Consumer complaint received 2026-01-02 00:00:00
Product: Debt collection — Mortgage debt
Issue: Written notification about debt — Didn't receive enough information to verify debt
Company: CORELOGIC INC
State: GA

Complaint narrative:
XXXX XXXX  and XXXX XXXX in Mortgage Tax Servicing : The CoreLogic-BAC Nexus Executive Summary : Strategic Context and Definitive Findings The structural transformation of the United States mortgage servicing landscape over the past XXXX decades is epitomized by the strategic nexus formed between XXXX XXXX XXXXXXXX XXXX XXXX ) and CoreLogic. This relationship, fundamentally cemented through a landmark asset divestiture in XX/XX/XXXX, represents a profound shift in the operational philosophy of systemically important financial institutions ( SIFIs ). The identification of " XXXX XXXX XXXX XXXX '' unequivocally points to a former operational unit of XXXX XXXX XXXX XXXX, whose common shares trade under the XXXX symbol " BAC ''. This corporate linkage is the cornerstone for understanding a transactional framework that moved from internal bank management to a highly specialized, scaled third-party processing ( TPP ) model. 
The relationship is not competitive or transactional on a spot-market basis, but rather an established, long-term outsourcing arrangement born from necessity. This arrangement was formalized when XXXX acquired XXXX property tax processing and flood zone determination assets, along with their corresponding operating platforms. Post-acquisition, XXXX rebranded as Cotality in XXXXassumed the primary responsibility as the operational payer to more than XXXX municipal tax authorities. In this capacity, XXXX functions as a specialized TPP, executing the fiduciary property tax obligations retained by XXXX XXXX XXXXXXXX for its massive residential loan portfolio. 
The transaction data reflects the execution of mortgage servicing obligations through XXXX primary capital flows. The most visible flow consists of large, bundled disbursements directed toward specific taxing jurisdictions, such as county treasurers, derived from accumulated homeowner escrow funds. The second, less visible flow involves the internal transfer of fiduciary capital and contractual servicing fees from XXXX XXXX XXXXXXXX to XXXX under the specific XXXX services agreement established during the XXXX asset purchase. This strategic outsourcing decision was fundamentally driven by the need to streamline operations, reduce inherent litigation exposure associated with high-volume tasks, and optimize regulatory capital utilization under the XXXX XXXX XXXX. 
Corporate Identity Disambiguation and the XXXX XXXX XXXX The precise nature of the CoreLogic and BAC relationship is anchored in a definitive strategic transaction that occurred in XXXX. To analyze this relationship, it is first necessary to disambiguate the corporate entities involved. The nomenclature " XXXX XXXX XXXX XXXX '' strongly correlates with XXXX XXXXXXXX XXXX XXXX, as " BAC '' is the definitive organizational identifier used on the XXXX XXXX XXXXXXXX XXXX. This massive financial services unit must be distinguished from smaller, unrelated entities like " XXXX XXXX XXXX, '' which specializes in individual tax returns. 
The transactional relationship began with a major strategic divestiture. On XX/XX/XXXX, XXXX publicly announced the acquisition of flood zone determination and property tax processing services assets from XXXX XXXX XXXXXXXX. This deal, which closed on XX/XX/XXXX, was funded by cash on hand and accompanied by a long-term services agreement. 
