Consumer complaint received 2025-12-06 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Problem with additional add-on products or services — 
Company: Royalty Lending Financial Services Inc.
State: CA

Complaint narrative:
CFPB OFFICIAL REBUTTAL Re : CFPB Complaint XXXX ( Royalty Lending XXXX XXXX ) Response to Companys Interim Filing & Misuse of Arbitration Decision I am submitting this rebuttal after reviewing the companys preliminary response and the exhibits they uploaded.

The companys filing is inaccurate, misleading, and does not address the issues in my complaint.

Below are the reasons why the companys argument can not block CFPB oversight.

1. The company falsely claims the XXXX arbitrator can prevent reporting to regulators.

In their interim response, the company quotes a line from the arbitrators decision claiming I was ordered to : Cease and desist from presenting any further claims or complaints to any law enforcement agency or any other agency charged with enforcing the law.

( Preliminary Response, p.1 ) Royalty Lending XXXX XXXX XXXX This is legally unenforceable and directly contradicted by federal law.

Arbitrators have ZERO authority to restrict a consumers right to file complaints with : CFPB FTC IRS State Attorneys General State regulatory agencies ( XXXX, XXXX, Texas AG, etc. ) No arbitrator can override federal rights.

Fact : The CFPB itself states that arbitration agreements and arbitration outcomes do not prevent consumers from filing complaints with the Bureau.

The companys attempt to use the arbitrators language to silence regulatory reporting is inappropriate and itself raises UDAAP concerns.

2. The XXXX  arbitrator had no jurisdiction over the issues in my CFPB complaint.

The arbitrator explicitly states in his written decision ( Exhibit 3 Reasons for Decision ) that : He ruled ONLY on the loan contract dispute, NOT on royalty diversion, NOT on tax misreporting, NOT on licensing violations, NOT on operator misconduct, NOT on unrecorded deed misuse, NOT on diverted suspense funds, NOT on new evidence arising after arbitration.

This alone makes the companys argument invalid.

3. The arbitrator admitted he did NOT have the evidence needed to rule on the issues now before the CFPB.

Their own Exhibit 3 shows : The arbitrator did not review : XXXX operator payment records XXXX  ACH interference Suspense release summaries XXXX misreporting evidence Multi-state licensing evidence County tax confirmations Deed misuse and impersonation of ownership Royalty diversion records XXXX evidence ( received after arbitration ) None of this evidence existed at the time of the XXXX  hearing. 
This is especially important because : The arbitrator states in Exhibit 3 that he was ruling solely on what XXXX XXXX had presented, and could not evaluate oil & gas accounting issues or multi-state regulatory issues.

This makes the arbitration factually and legally irrelevant to my CFPB complaint.

4. The arbitration award CAN NOT block the CFPB from investigating new violations.

My CFPB complaint concerns : Unlicensed lending ( multi-state ) Royalty diversion Operator payment manipulation Tax misreporting ( fraudulent 1099s & 1098s ) Use of an unrecorded deed to impersonate ownership Suspense fund releases without authorization Post-arbitration evidence ( XX/XX/XXXX operator reports ) These issues : Were not presented at arbitration Did not exist at arbitration Were outside the arbitrators jurisdiction Involve regulatory violations the XXXX  can not adjudicate Therefore, arbitration can not preclude this investigation.

5. Exhibit 2 ( Decision ) and Exhibit 3 ( Reasons ) actually SUPPORT the CFPBs investigation.

Exhibit 2 states the arbitrator ruled based only on the loan documents and limited submissions.

Exhibit 3 shows he lacked evidence and expertise to evaluate royalty, tax, and operator misconduct.

These documents confirm that the arbitrator never addressed the issues now before the CFPB.

6. The companys argument is an attempt to intimidate a borrower from reporting misconduct.

Using an arbitration decision to discourage a consumer from reporting : tax irregularities, deceptive lending, misapplication of payments, unlicensed lending, operator collusion, deed misuse, royalty diversion is itself a red flag under UDAAP.

Regulators can not be blocked by private arbitration language.

7. The CFPB, FTC, and state regulators now have the complete evidenceincluding XXXX documentation the arbitrator never saw. 
This includes : XXXX XX/XX/XXXX payment reports XXXX email showing unauthorized ownership manipulation XXXX tax records showing overcharges XXXX and XXXX inconsistencies Unrecorded deed misuse Royalty diversion across multiple operators These materials materially change the factual landscape, making the arbitration decision incomplete and irrelevant for the purposes of regulatory review. 

