Consumer complaint received 2026-05-05 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — Fees or costs during the application process
Company: CITIZENS FINANCIAL GROUP, INC.
State: TX

Complaint narrative:
FORMAL CFPB COMPLAINT COMPLAINANT INFORMATION Full Name : XXXX XXXX XXXX XXXX XXXX XXXX : XXXX Co-Borrower : XXXX XXXX ( XXXX ) Address : XXXX XXXX XXXX XXXX XXXX XXXX. Date of Complaint : XX/XX/year> FINANCIAL INSTITUTION INFORMATION Institution Name : Citizens Bank , N.A. Primary Contact : XXXX XXXX, Senior Loan Officer ( XXXX ID # XXXX ) Contact Address : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Contact Phone : XXXX Contact Email : XXXX Additional Staff Involved : XXXX XXXX XXXX ( Loan Officer Assistant ), XXXX XXXX, XXXX XXXX Product Type : Jumbo Adjustable-Rate Mortgage ( XXXX XXXX ) Loan Amount : {$990000.00} Closing Date : XX/XX/year> NATURE OF COMPLAINT This complaint concerns Citizens Bank 's failure to honor a verbal and written commitment to match a competitor 's mortgage rate and associated closing costs made at the time of rate lock. The complainant alleges : ( 1 ) deceptive loan officer representations, ( 2 ) bait-and-switch practices involving closing costs, ( 3 ) excessive and unexplained fee loading relative to the competitor offer, and ( 4 ) failure to provide transparent and timely loan cost disclosures. CHRONOLOGICAL STATEMENT OF FACTS XX/XX/year> Competitor Rate Offer Submitted Complainant received a Loan Estimate from XXXX XXXX XXXX XXXX ( XXXX ) for a XXXX Jumbo ARM at 5.875 % interest rate with XXXX points and no escrow. Complainant submitted this offer to Citizens Bank loan officer XXXX XXXX and requested that Citizens Bank match or beat both the rate and the associated costs. XX/XX/year> Citizens Bank written Commits to Match Loan officer XXXX responded : " I can look to match this rate on the 5 year ARM. '' This constituted a commitment to match the competitor offer. Complainant, in reliance on this commitment, held off on locking the rate as Citizens Bank needed additional processing time. Complainant also requested a free float-down option and waiver of the rate lock extension fee neither of which was confirmed as available by Citizens Bank . XX/XX/year> Citizens Bank Acknowledges Rate Match Obligation In written correspondence, XXXX confirmed : " In order to match this rate, we MUST lock in the rate first, then process the matching part. In regards to the fees, our fees will end up being a bit lower, once you factor in the extra {$2500.00} lender credit that we are going to be giving you at closing, on top of the {$10000.00} from XXXX XXXX. '' This email confirmed Citizens Bank 's intent to match both rate and fees. XX/XX/year> XXXX Rate Improves ; Complainant Requests Lock XXXX provided an updated Loan Estimate with a 5.75 % rate, XXXX points, and no major escrow. Complainant formally requested Citizens Bank lock in at this rate and match all costs. Citizens Bank did not lock the rate at this time. XX/XX/year> Citizens Bank Issues Update with XXXX XXXX provided a written update explicitly stating : ( 1 ) matching the exact rate, points, and closing costs is " not guaranteed on every scenario '' ; ( 2 ) Citizens Bank does not offer free float-downs ; ( 3 ) the file was still under compliance review. These statements materially contradicted the earlier commitment to match the competitor offer. XX/XX/year> Loan Estimate Delivered with Inflated Costs Citizens Bank provided an updated Loan Estimate after a compliance review. The costs were dramatically higher than XXXXXXXX XXXX offer. Complainant raised the discrepancy in writing. XXXX responded that Citizens Bank had already " eaten up {$8700.00} in costs '' as a pricing exception, but even after this exception, Citizens Bank 's offer remained far more expensive than XXXXXXXX XXXX. CLOSING COST COMPARISON The following table illustrates the documented cost disparity between the two lenders, drawn directly from Loan Estimates as presented in the email correspondence : Line Item Citizens Bank XXXX Points {$12000.00} {$790.00} Processing Fee {$850.00} {$0.00} Underwriting Fee {$500.00} {$0.00} Appraisal Fee {$870.00} {$800.00} Credit Report Fee {$280.00} {$0.00} Flood Certificate Fee {$7.00} {$0.00} Tax Service Fee {$77.00} {$0.00} Texas Attorney Fee {$170.00} {$250.00} Recording Fee {$150.00} {$230.00} Total {$15000.00} {$2000.00} Lender Credits - {$2500.00} - {$3200.00} Cash to Close {$12000.00} - {$1200.00} Net difference in cash to close : Complainant would pay {$14000.00} MORE with Citizens Bank than with XXXX. Citizens Bank 's