Table XXXX : XXXX Acquisition of XXXX XXXX  XXXX XXXX ( XX/XX/XXXX ) | Asset/Function | Seller ( BAC Operational Unit ) | Acquirer ( CoreLogic ) | Resultant Payer Status | | -- -| -- -| -- -| -- -| | Tax Processing Platforms | Internal Servicing Infrastructure | Services Segment Operations | CoreLogic became operational payer to municipalities | | Flood Zone Determination | Internal Compliance Unit | Specialized CoreLogic Unit | CoreLogic became contracted provider for compliance | | Servicing Obligation | Remains with XXXX ( MSRs retained ) | Operational Execution Outsourced | XXXX is the funder ; CoreLogic is the executor | | | Fiduciary Duty | Retained by XXXX | Managed via Agreement | The strategic rationale for Bank of Americas divestiture was rooted in the post-XXXX economic crisis environment. By XXXX, XXXX XXXX  XXXX was grappling with intense regulatory scrutiny concerning its past origination and servicing activities, including extensive litigation related to foreclosure documentation. Divesting complex, high-risk operational business lines was a key component of XXXX 's XXXX to reduce its involvement in non-core functions and mitigate the massive legal fees associated with managing a distressed loan portfolio. 
For XXXX, the acquisition was a move to achieve scale and expand profitability. XXXX XXXX, then XXXX and XXXX of XXXX, stated the deal aligned with the companys imperative of driving scale and operating leverage in its mortgage origination services segment. The integration of XXXX 's operations was expected to create significant revenue growth and margin expansion, effectively making XXXX the " utility '' for XXXX 's tax compliance. 
The Macroeconomic and Regulatory Catalyst : XXXX XXXX and De-Risking The broader strategic implication of this payer relationship serves as a primary case study of the structural changes within the XXXX XXXX services sector following the XXXX crisis. The decision to outsource was not merely operational ; it was a response to the punitive regulatory capital requirements introduced by the XXXX XXXX framework. 
XXXX XXXX and MSR Risk Weighting XXXX XXXX, as implemented by XXXX federal regulators, placed restrictive limits on the amount of Mortgage Servicing Rights ( MSRs ) that could be held by federally regulated financial institutions. Under pre-crisis rules, bank MSR investments were limited to XXXX  % of the common equity component of tier XXXX capital. XXXX XXXX reduced this cap to XXXX %. Furthermore, the implementation significantly increased the risk-weighting of MSRs from XXXX % to XXXX %. 
This regulatory environment transformed MSRs into an exceptionally costly asset class. The " gold plating '' of XXXX risk weights in the XXXX added XXXX percentage points across the board, further incentivizing banks to sell MSRs or, at the very least, outsource the operational mechanics to reduce the overhead and potential for regulatory failure. By transferring the property tax processing function to a non-bank entity like XXXX, Bank XXXX XXXX effectively shifted the operational and compliance burden, paying XXXX to manage the risk while optimizing its own balance sheet. 
XXXX XXXX and Structural Simplification Simultaneously, Title I of the Dodd-Frank Act required large financial institutions to develop resolution plans, or " living wills ''. These plans are intended to ensure that a large bank can be resolved in a rapid and orderly fashion without a taxpayer bailout. Part of this process involves rationalizing and simplifying the company 's legal entity structure by eliminating non-essential internal units. Divesting the tax servicing operations into a contractual XXXX relationship with XXXX supported XXXX 's goal of " Responsible Growth '' by reducing internal complexity and aligning with their risk framework. 
Operational Framework of Mortgage Escrow and Third-Party Processing To interpret the transactional data between BAC and CoreLogic, one must understand the technical mechanism of property tax escrow, commonly known as XXXX ( Principal, Interest, Taxes, and Insurance ). For most residential mortgages, the servicerXXXX XXXX XXXXcollects a portion of the annual property taxes and insurance premiums each month, holding them in a segregated, fiduciary escrow account. 
The Mechanism of Property Tax Escrow The mortgage servicer accepts a fiduciary duty to accurately collect, hold, and disburse these funds to governmental tax authorities and insurance carriers. This duty involves three key components : * Duty of Loyalty : Managing assets solely in the interests of the beneficiaries ( the homeowners and investors ).

