Consumer complaint received 2025-04-24 00:00:00
Product: Mortgage — FHA mortgage
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: LD Holdings Group, LLC
State: TX

Complaint narrative:
We are experiencing repeated escrow overcharges from loanDepot on our FHA-backed mortgage. Our monthly payment was significantly increased due to projected escrow shortages, but the figures used do not match actual city/county tax, and insurance costs. 

The servicer has required escrow balances that exceed the 1/6 limit allowed by RESPA. Despite us paying the initial shortage to bring the account to a positive balance, we were told we must maintain a much higher amount " at all times, '' without legal justification. 

Escrow analyses show inconsistent and inflated tax projections, including double in city/county taxes. In one case, our projected shortage increased by over {$5000.00} within 30 days. 

Weve requested explanations and documentation several times, including whether our FHA loan qualifies for escrow removal. Responses have been vague, inconsistent, and in some cases, contradictory. The most recent escrow analysis was not included in the company 's prior response, in my wife 's previously submitted complaint that has since been closed XXXX XXXX XXXX. We are submitting this new complaint with updated evidence showing the continued mismanagement of our escrow account and possible RESPA violations. 

Their response cited increased taxes and insurance, but did not explain why they required escrow balances well above the RESPA 1/6 limit. They also provided an outdated escrow analysis and ignored the most recent one, which projected a shortage of over {$4700.00} despite actual tax records showing significantly lower amounts. 

Additionally, it appears the servicer is carrying forward or rolling over previous shortages into each new analysis, rather than resetting based on current disbursements. This practice inflates projected escrow requirements and creates an ongoing cycle of overcollection, even when payments are current and the account has a positive balance. 

1. They did not address our core legal concern. 
Their response justified increases with insurance/tax hikes but did not explain why escrow buffers exceeded the 1/6 RESPA limit XXXX 

Attached shows that they used inflated or outdated figures. 

2. They cherry-picked which documents to include. 
They referenced disclosures and provided an old escrow analysis, but not the most recent one which further inflated our shortage. 

That undermines their credibility and supports the claim of manipulation or misrepresentation. 

We understand that our loan disclosures may include language stating that escrow balances and payments can be adjusted. However, no clause or fine print in a loan agreement can override federal law. 

Under RESPA ( 12 U.S.C. 2605 ( g ) ), servicers are prohibited from requiring an escrow cushion greater than 1/6 of the annual disbursements ( i.e., no more than two months ' worth ). 

Regardless of what was disclosed during loan application, federal law takes precedence, and we believe the escrow balances required by our servicer have consistently exceeded this legal limit. 

We are requesting that our escrow account be brought into compliance with RESPA and that any overcollections be corrected or refunded accordingly. 

3. We have organized evidence. 
Our 3-part packet shows a consistent pattern of overcollection, unexplained forecasting, and contradictory statements from their agents ( like the FHA escrow removal contradiction ). 

I have attached a detailed packet, including : Official county tax statements All escrow analyses ( including the most recent ) CFPB response from closed complaint and call logs We are still requesting an investigation into whether their practices violate RESPA, and whether we are owed a correction or refund for overcollection.

Company response to consumer: Closed with explanation