Consumer complaint received 2026-05-22 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: TD BANK US HOLDING COMPANY
State: MD

Complaint narrative:
XX/XX/XXXX Consumer Financial Protection Bureau ( CFPB ) Re : Complaint Against TD Bank Improper Rate Lock Extension Fee and Inadequate Disclosure Loan No. XXXX To Whom It May Concern, We are submitting this complaint regarding TD Banks imposition of an {$820.00} rate lock extension fee in connection with our mortgage refinance loan ( Loan No. XXXX ). We believe this fee resulted from delays within TD Banks own underwriting and closing process, was not properly disclosed in advance, and was unfairly imposed on us despite repeated documented warnings that the loan timeline was jeopardizing the rate lock expiration date. We have already completed TD Banks internal complaint process, including both XXXX XXXX and XXXX XXXX review. Our complaint was formally denied in a XXXX XXXX Letter dated XX/XX/XXXX from XXXX, Advocate & Customer Experience Analyst, TD Bank XXXX We are therefore requesting CFPB review and assistance. XXXX. Our Specific Concern and the Circumstances Surrounding It We were charged an {$820.00} rate lock extension fee in connection with our mortgage refinance ( Loan No. XXXX ). We believe this fee was caused by delays in TD Banks own final underwriting and closing process, not by any failure on our part, and should be reimbursed. The key facts are as follows : Our mortgage application was submitted on XX/XX/XXXX. TD Bank requested additional documents on XX/XX/XXXX, XXXX, and XXXX. We responded promptly to these requests and continued actively communicating with TD Bank regarding loan conditions and required materials. Final borrower submissions were completed by XX/XX/XXXX. TD Bank issued a conditional approval on XX/XX/XXXX. From that point forward, the process was primarily within TD Banks internal underwriting and closing operations. Throughout XXXX and into XXXX, we repeatedly and explicitly warned TD Bank in writing that ongoing underwriting delays were putting the rate lock expiration date at risk. These warnings are documented. Despite these warnings, final approval was issued only two days after the rate lock expired. The {$820.00} extension fee appeared for the first time in the Closing Disclosure presented to us at the signing table. We had no prior written notice of the charge and no meaningful opportunity to contest it, seek alternatives, or avoid it before it was imposed. We objected to the fee immediately at closing. We were told it could not be removed and that we were responsible for the delay. No documentation was provided to support that conclusion. Our loan officer, XXXX XXXX XXXX, and his assistant, XXXX XXXX XXXX, were aware of the underwriting delays throughout the process and expressed concern about them. It is our understanding that XXXX XXXX supported waiving the fee but did not have authority to do so. This is our third mortgage with TD Bank. We have maintained a longstanding relationship with the institution and acted in good faith throughout the transaction. XXXX. TD Banks Response and Why It Is Inadequate On XX/XX/XXXX, TD Bank issued a Senior XXXX Letter denying our request for reimbursement. In that response, TD Bank stated that : additional information was required during XXXX ; our file was not submitted to underwriting until XX/XX/XXXX ; remaining documents were received on XX/XX/XXXX ; conditional approval was issued on XX/XX/XXXX ; and the loan was processed within 35 days of approval. We respectfully believe this response is incomplete, nonresponsive, and fails to address the central issues raised in our complaint. First, TD Banks response focuses on the wrong period of the transaction. We are not disputing that documents were requested during XXXX or that materials were submitted by XX/XX/XXXX. The rate lock did not expire during that phase. The relevant delay occurred after borrower submissions were complete and after conditional approval was issued, during TD Banks own underwriting and closing process. Second, TD Banks own timeline supports our concern. If conditional approval was issued on XX/XX/XXXX and the loan then required an additional 35 days to process, the delay occurred within TD Banks internal post-approval operations. The response does not identify any borrower action or omission after XX/XX/XXXX that caused the rate lock to expire. Third, the response completely fails to address why final approval occurred only after the rate lock expired, despite our repeated documented warnings about the approaching deadline. This was the core issue raised in our complaint, yet TD Bank did not answer it. Fourth, the response does not address the disclosure problem. The {$820.00} fee was disclosed for the first time at the closing table through the Closing Disclosure itself. We received no revised Loan Estimate, no advance notice of the fee, and no opportunity to make informed decisions before closing. TD Banks letter entirely ignores this concern. Fifth, TD Banks response does not provide evidence that we caused the delay. It simply recites early document requests and concludes that reimbursement will not be provided. No explanation is given as to how those XXXX requests caused a rate lock extension after conditional approval and after the file was already in TD Banks control. XXXX, TD Bank ignored relevant internal facts known to its own staff. Our loan officer and his assistant were aware of the underwriting delays and the risk to the rate lock timeline. It is our understanding that our loan officer supported waiving the fee, which strongly suggests internal recognition that the delay was not attributable to borrower conduct. In short, TD Banks response addresses a question we did not raise whether documents were requested during XXXX while failing entirely to address the question we actually raised : why final approval occurred after the rate lock expired and why the resulting fee was disclosed only at closing. XXXX. Why We Believe TD Bank Acted Improperly We believe TD Banks conduct raises concerns regarding fairness, transparency, and mortgage disclosure obligations. The delay that triggered the fee occurred after borrower submissions were complete and during TD Banks internal processing timeline. We repeatedly warned TD Bank in advance that the rate lock deadline was at risk. Nevertheless, the loan was not finalized before expiration. Moreover, the fee was disclosed only at closing, depriving us of any meaningful opportunity to evaluate, dispute, or avoid the charge before signing final documents. We are concerned this may be inconsistent with the intent and consumer protection purposes underlying RESPA and Regulation Z disclosure requirements. The fee also appears unreasonable under the circumstances. The gap between rate lock expiration and final approval was only two days, and many lenders routinely provide grace periods or waive extension fees where delays arise internally rather than from borrower conduct. XXXX. Resolution Requested We respectfully request that CFPB review TD Banks conduct and assist in obtaining : Reimbursement of the full {$820.00} rate lock extension fee ; A written explanation from TD Bank identifying what specific borrower act or omission allegedly caused the delay beyond the rate lock expiration date ; Clarification regarding TD Banks disclosure practices for rate lock extension fees and whether borrowers are entitled to earlier notice before such fees appear for the first time at closing ; Review of whether TD Banks handling of this matter complied with applicable mortgage disclosure and fair lending obligations. XXXX. Supporting Documentation We are prepared to provide the following supporting materials : Email correspondence documenting our timely responses to all document requests ; Emails warning TD Bank about the risk of rate lock expiration caused by underwriting delays ; Conditional approval letter dated XX/XX/XXXX ; Closing Disclosure showing the {$820.00} extension fee ; TD Banks Senior Officer Letter dated XX/XX/XXXX denying our complaint ; Records of our objection to the fee at closing. XXXX. Contact Information XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, MD XXXX Phone : ( XXXX ) XXXX Email : [ XXXX ] ( XXXX : XXXX ) Co-Borrower : XXXX XXXX XXXX We appreciate the CFPBs attention to this matter and respectfully request review of TD Banks handling of this loan transaction and related fee practices. SincerelyXXXX XXXX XXXX XXXX XXXX XXXX XXXX

Company response to consumer: Closed with explanation