Consumer complaint received 2019-05-11
Product: Mortgage — VA mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — 
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION (CO)

-We applied for a refinance VA mortgage on XX/XX/XXXX telephonically with XXXX XXXX . We explained that we had a modular home that was built on a walkout basement. We took the time to clarify that it was not an on-frame manufactured home. 

- XX/XX/XXXX- We signed the Pre-Disclosure Consent Package electronically. 

- XX/XX/XXXX We received an email from XXXX XXXX with a list of items we were required to upload into the USAA system. We were also notified that we needed to pay {$750.00} for an appraisal. All of which was completed within a matter if days. 

-Received an email from XXXX XXXX on XX/XX/XXXX requesting additional information on our construction loan. 

- Received an email from XXXX XXXX requesting the following information on XX/XX/XXXX : 1. Modular home certification. 
2. Please verify if the modular home is on frame ( built in factory ) or off frame ( Materials brought to site to build ). 
3. Please provide certification of approval by the state of Colorado. 
Materials were provided promptly. 

- Received a phone call on or about XX/XX/XXXX from XXXX XXXX stating that my application was declined because my house was a manufactured On Frame home and USAA does not have a product for such a home. I replied that my home was a modular home built to 2015 IRC standards and that in fact it was not a manufactured home On Frame. I referred to the appraisal which listed all the comps as stick built homes and not manufactured On Frame construction. The appraisal clearly identified that my home was in fact on a walkout basement. 

-Received a phone call from XXXX XXXX on or about XX/XX/XXXX ( with follow up email ) stating that my home considered by  USAA as a manufactured On Frame home and that my application was being terminated since USAA does not have a product for that type of house. I reiterated that it was in fact a modular built to International Residency Code standards as stated in the appraisal. 

-Received an email from XXXX XXXX on XX/XX/XXXX showing an image of a barely legible State Of Colorado Inspection Sticker that USAA believes states my home is a Manufactured On Frame home. In fact, This plate only lists the manufacturer 's name and makes no reference to the type of home being " manufactured '' nor does it reference the home is " on frame ''. This image was included with the appraisal which clearly contradicts USAA 's assertions. 

- A " Manufactured '' home would not have any State Inspection Labels since they are inspected and certified by the US Federal Government. A home can not be considered " on frame '' if it is mounted on a permanent foundation ( clearly identified in the appraisal ). I have provided several documents to USAA, including my County Certificate of Occupancy, which clearly show my home was inspected in accordance with 2006 International Residential Code verifying that it meets all criteria that a similar On-Site constructed home would need to meet ( AKA " stick built '' ). I have also sent USAA images of my home showing that it is on a permanent concrete foundation and therefore could not be on the steel frame that manufactured homes are delivered on. 

I believe that USAA is either grossly incompetent by selecting a single obscure State of Colorado inspection label that only asks for the name of the home 's manufacturer and ignoring the significant additional information contained in the full appraisal. OR they have chosen to discriminate against me because my sole income is currently derived from VA XXXX and Social Security XXXX. I do not reach this conclusion lightly. However, my loan to value meets requirements ( home appraised at {$500000.00} when requested financing is for {$220000.00} ), my credit scores from all three reporting agencies are excellent, and I have been a member of USAA for 30 years.