cash-to-close is {$12000.00} vs. XXXX 's credit of - {$1200.00} a net disadvantage of {$14000.00}. Additionally, Citizens Bank 's point charge alone ( {$12000.00} ) is 15.7 times higher than XXXXXXXX XXXX ( {$790.00} ), despite Citizens Bank 's claim that it had already applied a pricing exception of approximately {$8700.00}. ALLEGED REGULATORY VIOLATIONS 6.1 TILA / Regulation Z : Good Faith Loan Estimate Requirements Citizens Bank 's Loan Estimate did not reflect the terms that were represented verbally and in writing. Under TILA and Regulation Z ( 12 CFR Part 1026 ), lenders are required to provide good faith estimates of loan costs. The final costs delivered differed substantially from what was communicated, without adequate explanation or redisclosure. 6.2 RESPA : Prohibition on Unearned Fees The fees charged by Citizens Bank particularly the {$850.00} processing fee, {$500.00} underwriting fee, {$280.00} credit report fee, {$77.00} tax service fee, and {$7.00} flood certificate fee which are all {$0.00} at XXXX may constitute charges in excess of actual costs. RESPA ( 12 U.S.C. 2607 ) prohibits the acceptance of fees, kickbacks, or other things of value in connection with mortgage loan referrals or settlements that are not for services actually performed. 6.3 CFPA : Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) Deceptive : Citizens Bank repeatedly communicated that it would match the competitor rate and costs, which Complainant reasonably relied upon in not locking with XXXX. The subsequent delivery of a Loan Estimate with dramatically higher costs constitutes a deceptive practice. Abusive : The unexplained shift in terms from a commitment to match to a unilateral assertion that matching is " not guaranteed '' took advantage of Complainant 's reliance and lack of leverage, given the approaching closing date of XX/XX/year>. Bait-and-Switch : Citizens Bank used the promise of competitive terms to prevent Complainant from locking with XXXX, then delivered materially inferior terms once Complainant was constrained by timeline and the ongoing loan process. 6.4 Possible Fair Lending Concern Complainant notes, in written correspondence, a concern that the inflated rate and costs may be related to the fact that the home builder ( XXXX XXXX ) is providing {$10000.00} in seller credits. Complainant requests the CFPB investigate whether the existence of builder credits influenced the loan pricing in a manner inconsistent with regulatory requirements. HARM SUFFERED Financial harm : Complainant faces an estimated {$14000.00} excess cost compared to the competitor offer that Citizens Bank committed to matching. Opportunity cost : Complainant refrained from locking in with XXXX at 5.75 % with XXXX points based on Citizens Bank 's representations. If forced to proceed with XXXX after delay, rate availability is uncertain. Time and stress : Complainant has spent significant time and effort escalating internally within Citizens Bank, including reaching out to senior executives ( CEO XXXX XXXX XXXX, President XXXX XXXX, and the Office of the Customer ), with no satisfactory resolution as of the date of this complaint. Risk to closing timeline : With a closing date of XX/XX/year>, the ongoing dispute puts the transaction at risk. RESOLUTION REQUESTED Complainant respectfully requests the following relief : 1. That Citizens Bank honor the original commitment to match the XXXX rate ( 5.75 % ) and all associated costs, including XXXX points, XXXX escrow, XXXX processing fee, XXXX underwriting fee, XXXX credit report fee, XXXX XXXX XXXX fee, and XXXX flood certificate fee. 2. That the CFPB investigate Citizens Bank 's loan estimate practices, fee structures, and the consistency between verbal/written representations and final loan disclosures. 3. That the CFPB investigate whether Citizens Bank 's pricing practices in connection with builder-credit transactions comply with RESPA, TILA, and UDAAP standards. SUPPORTING DOCUMENTATION The following documents are available to support this complaint and will be provided upon request : Full email thread between Complainant and Citizens Bank dated XX/XX/XXXX XX/XX/year> ( already printed as PDF and attached herein ) XXXX Loan Estimate dated XX/XX/year> ( 5.875 %, XXXX points ) XXXX updated Loan Estimate dated XX/XX/year> ( 5.75 %, XXXX points ) Citizens Bank Loan Estimate ( updated, post-compliance review ) dated XX/XX/year> Internal escalation emails to Citizens Bank senior executives ( XXXX XXXX, XXXX XXXX XXXX, Office of the Customer )

Company response to consumer: Closed with explanation