Consumer complaint received 2026-05-04 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Trouble during payment process — Private mortgage insurance (PMI)
Company: Valon Technologies, Inc.
State: AR

Complaint narrative:
Supplemental Statement CFPB Complaint # XXXX Re : Valon Mortgage Inc. / XXXX XXXX XXXX I am submitting this supplemental statement to correct a factual error in my original complaint and to clarify and strengthen the arguments presented therein. In my original complaint, I stated that the XX/XX/XXXX appraisal was ordered through XXXX XXXX XXXX XXXX XXXX XXXX. I am correcting that statement. XXXX XXXX XXXX XXXX XXXX PMI department confirmed in writing on XX/XX/XXXX that the appraisal was ordered through XXXX, a third-party vendor, in connection with the partial release transaction not through XXXX XXXX XXXX XXXX XXXX as required for XXXX termination purposes. I was not aware of this distinction at the time of my original submission. This correction does not weaken my complaint. It strengthens it. I. The Cost of the New Valuation Should Be Borne by the Servicer, Not the Borrower The need for a new XXXX-ordered valuation exists entirely because XXXX XXXX XXXX XXXX XXXX servicing department ordered the XX/XX/XXXX appraisal through the wrong channel. XXXX XXXX XXXX ordered the appraisal through XXXX for the partial release transaction when had anyone in XXXX XXXX XXXX XXXX servicing operation coordinated with its own PMI department it would have been apparent that ordering through FanXXXX XXXX XXXX XXXX system would have served both purposes simultaneously. XXXX XXXX XXXX 's own PMI department acknowledged this implicitly. Rather than simply denying my request and closing the matter, XXXX XXXX XXXX XXXX PMI representative XXXX XXXX emailed XXXX XXXX on XX/XX/XXXX to request an exception asking XXXX XXXX to accept the existing XXXX appraisal for PMI removal purposes. His XX/XX/XXXX email to me stated : " I have emailed XXXX requesting that they accept your appraisal for PMI removal. I am now awaiting XXXXXXXX XXXX reply as they hold the pen in this matter. '' This exception request was still active and unresolved when loan servicing transferred from XXXX XXXX XXXX XXXX to Valon Mortgage on XX/XX/XXXX. Standard servicing transfer protocols require the transferring servicer to convey all open requests and pending actions to the successor servicer. Valon inherited not just the loan but an open, mid-process exception request that XXXX XXXX XXXX had initiated on the borrower 's behalf. Whether Valon was made aware of this exception request through the transfer file or not, the borrower should not bear the cost of its abandonment. Valon has required me to pay {$190.00} for a new XXXX without ever indicating whether it reviewed the transfer file for open actions, whether the XXXX XXXX exception request was conveyed at transfer, or whether any attempt was made to continue pursuing it. Under 12 U.S.C. 4902 ( a ) ( 4 ), evidence requirements must be established in advance and communicated to the borrower promptly upon receipt of a cancellation request. The requirement for an XXXX-ordered valuation was not communicated to me at the time of my XX/XX/XXXX request and when it was finally communicated on XX/XX/XXXX, XXXX XXXX XXXX XXXX own response was to pursue an exception rather than simply require me to pay for a new valuation. That response was an implicit acknowledgment that the ordering error was XXXX XXXX XXXX XXXX, not mine. I request that the CFPB direct Valon Mortgage to : ( 1 ) determine the current status of XXXX XXXX XXXX XXXX XXXX XX/XX/XXXX exception request to XXXX XXXX, and ( 2 ) if that exception was not resolved, pursue it to resolution before requiring the borrower to pay for a new valuation. II. XXXX XXXX XXXX Purpose-Specific Valuation Requirement Imposes Unjustifiable Costs on Borrowers I respectfully request that the CFPB consider whether XXXX XXXX XXXX requirement that valuations be ordered specifically through XXXX for MI termination purposes rather than accepting a state-certified appraisal ordered through a XXXX XXXX-approved vendor for a related transaction on the same property constitutes an unfair practice warranting regulatory review. The practical effect of XXXX XXXX XXXX current system is that different transaction types require separately ordered valuations even when completed by the same class of state-licensed appraisers under the same professional standards, on the same property, within the same time period. A full interior and exterior appraisal completed by a XXXX XXXXapproved appraiser through a XXXX XXXX-approved vendor is competent evidence of a property 's market value regardless of which internal XXXX XXXX system generated the work order. The market value of a property does not change based on the transactional purpose for which the appraisal was ordered. This system creates two specific problems the CFPB should examine. First, it produces an outcome that is both absurd and contrary to the HPA 's consumer protection purpose : a borrower can be required to pay for a XXXX an inferior valuation product when a full state-certified appraisal already exists for the same property, solely because XXXX XXXX XXXX internal systems do not share appraisal data across transaction types. The XXXX requires only " evidence that the value of the property has not declined below the original value. '' A full appraisal is self-evidently superior evidence of value compared to a XXXX. Requiring the inferior product when the superior one already exists serves no consumer protection purpose. Second, the system creates a structural information asymmetry that works against borrowers. Servicers know at the moment an appraisal is ordered which channel it is being ordered through and what that channel can and can not be used for. Borrowers do not. In my case, XXXX XXXX XXXX XXXX XXXX servicing department ordered an appraisal that would prove useless for PMI removal without ever informing me of that limitation despite the fact that I had explicitly communicated my intent to use it for PMI removal. The cost of that institutional opacity fell entirely on me. As I wrote to XXXX XXXX XXXX XXXX on XX/XX/XXXX : " The fact that XXXX XXXX XXXX XXXX didn't initiate the appraisal order through the XXXX or the XXXX platform on a request specifically for XXXX XXXX is on XXXX XXXX XXXX XXXX. I'm not concerned that XXXX XXXX accepts appraisals ordered outside their system for some purposes. If they require it for others and there are no drawbacks, they should all be ordered through their system or I should be told up front why not and have the option to choose. '' That remains my position. If XXXX XXXX XXXX internal system requirements serve legitimate purposes, the cost of those requirements should not fall on borrowers who had no knowledge of them and no ability to influence how their servicer ordered the appraisal. I request that the CFPB consider whether guidance or rulemaking is warranted to require servicers to disclose, at the time any property valuation is ordered, whether that valuation will be usable for MI termination purposes and if not, to offer the borrower the option of ordering a valuation that will serve both purposes simultaneously.

Company response to consumer: Closed with explanation