REQUEST TO CFPB I respectfully request the CFPB to : Continue investigating all issues raised in this complaint Disregard the companys misuse of the cease & desist language Review the post-arbitration evidence now in the CFPBs possession Coordinate with FTC, IRS, Texas AG, California XXXX, Colorado XXXX, and other agencies as needed Arbitration does not limit this agencys authority or my right to report violations.

Thank you for your continued review. 
XXXX XXXX his complaint is related to, but separate from, my prior CFPB complaint XXXX, which the Bureau has closed. I am filing a new complaint because ( 1 ) I have obtained critical new evidence that did not exist at the time of a prior XXXX  arbitration and ( 2 ) the main issues in this complaint involve unlawful fees, misapplication of proceeds, forced insurance, and misrepresented tax and lien charges, not just loan payment not credited.

The lender is Royalty Lending XXXX XXXX XXXX XXXX XXXX XXXX XXXX and affiliates ( Royalty Lending ). The loan was structured as a title/royalty-based loan secured by my oil-and-gas royalties. After I signed and notarized a Special Warranty Deed, the lender : 1. Forced whole-life insurance as a condition for funding. I was required to purchase two whole-life insurance policies and name the lender as beneficiary before receiving funds. Whole-life insurance can not lawfully be required as a loan condition. This is illegal tying and a predatory practice.

2. Misrepresented taxes and used a Special Warranty Deed to fabricate tax obligations. The lender inserted a clause making me responsible for taxes, even though a Special Warranty Deed does not create tax escrow or lien rights. I was charged {$2200.00} for property taxes in multiple Texas counties, but county tax offices later confirmed the lender only actually paid {$300.00}. The difference was kept by the lender.

3. Charged lien-release fees in counties where I own no property. I was charged for lien releases in five Texas counties, including XXXX XXXX, where I do not own any property at all. A lien can not exist where the borrower has no ownership interest. Charging me for releasing a lien that never existed is a fraudulent fee.

4. Delayed funding, reduced disbursement, and charged interest before I received the money. The promissory note was dated XX/XX/XXXX and presented as an {$85000.00} loan, but I only received {$29000.00}, and not until roughly two months later. Funding was conditioned on providing life insurance and delivering the deed. Despite this delay and lower disbursement, interest was charged from day one as if the full amount was funded on the note date.

5. Obstructed payoff and failed to provide accurate payoff statements. I repeatedly requested payoff figures and accounting. The lender delayed, inflated the payoff amount, and never provided a clear, consistent ledger. An internal recap from the lender contradicts the final payoff numbers.

6. Misapplied operator royalty payments and concealed credits. In XXXX XXXXafter XXXX arbitrationXXXX sent me new emails and XXXX files. These documents show royalties and suspense funds released to the lender that were not applied to my loan. There is at least {$7800.00} in missing operator revenue, plus {$860.00} reported on XXXX, along with XXXX XXXX reported under the lenders EIN for income that belonged to me. Some of this revenue was reclassified by the lender as loan advances instead of credits to my balance.

7. New evidence did not exist or was not reviewed during arbitration. The lender is now trying to hide behind a XXXX arbitration decision that occurred before I received the XXXX evidence and before I obtained county tax confirmations. The arbitrator explicitly stated he lacked oil-and-gas expertise and did not have the operator records. Therefore, the arbitration did not and could not address the new evidence or the current violations described here.

I believe these actions constitute unfair, deceptive, and abusive acts or practices ( UDAAP ) and improper loan servicing. I am requesting that the CFPB : Investigate the lenders use of forced life insurance as a condition of credit.

Investigate fabricated tax and lien release charges, including in counties where I own no property.

Require a complete accounting of all operator payments, suspense releases, and credits applied to my loan from XXXX. 
Require the lender to correct any improper XXXX reporting tied to misdirected income.

Order restitution of all improper fees, overcharges, and misapplied payments.

Review whether these practices are being used on other borrowers whose royalties or properties are being used as collateral.

I authorize the CFPB to share this complaint and its exhibits with other federal and state regulators.

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