Consumer complaint received 2026-06-02 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — Loan estimate or other related disclosures
Company: United Shore Financial Services, LLC
State: LA

Complaint narrative:
I am filing this complaint against ( XXXX ) XXXX XXXX XXXX XXXX, a mortgage broker in XXXX XXXX, XXXX ( XXXX # XXXX ), operated by XXXX XXXX ( XXXX # XXXX ) ; and ( 2 ) United Wholesale Mortgage , LLC ( UWM ), the wholesale lender that funded my loan. Both parties engaged in coordinated deceptive and predatory practices in connection with my residential mortgage on XXXX XXXX XXXX, XXXX, XXXX, closed XX/XX/XXXX, Loan ID # XXXX, original principal {$470000.00} at 7.74 % fixed interest, monthly payment {$4600.00}. VIOLATION 1 UNDISCLOSED LENDER-PAID BROKER COMPENSATION My Loan Estimate disclosed only {$2100.00} in origination fees payable to XXXX XXXX XXXX XXXX XXXX My Closing Disclosure provided only at closing, after I was committed to the transaction revealed an additional {$12000.00} listed as Paid by Others ( L ), meaning United Wholesale Mortgage paid this amount directly to XXXX. This payment was never disclosed on the Loan Estimate as required by Regulation Z, 12 CFR Section 1026.37 ( f ) ( 6 ). Total broker compensation on this transaction was {$15000.00}. The {$12000.00} payment from UWM to XXXX constitutes an illegal kickback under RESPA Section 8 ( a ), 12 U.S.C. Section 2607 ( a ). Throughout the loan process, XXXX XXXX verbally represented to me and to my independent witness that she had no financial relationship with UWM. The Closing Disclosure proves otherwise. VIOLATION 2 NO AFFILIATED BUSINESS ARRANGEMENT DISCLOSURE XXXX XXXX verbally represented she was independently shopping lenders on my behalf. Despite this, the Loan Estimate was printed on United Wholesale Mortgage letterhead identifying UWM as the lender. No Affiliated Business Arrangement ( AfBA ) Disclosure was ever provided to me at any point not during application, processing, or closing. Under RESPA Section 8 ( c ) ( 4 ), 12 U.S.C. Section 2607 ( c ) ( 4 ), and 12 CFR Section 1024.15, a mortgage broker is required to provide an AfBA Disclosure before referring a borrower to any settlement service provider with whom the broker has a financial relationship. XXXX failure to provide this disclosure is a per se RESPA violation. XXXX XXXX XXXX XXXX had been in operation only eleven months at the time of closing, with one sponsored mortgage loan originator. It could not credibly have conducted a genuine multi-lender market comparison. VIOLATION 3 ANTI-STEERING AND DENIAL OF RIGHT TO CHOOSE Page 1 of 4 CFPB Complaint | XXXX XXXX | Loan # XXXX When I requested to see competing loan options from other lenders, XXXX XXXX communicated that a competing product was slightly worse and that we would stick with the company that we have. She provided no name of the competing bank, no interest rate, no APR, no formal Loan Estimate, and no written terms from any other lender. She substituted her own financially-motivated judgment she was receiving {$12000.00} from UWM for my legal right to independently evaluate and choose among competing loan products. Under Regulation Z, 12 CFR Section 1026.36 ( e ), a mortgage originator may not steer a consumer to a loan product based on the originators compensation rather than the consumers interest. This is a documented anti-steering violation. VIOLATION 4 FRAUDULENT MISREPRESENTATION OF AUTHORITY On XX/XX/XXXX, when I attempted to independently contact competing lenders to verify rates, XXXX XXXX communicated to me directly : No maam, I speak on behalf of the bank. XXXX XXXX is a licensed mortgage broker, XXXX # XXXX. She has zero legal authority to speak for, represent, or act on behalf of any bank or federally insured lending institution. This statement was made specifically to prevent me from independently verifying the loan terms or contacting competing lenders. It constitutes fraudulent misrepresentation of authority under XXXX Civil Code Article 1953 and implicates 18 U.S.C. Section 709 and the FDIC Act Section 18 ( a ) ( 4 ), which prohibit false claims of banking institution affiliation. This statement has been preserved in writing and is available for production upon request. VIOLATION 5 DEFECTIVE LOAN SERVICING TRANSFER NOTICE On XX/XX/XXXX, I received a loan servicing transfer notice stating that my loan servicer would change from United Wholesale Mortgage to United Wholesale Mortgage. This notice is facially defective. Under RESPA Section 6, 12 U.S.C. Section 2605, and 12 CFR Section 1024.33, a Notice of Transfer of Loan Servicing must identify the NEW servicer by name, address, and telephone number and must be provided no later than 15 days before the effective transfer date. A notice identifying the new servicer as the same entity as the current servicer provides no actionable information and constitutes a per se RESPA Section 6 violation. VIOLATION 6 UNDISCLOSED THIRD-PARTY SUBSERVICER On XX/XX/XXXX, I contacted UWM by telephone. During that call, a UWM representative identified a third-party entity called XXXX as the entity actually servicing my loan on UWMs behalf, stating : This is Fenlar that services United Wholesale Mortgage . XXXX has never been identified in any loan document, Loan