Consumer complaint received 2025-10-13 00:00:00
Product: Mortgage — FHA mortgage
Issue: Trouble during payment process — Lien release
Company: CITIZENS FINANCIAL GROUP, INC.
State: PA

Complaint narrative:
CITIZENS BANK OF PENNSYLVANIA XXXXXXXX XXXX XXXX XXXXXXXX, Pa, XXXX Loan number # XXXX Transferred after loans maturity date to loan # XXXXXXXX XXXX XXXX XXXX XXXX PA, XXXX CITIZENS NA XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX, SC XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX, Georgia, XXXX Formal Complaint to the CFPB against the legal entities who have serviced my mortgage incorrectly and against the terms in the mortgage/loan agreement after my residential property secured by a lien by CITIZENS NA was remapped into a designated FEMA flood zone in XXXX. 

RE : Written request to CITIZENS NA, RESPA 2605 ( e ) for information regarding the INSURERS ASICs dual roles when providing Mortgage Services on the XXXX XXXX XXXX ( XXXX  ) through the XXXX XXXX XXXX ( XXXX  ) and the business of insurance for the lenders CITIZENS NA to purchase flood insurance on the borrowers behalf if the residential property secured by a lien, had insufficient flood insurance from the residential property remapped into a designated FEMA flood zone, requiring flood insurance. 

CLARIFICATION NEEDED If mortgage servicing is provided by insurers and not the lenders for the business of mortgage/loan servicing, does the protections under the Dodd Frank Act not apply to borrowers because Insurers were appointed by the lender ( CITIZENS NA ) to perform the automatic loan servicing on the XXXX XXXX XXXX ( XXXX  )?

CITIZENS NA is Attempting to limit the scope of my complaint for the errors that occurred during loan servicing with my mortgage on the XXXX, by dismissing my concerns because my concerns are an insurance matter, not a loan servicing matter. 

CITIZENS NA has been obscuring relevant facts and the identity of the different legal entities involved in the XXXX XXXX XXXX  for the mortgage/loans in CITIZENS NA mortgage portfolio that are automatically serviced on the XXXX, in an attempt to keep the scope narrow so the facts in my case become only irrelevant and unfortunate for me, and not direct mortgage servicing violations.

CITIZEN NA has obscured who services the loan by making it appear the insurer XXXX is used for the buisness of purchasing insurance only to be placed on the residential properties in CITIZENS NA mortgage portfolio for the XXXX XXXX XXXX if a borrowers insurance becomes insufficient. 

The insurer XXXX doing business under XXXX is ALSO the mortgage servicer using the XXXX to automatically track and trigger insurance, billing, and escrow on the mortgages/loans in CITIZENS NAs mortgage portfolio. 

There is No disclosure or mention that the insurer has duel roles from either the insurer XXXX or the Lender CITIZENS NA, for SEPARATING the business of selling insurance and the business of mortgage servicing for the XXXX Mortgage XXXX XXXX when using the XXXX. 

No recognition from CITIZENS NA or disclosure from XXXXXXXX XXXX for the duel roles XXXX has as an insurer and a mortgage servicer, allows the insurer ( XXXX ) to provide mortgage servicing for CITIZENS NA that is not regulated under the CFPB because the CFPB lack jurisdiction over insurance, so customers complaints about PROBLEMS with XXXX XXXX are ignored and not regulated because the concerns are complaints regarding insurance, not loan servicing. 

Requesting the names of the individual legal entities and their direct contact information from Citizens NA that serviced my mortgage in the XXXX, and other departments so I can contact each department individually in an attempt to correct the error causing my mortgage to be serviced incorrectly on the XXXX, and against the terms in the loan agreement so the error on the platform could be corrected and the lien on my property could be released from CITIZENS NA, because my mortgage MATURED XX/XX/XXXX and all scheduled payments and late fees have been paid by the loans maturity date. 

I have included CITIZENS NAs disclosure sent from : The Insurance Department that discloses the insurer XXXX employees answer CITIZENS NAS customer service calls, when customers call CITIZENS NAs Insurance department, blurring the lines further as to who is responsible to contact to fix the errors that occurred on the XXXX platform during loan servicing and who is responsible for the 12 unsigned flood insurance policies purchased on my behalf by the XXXXXXXX XXXX XXXX, under XXXX for flood insurance coverage in the amount of {$250000.00}, far exceeding the Lenders CITIZENS NAs security interest of {$58000.00} for the property appraised at {$80000.00} that I am being retroactively charged for from XXXX, and responsible to pay because the residential property is in a designated FEMA Flood Zone and Lenders are required to purchase Flood insurance coverage for properties secured by a lien mapped into a designated FEMA flood zone ; .and the borrower is responsible to pay for the Flood insurance coverage for residential properties secured by a lien mapped into a designated FEMA Flood Zone ; therefore there is nothing to dispute further. 

I am not disputing the flood law and understand I am responsible for flood insurance for my property if mapped into a designated flood zone while the residential property is secured by a lien. I am disputing how my loan was serviced incorrectly against the loans terms, causing a balloon payment owed after my loan matured on a mortgage at a fixed rates at a term of 20 years, with scheduled payments on a fixed amortization schedule that were never increased XX/XX/XXXX the cost for any flood insurance premiums owed, each month when scheduled payments were due until the premium cost was paid in full, as written in the mortgage agreement. 
Instead no disclosures were sent, No Billing, scheduled payments were not increased the amount for the price of flood insurance each month, and escrow was never triggered on the XXXX for an escrow account to be created, resulting in my property secured by a lien held by CITIZENS NA to be in FORCLOSURE after all scheduled payments were made and the loan was paid in full. 

Although the Dodd-Frank Act was enacted to regulate mortgage and loan servicing, those protections do not apply to the mortgage servicing done with my mortgage because the mortgage servicing is done by insurers appointed by CITIZENS NA on the XXXX, and under Frank Dodd insurers are explicitly exempt from CFPB oversight . 

Any information or guidance would be greatly appreciated. 
Regulation X 1024.35 Regulation X 1024.36 TILA 1639f / Reg Z 1026.36 Thank you for your time in this matter. 

XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

Company response to consumer: Closed with explanation