Consumer complaint received 2026-01-03 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Closing on a mortgage — Closing disclosure or other related disclosures
Company: LD Holdings Group, LLC
State: GA

Complaint narrative:
Referencing XXXX XXXX XXXX XXXX Below has been sent to loanDepot RE : CEASE AND DESIST WRONGFUL FORECLOSURE, DEFECTIVE COLLATERAL, AND IMPROPER FORCE-PLACED INSURANCE Borrowers : XXXX XXXX and XXXX XXXX XXXX XXXX : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX : VA-Guaranteed Mortgage Loan Foreclosure XXXX XXXX : XX/XX/XXXX Force-Placed Insurance Notice : XX/XX/XXXX To loanDepot, LLC : This letter serves as formal notice and demand regarding loanDepots lack of lawful authority to foreclose, improper servicing conduct, and continued reliance on materially defective collateral. 
To loanDepot, LLC : This letter serves as formal notice and demand regarding loanDepots lack of lawful authority to foreclose, improper servicing conduct, and continued reliance on materially defective collateral. 
XXXX. Defective and Clouded Title No Lawful Foreclosure Authority At origination, loanDepot funded this loan based on representations that the collateral consisted of a unified XXXX improved parcel with residence and appurtenances. That representation was false. 
The chain of title contains overlapping conveyances, altered or irreconcilable plats, inconsistent acreage descriptions, and conflicting deeds, including but not limited to : Prior divestment of the homesite before the sellers purported acquisition Competing deeds recorded in different counties Agricultural covenant inconsistencies with residential improvements The plat prepared by XXXX XXXX XXXX, XXXX. No. XXXX, dated XX/XX/XXXX, was relied upon as the defining boundary instrument for the XXXX property. However, this plat was not recorded with any corresponding deed book or page reference, nor does it contain a clerks filing stamp identifying its entry into the official county records. Despite the absence of a properly recorded plat, the property was subsequently placed under a XXXX XXXX XXXX XXXX ( XXXX ), with the covenant instrument recorded on XX/XX/XXXX, and a later bona fide application filed on XX/XX/XXXX. The use of an unrecorded or unindexed plat as the controlling boundary document for acreage certification in support of a XXXX filing raises material concerns regarding professional compliance with XXXX 43-15 and Board Rules, includingbut not limited tosurvey accuracy, proper referencing of antecedent instruments, and the requirement that surveys relied upon for legal or taxation purposes be capable of verification through the public record. The timing and manner in which the XXXX plat was utilized appear inconsistent with the minimum standards for land surveying practice and hinder the ability to reconcile the acreage certified in the XXXX filings with the chain of title and prior recorded instruments. 
Legal descriptions that do not reconcile Trustee deed and limited warranty deed inconsistencies These defects were matters of public record and therefore constitute constructive notice to loanDepot at the time of underwriting and funding. A lender may not disclaim responsibility for defects embedded in the very instruments upon which it bases foreclosure authority. 
Because the security deed is founded upon void or voidable title, loanDepot lacked lawful authority to foreclose. Foreclosure under such circumstances constitutes wrongful foreclosure under Georgia law. 
XXXX. Improper Force-Placed Hazard Insurance Bad Faith Servicing On XX/XX/XXXX, XXXX days before the scheduled foreclosure sale of XX/XX/XXXX, XXXX issued a force-placed hazard insurance notice. This was sent XX/XX/XXXX, to the XXXX XXXX XXXX XXXX property, even though the lender had an updated address on file. I have the screen shot. Further, the letter states it was the second notice, in which we never received the first. The VA valuation officer informed us that a liquidation appraisal was done, however that was sent to an outdated address, an address we lived at back in XXXX, depriving us of notice and opportunity to protect our rights. Neither specific Georgia law nor federal VA regulations explicitly mandate that the servicer ( lender ) provide the homeowner with a copy of the liquidation appraisal during the foreclosure process itself. However, VA regulations state that all appraisal reports and VA value notices are available for inspection or copying by any party on request. We didnt even know one was completed. 
At that time, loanDepot : Knew the property was subject to foreclosure Knew the collateral was defective and disputed Knew ownership would imminently change Imposing lender-placed insurance under these circumstances served no legitimate protective purpose and instead constitutes : Bad-faith servicing Unjust enrichment Improper charges Accounting irregularities The residence and improvements are situated on land subject to competing ownership claims, rendering the collateral uninsurable under standard underwriting practices. Any attempt to impose or charge force-placed insurance with notice of such defects is commercially unreasonable and inequitable. 
XXXX. Failure to Provide XXXX Despite Payment Despite payment for title services at closing, loanDepot has failed to provide a Closing Protection Letter ( CPL ) or produce evidence that XXXX was issued. 
A XXXX is material to determining : Whether the lender or title insurer assumed risk for settlement agent misconduct Whether title defects, altered instruments, or misapplied funds are covered Whether loanDepot exercised reasonable diligence in closing oversight Failure to provide the XXXX after payment further impairs loanDepots position and supports claims of improper closing practices and lack of good faith. 
XXXX. Notice and Demand Accordingly, loanDepot is hereby directed to : Immediately cease and desist from all collection activity related to this loan Suspend any dispossessory coordination, directly or through counsel Refrain from placing or charging force-placed insurance Cease adverse credit reporting related to this foreclosure Produce the Closing Protection Letter ( CPL ) or written confirmation that none exists Preserve all documents, communications, underwriting materials, title files, servicing notes, and third-party vendor records related to this loan Nothing in this correspondence constitutes a waiver of any rights or remedies. All rights are expressly reserved. 
XXXX. Notice Regarding Counsel and Agents Any actions taken by XXXX XXXX XXXX XXXX, XXXX are undertaken solely as agent and stand or fall with the validity of loanDepots foreclosure. If the foreclosure is void or voidable, neither loanDepot nor any purported purchaser holds superior title sufficient to support dispossessory proceedings. XXXX et al., has failed to show superior title. 


Update for CFPB Georgia XXXX XXXX and XXXX XXXX XXXX have received complaint of fraud and misrepresentation and accepted Complaint has passed intake and I have been assigned an investigator for the XXXX XXXX XXXX XXXX XXXXXXXX and XXXX will be going out sometime next week Even though the closing documents are conflicting, and I was charged illegal junk fees, I paid for a XXXX  that no one can present.

Company response to consumer: Closed with explanation