Estimate, Closing Disclosure, or any disclosure provided to me at or after origination. I was never informed that a third-party subservicer would be involved in handling my loan. Under RESPA Section 6, all servicing entities must be properly disclosed to the borrower. As of this filing, I do not know FENLARs full legal name, address, NMLS registration number, whether XXXX is licensed to service residential mortgage loans in XXXX, or when XXXX began subservicing my account. VIOLATION 7 UNDISCLOSED INVESTOR : XXXX XXXX During the same XX/XX/XXXX call, a UWM representative stated : Your investors are XXXX XXXX. XXXX XXXX status as investor or beneficial owner of my loan was never disclosed at origination, on the Loan Estimate, or on the Closing Disclosure. Under TILA Section 1638, 15 U.S.C. Section 1638, and Regulation Z Section 1026.18, the identity of the creditor must be disclosed to the borrower. This is a material disclosure failure. Page 2 of 4 CFPB Complaint | XXXX XXXX | Loan # XXXX VIOLATION 8 UWM CAN NOT IDENTIFY CURRENT NOTE HOLDER During the XX/XX/XXXX call, UWMs own representatives gave three different and contradictory answers about who currently holds my promissory note : first, that XXXX XXXX is the investor ; second, that XXXX XXXX had sold the loan but the representative did not know to whom ; and third, that UWM XXXX XXXX XXXX is the current servicer. Three contradictory answers in a single call from the servicers own agents raises a threshold question under UCC Article 3, Section 301 about whether UWM has any legal right to demand and receive mortgage payments at all. I can not safely direct payments to a party that can not confirm its legal authority to receive them. VIOLATION 9 PAYMENT GAP : NO PAYEE AVAILABLE XX/XX/XXXX On the XX/XX/XXXX call, the UWM representative explicitly told me not to make a payment yet because the loan transfer was still in process ; to wait for a notice to arrive by mail ; to call the number on that notice to obtain a new loan number ; and that the account would not be set up until after XX/XX/XXXX. This means there was a minimum five-day period XX/XX/XXXX through XX/XX/XXXX during which no party UWM could identify was available to receive my monthly payment of {$4600.00}. This gap was created entirely by UWMs defective transfer process. Under 12 CFR Section 1024.33 ( c ), a transferee servicer must accept payments from the borrower beginning on the transfer date. UWM failed to establish any mechanism for accepting payment during this period. Any adverse credit notation or late payment designation applied to this account for this period would be improper and retaliatory. VIOLATION 10 PATTERN OF PREDATORY CONDUCT On a separate occasion, XXXX XXXX solicited me to refinance a separate investment property through XXXX XXXX XXXX at 11.740 % interest with a 5-year prepayment penalty. She told me no lender could offer better terms. I independently obtained significantly better financing from XXXX XXXX XXXX XXXX XXXX directly contradicting her representation. XXXX also subsequently disclosed in writing that she had a servicing contract with the current lender containing clawback provisions she had never disclosed to me. This pattern of concealing financial relationships, misrepresenting market conditions, and prioritizing her own compensation over my interests mirrors the conduct on the XXXX XXXX transaction and constitutes a pattern of predatory lending under XXXX Unfair Trade Practices Act, XXXX. XXXX. 51:1401. NATIONAL ENFORCEMENT CONTEXT UWM is currently the subject of an XXXX Attorney General lawsuit filed XX/XX/XXXX alleging an identical broker-capture scheme, with {$25000.00} per deceptive act sought. Federal RESPA claims against UWM for the same type of undisclosed broker compensation arrangement survived a motion to dismiss in the XXXX XXXX XXXX XXXX in XX/XX/XXXX. My transaction fits this documented institutional pattern precisely. WHAT I AM REQUESTING 1. Investigate XXXX XXXX XXXX XXXX ( XXXX # XXXX ) and XXXX XXXX ( XXXX # XXXX ) for RESPA Section XXXX kickback violations, Regulation Z anti-steering violations, compensation disclosure failures, and fraudulent misrepresentation of authority. Page 3 of 4 CFPB Complaint | XXXX XXXX | Loan # XXXX XXXX. Investigate United Wholesale Mortgage , LLC ( XXXX # XXXX ) for paying {$12000.00} in undisclosed broker compensation ; issuing a facially defective servicing transfer notice ; operating an undisclosed subservicer ( XXXX ) ; failing to disclose XXXX XXXX as investor ; and failing to identify the current note holder when directly asked. 3. Order both parties to produce the complete wholesale broker agreement between XXXX XXXX XXXX XXXX and UWM governing compensation for Loan # XXXX. 4. Order UWM to produce : ( a ) the full legal identity, XXXX number, and licensing status of XXXX ; ( b ) the identity of the current legal holder of Loan # XXXX with complete chain of endorsements ; ( c ) a corrected, legally compliant servicing transfer notice. 5. Prohibit any adverse, delinquent, or negative credit reporting in connection with Loan # XXXX during the pendency of this complaint, per RESPA Section 6, 12 U.S.C. Section 2605 ( e ) ( 3 ), and 12 CFR Section 1024.35 ( i ).

Company response to consumer: Closed with explanation