Consumer complaint received 2026-01-28 00:00:00
Product: Mortgage — FHA mortgage
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: CMG Financial Services, Inc.
State: TX

Complaint narrative:
Consumer Response Team Consumer Financial Protection Bureau Re : * * XXXX XXXX XXXX * * Mortgage Servicer : * * CMG Mortgage , Inc. * * Loan Number : [ Loan Number ] Property Address : [ Property Address ] Dear Consumer Response Team, I am submitting this correspondence as a * * third CFPB complaint * * concerning the servicing of my mortgage loan by CMG Mortgage , Inc . This complaint * * incorporates and builds upon my first and second CFPB complaints * * and addresses the * * inadequate and conclusory response provided by CMG dated XX/XX/XXXX * *. 

Despite multiple opportunities to correct or meaningfully address the issues raised, CMG has failed to demonstrate that it conducted a reasonable investigation, corrected servicing errors, or provided a substantive explanation supported by evidence. Instead, CMG has repeatedly relied on unsupported conclusions while leaving material issues unresolved. 

XXXX XXXX XXXX XXXX XXXX I. Failure to Adequately Address Identified Escrow and Payment Application Errors In its XX/XX/XXXX response, CMG asserts that no errors were found in the servicing of my escrow account. However, CMG does not explain how this conclusion was reached or what investigation was conducted.

Specifically, CMG does not explain : * How the initial escrow calculation was evaluated or verified ; * What tax data or assumptions were relied upon ; * Whether escrow projections were reviewed for accuracy ; or * How the servicer determined compliance with applicable servicing requirements.

A conclusory statement denying error, without a substantive explanation of the investigation performed, does not satisfy a servicers obligations under RESPA and Regulation X. XXXX XXXX XXXX XXXX XXXX II. Improper Application of Escrow Funds Prior to First Payment Due Date CMG confirms that a payment received on XX/XX/XXXX was applied to escrow even though the first payment due date was XX/XX/XXXX. This issue was specifically raised in my prior complaints. 

CMG does not explain : * Why escrow funds were applied before a payment was due; * Whether this application complied with applicable servicing, FHA, and RESPA requirements ; or * Whether this issue was reviewed as part of any post-closing or servicing analysis.

This matter remains unresolved and was not meaningfully addressed in CMGs response. 

XXXX XXXX XXXX XXXX XXXX III. Failure to Conduct or Describe a Reasonable Investigation XXXX states that its Compliance Department reviewed the escrow calculation but does not identify : * What review was conducted ; * When the review occurred ; * Who conducted the review; * What documents or data were evaluated ; or * Whether any post-closing or servicing quality control review was performed.

Without this information, CMG has failed to demonstrate that it conducted a reasonable investigation or provided a meaningful explanation of its conclusions, as required by Regulation X.

XXXX XXXX XXXX XXXX XXXX IV. Improper Attribution of Responsibility to Borrower CMG attempts to attribute increased property taxes to my alleged failure to file a homeowners exemption. Even if an exemption was not filed, this does not relieve CMG of its obligation to ensure that escrow calculations were reasonable, accurate, and supported by verified information, nor does it excuse the absence of review to detect and remediate errors.

This explanation does not address the servicing errors raised and does not satisfy CMGs regulatory obligations. 

XXXX XXXX XXXX XXXX XXXX  V. Relevance of HUD Office of Inspector General Audit Findings CMGs unsupported conclusions should be evaluated in light of a recent * * HUD Office of Inspector General audit * *, which found that CMG Mortgage , Inc. * * did not maintain a sufficient quality control program for FHA-insured loans * *. The audit documented failures to properly select loans for review, conduct complete reviews, maintain supporting documentation, and identify material deficiencies.

Given these findings, CMGs assertion that no errors were found lacks credibility absent documented evidence that required quality control safeguards were applied to my loan.

VI. Loan Transfer Does Not Cure Prior Servicing Failures CMG notes that servicing of the loan was later transferred. This transfer does not extinguish CMGs responsibility for origination-period and servicing-period compliance failures, including escrow setup, payment application, and required quality control review.

VII. Pattern of Inadequate Responses and Failure to Remedy Errors This third CFPB complaint is submitted because CMG has now : Failed to correct identified escrow and payment application errors ; Failed to provide a substantive explanation supported by evidence ; Failed to demonstrate that a reasonable investigation was conducted ; Failed to meaningfully respond to multiple CFPB complaints ; and Continued to rely on conclusory statements rather than documented compliance.

Request for CFPB Review I respectfully request that the CFPB : Require CMG Mortgage , Inc. to demonstrate whether my loan was subject to required post-closing or servicing quality control review ; Require CMG to substantiate its compliance conclusions with documented evidence ; and Review whether CMGs repeated failure to meaningfully address these issues constitutes noncompliance with federal mortgage servicing obligations.

Thank you for your continued attention to this matter. 

Sincerely, XXXX XXXX XXXX, XXXX Here is the timeline : | Date | Event | XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  | XX/XX/XXXX | Loan originated and acquired by CMG | | XX/XX/XXXX | Payment of {$3800.00} received ; {$1000.00} applied to escrow prior to first due date | | XX/XX/XXXX | First payment due | | XXXX | Escrow calculations and payment applications disputed | | XX/XX/XXXX | Initial CFPB complaint filed | | XX/XX/XXXX | Second CFPB complaint submitted | | XX/XX/XXXX | CMG issues conclusory response denying errors | | XXXX | HUD OIG audit finds CMG QC program insufficient | Requests for Production All quality control policies and procedures applicable to FHA-insured loans in effect between XX/XX/XXXX and XX/XX/XXXX. 

All documents reflecting whether Plaintiffs loan was selected for any post-closing or servicing quality control review.

All QC review reports, findings, checklists, or audit summaries related to Plaintiffs loan.

All communications referencing escrow calculations or payment application issues for Plaintiffs loan.

All documents reflecting training provided to CMG personnel regarding FHA escrow and QC requirements during the relevant period.

All internal audits, compliance reviews, or corrective action plans addressing QC deficiencies identified by HUD OIG.

Interrogatories Identify all QC reviews conducted on Plaintiffs loan, including dates, reviewers, and findings.

Describe the criteria used to select loans for QC review during the relevant period.

State whether any deficiencies were identified relating to escrow setup or payment application and, if not, explain how compliance was determined.

Company response to consumer: Closed with explanation