* Duty of Care : Exercising a high degree of skill to ensure timely and accurate payments. 
* Duty of Disclosure : Providing complete and accurate information about escrow balances and transactions.

Because property taxes are managed by thousands of highly fragmented local jurisdictions, the process of disbursement is exceptionally complex and prone to error. CoreLogic fills this gap as a specialized TPP, providing a centralized data infrastructure that tracks jurisdictional tax rates, payment dates, and parcel-level property data.

Operational Payer Hierarchy in the Outsourced Model In this outsourced model, the operational hierarchy dictates the nature of the observed payments. Each year, typically around XXXX, the servicer ( BofA ) provides CoreLogic with a list of properties for which taxes are due. The servicer then remits the accumulated escrow capital to CoreLogic. CoreLogic then assumes the role of the physical disburser, sending bulk payments to municipal tax authorities. 
A local government office, such as the XXXX XXXX XXXX, receives the tax payment from CoreLogic, not directly from XXXX XXXX XXXX This transfer of operational liability ensures continuity of service for the bank while achieving risk isolation. XXXX XXXX XXXXXXXX retains the regulatory oversight of the service contract but offloads the manual, error-prone task of tracking thousands of individual tax bills. 
Detailed Analysis of Transactional Flow and Payer Dynamics The payment history data reflects a sophisticated two-way flow of capital governed by the XXXX services agreement. Dissecting this flow clarifies the distinct financial responsibilities of XXXX and XXXX XXXXXXXX XXXX. 
Observed Payments ( CoreLogic as Payer ) When CoreLogic is the originating Payer, the transaction represents a XXXX XXXX XXXX aimed at satisfying local government obligations. These are the final payments in the escrow cycle. CoreLogic aggregates funds for thousands of properties and sends consolidated payments to taxing jurisdictions. The timing of these disbursements is critical, aligning with local due dates and " Economic Loss Dates '' ( ELDs ). CoreLogics proprietary data systems track these localized variances to ensure accuracy. 
Unseen Transactional Flow ( BAC as Payer ) While CoreLogic is the visible payer to the municipality, XXXX XXXXXXXX XXXX acts as the payer in the internal XXXX transactions necessary to fund the operation. This flow has XXXX components : * Escrow Fund Remittance : XXXX XXXX XXXXXXXX transfers the accumulated homeowner escrow capital ( the XXXX & I portion of XXXX ) to CoreLogic. This is a transfer of trust funds, where XXXX takes temporary custody of the funds needed for the tax bill. 
* Servicing Fee Payments : XXXX XXXX  XXXX pays contractual service fees to CoreLogic. This payment stream is CoreLogics compensation for operational administration, compliance management, and platform usage. This component generates the actual revenue and margin expansion anticipated during the XXXX acquisition. 
XXXX XXXX and XXXX XXXX The asset transfer introduced considerable accounting complexity, particularly in managing fiduciary capital. For CoreLogic, the acquisition necessitated adjustments to its cash flow reporting, as its operating activities became linked to managing high-volume escrow accounts. While escrow funds are not revenue, their management requires meticulous reconciliation. 
A key financial mechanism in this model is optimizing the " velocity of money '' or " float ''. Escrow accounts represent a massive, short-term pool of liquid capital. If CoreLogic receives funds from XXXX XXXX XXXX well in advance of the municipal due dates, it gains control over significant working capital for the intervening period. CoreLogics ability to achieve " margin expansion '' is tied to managing this float efficiently, ensuring capital is deployed advantageously before final disbursement.

Technology and Integration : The Digital Tax Portal The relationships sustainability is driven by CoreLogics significant investment in compliance technology. Traditionally, property tax processing relied on manual data handling and XXXX databases. CoreLogic transformed this process by building a Digital Tax Portal delivered to local municipalities.

Features of the Digital Tax Portal The portal centralizes loan and property tax data, providing real-time visibility into tax deadlines and payment status. It allows for : * Near Real-time Agency Connections : Access to data from XXXX agencies, including collector details and payment instructions. 
* Delinquency Risk Tracking : Tracking cut-off dates and collections to ensure correct payments.

* Self-Serve Features : Allowing servicers to update contracts, tax IDs, and legal documents in a few clicks.

* Automated Verification : Tools like Digital tax Connect provide instant access to property tax data through APIs, reducing manual processes and improving customer satisfaction. 
By XXXXXXXX XXXXXXXX % of client decisions were being performed through the portal rather than traditional methods. This digital transformation provides a layer of operational assurance and risk mitigation that XXXX XXXX XXXXXXXX could not achieve with its fragmented legacy internal systems. 
Table 2 : Digital Tax Portal Capabilities and Impact | Feature | Functionality | Strategic Benefit | | -- -| -- -| -- -| | Collector Portal | Electronic viewing and download of payment packages | Transparency and speed of reconciliation | | Tru-Pay Certification | Identifies shortages, overages, and duplicate payments | Mitigation of refund requests and errors | | API Integration | Seamless connection to servicer websites and apps | Reduced call center volume and cost | | Delinquency Monitoring | Real-time tracking of unpaid taxes and tax sales | Protection of the bank 's first-lien position | Operational and Consumer Impact of the Servicing Transition The corporate restructuring between CoreLogic and XXXX XXXX XXXXXXXX had tangible operational consequences, particularly during the transition period of XXXX. Moving massive volumes of data from legacy XXXX systems to XXXX platforms introduced friction points in data fidelity. 
Impact on Escrow Analysis Mortgage servicers are legally required to conduct an annual escrow analysis to ensure sufficient funds are collected. Discrepancies arising from data migrationsuch as inaccurate tracking of local property valuations or delayed recognition of tax increasescan lead directly to flawed analyses. 
Consequences for Homeowners ( XXXX ) A common consequence of operational friction during a servicing overhaul is the occurrence of an escrow shortage. A shortage occurs when the amount collected in the homeowners account is insufficient to cover the actual tax bill paid by CoreLogic. In XXXX and XXXX, former XXXX XXXX XXXXXXXX customers reported significant increases in their monthly payments as the servicer attempted to " catch up '' on these shortages. 
In some cases, homeowners discovered that funds intended for escrow were being incorrectly applied to the mortgage principal, creating a shortage in the tax account. These issues highlight the critical need for high-accuracy processing and the forensic accounting oversight that specialized entities like CoreLogic provide.

