Consumer complaint received 2025-07-14 00:00:00
Product: Mortgage — FHA mortgage
Issue: Trouble during payment process — Loan sold or transferred to another company
Company: Alabama Housing Finance Authority
State: NC

Complaint narrative:
I am submitting this new complaint against ServiSolutions / Alabama Housing Finance Authority to follow up on a previously closed CFPB case that has not been resolved. I am requesting that this new filing be reviewed independently, as ServiSolutions prior response was factually inaccurate, legally deficient, and failed to resolve the underlying violations. 

I have a fixed-rate FHA mortgage XXXX originally issued by XXXX XXXX and transferred to ServiSolutions. In 2025, my monthly payment increased by approximately {$70.00}, allegedly due to escrow, without any advance written notice or valid annual escrow analysis. 

I never received a mailed escrow analysis. I have never registered for nor accessed any online borrower portal. The only document Ive received is a PDF that was emailed to me after I complained, long after the alleged XXXX mailing date, and I still have not received a physical copy via U.S. Mail 3 months later. 

Federal law under RESPA ( 12 U.S.C. 2609 and 12 C.F.R. 1024.17 ) requires an annual escrow disclosure and 30 days written notice of any escrow-related payment increase. ServiSolutions failed to provide either.

When I tried to contact ServiSolutions, I experienced unreasonable hold times exceeding 40 minutes, and was unable to reach a live representative. This violates 12 C.F.R. 1024.40 ( a ), which requires prompt access to personnel for servicing inquiries and loss mitigation communication. 

ServiSolutions Prior Response ( XX/XX/year>, XXXX XXXX ) In the prior CFPB response, ServiSolutions misrepresented the facts : They continue to address me as XXXX XXXX in official documents. That is not my name and I have never went by that name. My name is XXXX XXXXXXXX XXXX XXXX XXXX This serious error undermines the credibility of their entire response. If they can not correctly identify the borrower, it calls into question whether the documents were even sent to the correct person or address. 

XXXX XXXX XXXX falsely claimed that the escrow statement was mailed to me in XXXXXXXX XXXX  This is untrue. I never received any physical escrow analysis report, and I still have not received a physical copy, 3 months later, despite multiple requests. 

XXXX XXXX XXXX claimed the statement was available in a borrower portal to which I was formally subscribed. This is also false. I do not have a portal account and have never given electronic consent under the E-SIGN Act ( 15 U.S.C. 7001 ( c ) ). In fact, I explicitly told their representative during our phone call that I do not conduct financial or legal business online and require physical documentation. I informed them at that time that I had never registered an account using their online portal. 

XXXX XXXX XXXX stated the company telephonically discussed the issue with me. That is misleading. I was never fully assisted over the phone and was simply told to wait for documents that never arrived, documents that I should've already received in advance, as required by law. 

XXXX XXXX XXXX excused the long hold times on XX/XX/XXXX as an atypically high-volume day. That is irrelevant. Under RESPA Regulation X ( 12 C.F.R. 1024.40 ), servicers are required to maintain reasonable access to live personnel, not just when its convenient.

I have a documented cognitive disability that requires in-person assistance and physical documentation to effectively manage legal and financial matters.

When I originated my loan with XXXX XXXX I was able to submit payments and speak with staff in person, which was essential to my comprehension and independence. Since the transfer to ServiSolutions ( an out-of-state servicer based in Alabama ), that accessibility has been eliminated. I now have no in-person servicing option, can not receive physical documents reliably, and am forced into a system that assumes digital literacy and access I do not have and am not cognitively able to navigate due to a documented disability.

This creates a barrier to servicing that violates : 42 U.S.C. 3604 ( f ) ( 3 ) ( B ) Fair Housing Act ( failure to reasonably accommodate ) Section 504 of the Rehabilitation Act ( 29 U.S.C. 794 ) Equal access in federally linked housing programs North Carolina General Statutes 168A-4 ( a ) Right to reasonable accommodations in public services 12 C.F.R. 1024.40 Failure to provide accessible servicing personnel Because of these barriers, my cosigner has had to submit payments on my behalf, which has stripped me of my independence and direct access to manage my loan.

Summary of Legal Violations Federal Law ( RESPA / Regulation X ) : 12 C.F.R. 1024.17 ( k ) No 30-day advance written notice of escrow payment increase 12 C.F.R. 1024.17 ( i ) No annual escrow disclosure was mailed 12 C.F.R. 1024.40 ( a ) No prompt access to personnel 12 C.F.R. 1024.35 Covered errors ( wrong borrower name, failure to provide notice, unexplained increase ) 15 U.S.C. 7001 ( c ) No opt-in to electronic communication ( E-SIGN Act ) Fair Housing / Disability Protections : 42 U.S.C. 3604 ( f ) ( 3 ) ( B ) Failure to reasonably accommodate my disability 29 U.S.C. 794 Inaccessible servicing in a federally linked program N.C.G.S. 168A-4 ( a ) Failure to provide reasonable accommodation in service delivery I respectfully ask the CFPB to keep this case open and demand a substantive, verifiable response that addresses these legal violations and resolves the service failures. The prior response did not do so.

Thank you for your attention to this matter. 

Respectfully, XXXX XXXX

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation