Consumer complaint received 2026-03-18 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: U.S. BANCORP
State: MO

Complaint narrative:
I am submitting this update to my existing complaint ( Case # XXXX ) to add specific federal regulatory violations that have become clear in light of U.S. Bank XXXX XX/XX/XXXX and XX/XX/XXXX responses. XXXX U.S. BANK CAN NOT UNILATERALLY REVOKE A CONFIRMED SUCCESSOR IN INTEREST STATUS On XX/XX/XXXX, U.S. Bank issued a formal written confirmation on U.S. Bank letterhead stating that XXXX XXXX had been confirmed and recorded as Successor in Interest on the account for the property at XXXX XXXX XXXX XXXX, XXXX XXXX, MO XXXX ( Account XXXX ). This confirmation was issued pursuant to the CFPB 's XXXX mortgage servicing rules under Regulation X, 12 CFR 1024.31 and 1024.38. Regulation X contains no provision permitting a mortgage servicer to unilaterally revoke a confirmed Successor in Interest designation including on the basis of the servicer 's own internal processing error. U.S. Bank 's position that the XX/XX/XXXX confirmation letter was 'sent in error ' does not constitute a legally valid basis for revoking confirmed SII status under federal law. Once confirmed in writing, U.S. Bank was and remains legally obligated to treat XXXX XXXX as a confirmed SII with full borrower protections under RESPA 's servicing rules. This is not a technicality. The irrevocability of confirmed SII status was a deliberate feature of the CFPB 's XXXX regulatory design, intended specifically to protect successors in interest from being stripped of their protections by servicer error or servicer convenience. II. FIVE YEARS OF CONDUCT CONSISTENT WITH CONFIRMED SII STATUS U.S. Bank 's own correspondence confirms a pattern of treating XXXX XXXX as authorized and as SII spanning nearly five years : - XX/XX/XXXX : U.S. Bank issues formal written SII confirmation to XXXX XXXX - XX/XX/XXXX : U.S. Bank writes to XXXX XXXX treating him as authorized on the account - XX/XX/XXXX : U.S. Bank issues a settlement letter explicitly addressed to XXXX XXXX XXXX Deceased ) and Successor In Interest XXXX XXXX XXXX for Account XXXX - XX/XX/XXXX : XXXX XXXX wires {$11000.00} in certified funds to U.S. Bank XXXX direct reliance on his written SII status - U.S. Bank accepts the {$11000.00} settlement payment - XX/XX/XXXX : U.S. Bank claims for the first time that SII status was always an error U.S. Bank accepted {$11000.00} from XXXX XXXX explicitly in his capacity as Successor in Interest and then only after receiving those funds informed him his SII status was invalid. This conduct is not consistent with a good faith correction of an administrative error. It is consistent with a servicer using a borrower 's funds and then denying the status upon which that transaction was premised. III. PROMISSORY ESTOPPEL / DETRIMENTAL RELIANCE Even if this Bureau were to find that Regulation X permits revocation of a confirmed SII status in some circumstances, U.S. Bank is independently barred from doing so here under the doctrine of promissory estoppel. The elements are clearly established : 1. U.S. Bank made a clear and unambiguous written promise the XX/XX/XXXX XXXX confirmation letter XXXX. XXXX XXXX reasonably relied on that confirmation for nearly five years, including managing the account, making payments, and ultimately entering into an {$11000.00} settlement in XX/XX/XXXX XXXX. XXXX XXXX suffered concrete and measurable detriment {$11000.00} wired in certified funds based on represented SII status, and now approximately {$4000.00} in escrow refund withheld 4. Injustice results if U.S. Bank is permitted to retroactively deny the status upon which it accepted {$11000.00} IV. RESPA ESCROW REFUND VIOLATION The subject property at XXXX XXXX XXXX XXXX has been sold and the associated mortgage loan has been paid off and closed. Under 12 CFR 1024.34 ( b ), U.S. Bank is required to return any escrow balance within 20 business days of loan payoff. U.S. Bank has refused to issue the approximately {$4000.00} escrow refund in XXXX XXXX 's name. U.S. Bank 's stated reason that XXXX XXXX has not been established as SII is not a valid basis for withholding an escrow refund on a closed, paid-off loan. There is no longer a mortgage associated with this property. Demanding SII documentation as a condition of returning escrow funds on a closed account is circular, unsupported by Regulation X, and is functionally using the escrow refund as leverage in bad faith. V. PATTERN OF MISHANDLING ACKNOWLEDGED BY U.S. BANK IN WRITING U.S. Bank has acknowledged the following errors in its own XX/XX/XXXX responses to this complaint : - Issuing an erroneous SII confirmation letter dated XX/XX/XXXX - Incorrectly informing XXXX XXXX of his SII status during a phone call on XX/XX/XXXX during the exact period he was completing the {$11000.00} settlement - A representative on XX/XX/XXXX mistakenly discussing payoff information without proper verification - A representative on XX/XX/XXXX assisting XXXX XXXX without proper authorization These are not isolated incidents. They represent a multi-year pattern of misrepresentation and mishandling by U.S. Bank that has caused direct and documented financial harm to XXXX XXXX. VI. RELIEF REQUESTED I respectfully request the CFPB direct U.S. Bank to : 1. Recognize that the XX/XX/XXXX written SII confirmation constitutes a binding confirmation under 12 CFR 1024.31 that U.S. Bank lacks legal authority to unilaterally revoke 2. Immediately issue the escrow refund of approximately {$4000.00} in XXXX XXXX 's name as required under 12 CFR 1024.34 ( b ) 3. Acknowledge that the XX/XX/XXXX settlement was entered into and {$11000.00} accepted by U.S. Bank with XXXX XXXX explicitly designated as Successor in Interest 4. Provide a full written accounting of all funds received from XXXX XXXX and all escrow amounts currently held 5. Cease conditioning the escrow refund on SII documentation for an account that has been paid off and closed I have retained and am prepared to produce all relevant correspondence including the XX/XX/XXXX SII confirmation letter, the XX/XX/XXXX settlement letter, the XX/XX/XXXX and XX/XX/XXXX U.S. Bank response letters, and records of the {$11000.00} wire transfer.

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 non-monetary relief