Risk and Litigation Context : The Post-Crisis Clean-Up The divestiture of tax servicing was part of a larger effort by Bank of XXXX to resolve the legal overhang of the financial crisis. In XXXX, the bank agreed to a record {$16.00} billion settlement with the Department of Justice to resolve claims related to the packaging and sale of residential mortgage-backed securities ( RMBS ). 
Litigation Pressures and Regulatory Settlements XXXX XXXX XXXX faced numerous lawsuits from state attorneys general and federal agencies like the XXXX. These settlements addressed systemic failures in mortgage origination and servicing, including misrepresentations made to investors and government entities like XXXX XXXX  and XXXX XXXX. 
By outsourcing tax servicing to CoreLogic, XXXX XXXXXXXX XXXX reduced its exposure to future litigation related to property tax errors, which had become a significant source of liability for the bank. This shift allowed XXXX to focus on its " Responsible Growth '' tenets, growing within its risk framework and driving operational excellence. 
Table 3 : Major XXXX XXXX XXXXXXXX Regulatory Settlements ( XXXX ) | Date | Settlement Entity | Amount | Focus Area | | -- -| -- -| -- -| -- -| | XX/XX/XXXX XXXX XXXX XXXX XXXX XXXX$11.00} XXXX XXXX Repurchase and servicing claims | | XX/XX/XXXX | XXXX | {$6.00} XXXX | XXXX litigation and contract claims | | XX/XX/XXXX | DOJ / SEC | {$16.00} XXXX | XXXX fraud and disclosure failures | | XX/XX/XXXX | CFPB | {$720.00} XXXX | Deceptive marketing of add-on products | The Rebranding of CoreLogic to Cotality ( XXXX ) The evolution of the relationship reached a new stage in XX/XX/XXXX when CoreLogic announced its global rebrand to Cotality. This transformation reflects the companys progression from a financial services support provider to a leader in property information and data-enabled solutions. 
Strategic Reasons for the Rebrand The transition from CoreLogic to Cotality was described by XXXX XXXX XXXX as a " transformation with purpose ''. The new name embodies XXXX pillars : * Collaboration and Connectivity : Uniting property professionals and fostering industry relationships. 
* Totality : Delivering comprehensive data and technology across the entire property ecosystem. 
* Vitality : Human-centric innovation and a focus on helping people thrive. 
For mortgage lenders, the rebrand signifies a partner focused on delivering enhanced, AI-driven insights to make home lending as efficient and effective as possible. 
XXXX XXXX for Mortgage XXXX XXXX vision for the future of mortgage servicing involves utilizing billions of real-time data signals to unearth hidden risks and opportunities. This includes : * XXXX XXXX Platforms : Helping institutions consolidate multiple vendor services into a single provider to cut costs and streamline workflows. 
* AI and Automation : Leveraging " CoreAI '' to evolve with the property ecosystem and drive smarter lending decisions.

* End-to-End Solutions : Providing predictive knowledge throughout the loan journey, from marketing and origination to servicing and monitoring. 
As of XXXX, Cotality manages property tax payments for XXXX % of XXXX homes with first liens and serves XXXX of the top XXXX mortgage servicers. Its stable financial outlook is supported by XXXX growth, cost savings, and interest income on cash deposits held in its tax business. 
XXXX XXXX and XXXX XXXX of Cotality Despite the challenges of high interest rates, Cotality has maintained a stable financial trajectory. In the XXXX months ended XX/XX/XXXX, the company reported revenue of {$980.00} XXXX, a modest year-over-year increase. Its revenue and XXXX growth are driven by market share gains and improving efficiency through cost-cutting, including a XXXX % reduction in global office space over the past XXXX years. 
XXXX XXXX and XXXX XXXX Cotality faces significant debt maturities in XXXX and will likely need to refinance its {$5.00} XXXX of debt in early XXXX. XXXX & XXXX XXXX economists forecast that mortgage rates will improve in XXXX and XXXX, which would provide a favorable environment for this refinancing. The companys liquidity remains ample, and it expects to use future cash flow to repay its revolver. 
Table XXXX : Cotality XXXX XXXX and Projections | Indicator | XXXX XXXX Actual | XXXX XXXX Actual | XXXX Projection | | -- -| -- -| -- -| -- -| | Revenue | {$980.00} XXXX | {$980.00} XXXX | Growth via non-mortgage biz | | Debt to XXXX | N/A | XXXX | XXXX ( Improving ) | | Free Operating Cash Flow | Negative | Improving | Positive | | Mortgage Origination Volume | Baseline | XXXX % ( Expected ) | XXXX % ( XXXX XXXX Unknown

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation