Consumer complaint received 2020-06-16
Product: Mortgage — Conventional home mortgage
Issue: Trouble during payment process — 
Company: WELLS FARGO & COMPANY (SC)

This will be the third complaint against Wells Fargo - prior complaints have been pushed aside without a care. Wells Fargo has requested additional time in both instances only to arrive at a non-conclusive reply - AND NEVER ANSWER THE QUESTION. 

This time I've found concrete legal ground to present. Complaints will continue to be sent UNTIL WELLS FARGO ACTUALLY PROVIDES AN ANSWER INSTEAD OF IGNORING THE AUTHORITY OF CFPB. Failure to provide an answer will result in me summoning Wells Fargo. 

Wells Fargo has a minimum of {$20000.00} to recast a home mortgage. Most banks are only a quarter of that amount - typically around 5-7k. I've asked why the amount was so high over years - and have never received a proper response. I've contacted XXXX XXXX - who opened an internal investigation - immediately alarmed at how much above normal XXXX is. While XXXX XXXX ultimately agreed with me, they said they are unable to modify any of Wells Fargo 's " overlays ''. 

Wells Fargo has responded by stating " {$20000.00} was what the bank deemed an appropriate amount where a significant difference to the monthly payment would be noticed. '' Yet, this doesn't make sense. A $ XXXX payment on a $ XXXX dollar balance will surely deliver a different impact on the monthly payment than a $ XXXX payment on a {$100000.00} loan .... but somehow Wells Fargo can generically apply this absurd $ XXXX minimum requirement to all outstanding mortages and deem it " the point where an overpayment will present a visible impact on the monthly payment '' ... Wells Fargo has failed to account for the outstanding balance in their reasoning - rendering their decision to set this minimum at $ XXXX. I guess you could argue - it is their policy and they can set it to $ XXXX if they wanted to ... 

I believe what we are dealing with is " Disparate Impact Discrimination '' The ability to recast a mortgage allows Americans to buy monthly flexibility and is an invaluable tool for ALL borrowers. It should not be kept out of reach by outrageous minimums that are apparently set by bogus reasoning without consideration to all loan parameters. 

- The cost of the average house in the US is {$220000.00}. 
- A {$20000.00} overpayment is nearly 10 % of the entire value of the home. 
- A {$5000.00} overpayment WILL have a significant SAVINGS for MOST AMERICANS. 
- Wells Fargo is one of the largest services of US loans. 
- Most Americans living in an average house of {$220000.00} DO NOT have {$20000.00} to throw at their mortgage " Any practices or polices that may not have any discriminatory intent, yet have a disproportionately negative impact on protected classes of individuals are said to have a DISPARATE IMPACT and are still prohibited by law ''. 

Wells Fargo 's CHOICE to set the minimum so high, creates that disproportionate negative impact on MANY AMERICAN HOUSEHOLDS. 

This is a massive disservice to every American household that has their mortgage serviced by Wells Fargo. It is unethical. It is illegal and it is arguably intentional.