement account by XX/XX/XXXX to cover that {$250.00} shortage. 

XXXX then call me on my mobile at approximately XXXX EST on XX/XX/XXXX to indicate that my loan was denied because I have that shortage of {$250.00}. I indicated to him that I had an updated balance from XXXX that same day, XX/XX/XXXX of {$23000.00} to show more than enough to cover that {$250.00} shortage. He also brought up another item to artificially push the goalpost further ; indicating that my deed needed to be transferred out from my single member XXXX, XXXX XXXX, XXXX which I was able to get done. All of this is to indicate that I met all the criteria that Wells Fargo Home Mortgage required for my loan refinance application, yet I was unethically denied the chance to refinance my mortgage. To make matters worse, I have had this existing loan with Wells Fargo Home Mortgage since XXXX of XXXX. I also refinance the mortgage with them in XXXX and it took less than two months to refinance the mortgage then. Additionally, my financial conditions are significantly better now than they were in XXXX. 

I am writing to appeal this application decline and to request a thorough investigation by the CFPB and other regulatory agencies of Wells Fargo Home Mortgage unethical loan review practices. I strongly felt XXXX XXXX, XXXX XXXX and the underwriting team were constantly changing the requirements as the application was in progress to ensure it would be difficult for me to provide sufficient income and reserves, which I was still able to prove despite their policy changes on the fly.