Consumer complaint received 2025-11-21 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: Ocwen Financial Corporation
State: AR

Complaint narrative:
Summary of Complaint I am submitting this complaint because PHH Mortgage engaged in deceptive, misleading, and misleadingly incomplete solicitation practices in violation of the Truth in Lending Act ( TILA ), Real Estate Settlement Procedures Act ( RESPA ), and XXXX prohibitions on Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ).

The PHH loan officer misrepresented loan terms, failed to disclose significant costs, created false urgency, omitted required financial information, failed to assess my needs, and used repeated high-pressure communications. 
Detailed Description of Violations XXXX. Misrepresentation of Upfront Costs ( TILA 1026.17 ( c ) ; Reg Z Accuracy of Disclosures ) When I inquired about the closing costs the loan officer verbally stated that the only upfront cost would be the {$600.00} ( approximate ) appraisal fee. 
The written estimate later provided shows : {$9300.00} due at closing {$5900.00} in discount points ( 2.77 % of loan amount ) Origination charges of {$6700.00} Total loan costs of {$7700.00} These costs were not mentioned at any time during the conversation, violating TILAs prohibition on inaccurate or misleading disclosures. 
XXXX. Failure to Disclose Discount Points ( Reg Z 1026.37 ( f ) ( 1 ) ; 1026.19 ( e ) ) The loan officer quoted a 6.125 % interest rate, representing it as the refinance rate available, without mentioning that the rate required nearly {$6000.00} in points. This is a material omission and constitutes a deceptive act because discount points directly affect the true cost of credit. 
XXXX. Contradictory and False Urgency Claims ( UDAAP ; Reg Z 1026.2 Prohibition on misleading urgency ) The loan officer stated I needed to apply " before Monday '' because the offer was time sensitive. Later in the same call, he claimed the rate was valid through the end of XXXX with is XXXX  days away. 
Creating false urgency is considered a deceptive practice under UDAAP because it interferes with a consumers ability to evaluate options and induces hurried decision-making. 
XXXX. Failure to Assess Borrower Needs or Objectives ( UDAAP Abusive Practices Standard ; XXXX XXXX ( d ) ) The loan officer never asked about my goals, financial objectives, or whether my priority was : lower payment lower interest rate removal of PMI shorter term cash-out vs. rate-and-term Instead, he said PHH was looking for people with an interest rate above 6.5 % to offer them a lower payment and proceeded without any suitability assessment. 
Under UDAAPs abusive standard, a lender must not materially interfere with a consumers ability to understand loan terms or take unreasonable advantage of a consumers lack of understanding. 
Failing to assess goals while presenting a cost-heavy refinance is abusive, because it presents the loan as beneficial while concealing that the structure may not meet the borrowers interests. 
XXXX. High-Pressure and Repeated Contact ( UDAAP ; RESPA 1024.41 ( d ) ) Before and after the call, I received : XXXX voicemails XXXX missed calls All from the same PHH sales line. Please note that the call where I received this verbal offer was made by me returning their calls. 
Screenshots are attached, showing repeated solicitations within a very short timeframe. 
This is consistent with high-pressure sales activity prohibited under UDAAP and discouraged under RESPAs servicing conduct standards. 
XXXX. Verbal vs. Written Discrepancies Showing Systemic Non-Compliance The written disclosures contradicted the verbal statements regarding : Upfront costs PMI status Rate stability Discount points Closing cost structure This constitutes a pattern of deceptive solicitation, prohibited under : TILA 1026.17 Accuracy and completeness of disclosures RESPA 1024.41 Duty for accurate servicer communication Dodd-Frank 1031 UDAAP Regulatory Citations ( Specific Provisions Violated ) Truth in Lending Act ( TILA ) / Regulation Z 1026.17 ( c ) Requirement of accurate and non-misleading disclosures 1026.19 ( e ) Early disclosures ; prohibition of misleading cost representations 1026.37 ( f ) Required disclosure of points, origination charges, closing costs RESPA / Regulation X 1024.41 ( d ) Prohibition on misleading or inaccurate borrower communications 1024.40 Servicer duty to maintain policies ensuring accurate information XXXX  UDAAP ( 12 USC 5531 & 5536 ) Unfair : Substantial injury, not reasonably avoidable, no countervailing benefit Deceptive : Misrepresented or omitted material information Abusive : Interfered with understanding of loan terms ; failed to consider consumers ability to evaluate choices

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 explanation