Consumer complaint received 2025-11-16 00:00:00
Product: Mortgage — FHA mortgage
Issue: Applying for a mortgage or refinancing an existing mortgage — Confusing or misleading advertising or marketing
Company: United Shore Financial Services, LLC
State: TX

Complaint narrative:
United Wholesale Mortgage ( UWM ) submitted a response to CFPB on XX/XX/XXXX that is factually incorrect, legally inaccurate, and contradicts federal law, XXXX mandates, and the documentary evidence attached to this complaint. 

I am filing a new dispute because UWMs explanations are demonstrably false, and the company continues to violate multiple federal housing and financial-fraud statutes tied to my property at XXXX Paloma XXXX, XXXX ( XXXX XXXX XXXX. ), MI XXXX. 

This complaint demands escalation to CFPB XXXX, DOJ, FTC, and HUD XXXX because UWMs conduct constitutes appraisal fraud, falsification of federally related mortgage documents, and the use of unlawful appraisal practices to manipulate contracts and strip homeowners of equity.

1. UWM FALSELY CLAIMED CLASS VALUATION IS NOT AFFILIATED WITH UWM THIS IS MISLEADING AND CONTRADICTS FEDERAL RECORDS UWMs letter states : Class Valuation is an independent XXXX and is not affiliated with UWM.

This is factually false.

FACTUAL EVIDENCE UWM and Class Valuation have long-standing commercial integration, including : exclusive-use relationships preferred-vendor status shared volume pipelines direct routing of UWM orders through Class Valuation Class Valuation has been repeatedly identified in federal litigation and mortgage-industry analyses as one of UWMs primary AMCs, with dependency relationships so significant that functional affiliation exists under federal definitions. 

LEGAL STANDARD Under Dodd-Frank 129E ( 15 U.S.C. 1639e ( k ) ), affiliation is not limited to corporate ownershipit includes business arrangements creating financial incentives that compromise appraisal independence. 

UWMs attempt to disclaim affiliation is legally meaningless and misleading. 



2. UWM FALSELY CLAIMED A LOAN OFFICER PAYING FOR AN APPRAISAL IS COMMON PRACTICE THIS IS 100 % FALSE UNDER FEDERAL LAW Congress explicitly banned this practice.

Under the Truth in Lending Act ( TILA ) as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act, it is illegal for : A loan officer, A mortgage broker, or Any party with a financial interest in the loan to PAY FOR, INFLUENCE, or CONTROL an appraisal. 

CONTROLLING LAW 15 U.S.C. 1639e ( b ) Appraisal Independence Requirements Prohibits : payment, inducement, or coercion by any loan production staff improper influence over the valuation 12 C.F.R. 1026.42 ( c ) ( 1 ) Prohibits a loan originator from : providing compensation or anything of value to the appraiser Congressional Intent ( 2010 House-Senate Conference Report on Dodd-Frank ) Congress expressly stated : Loan officers shall have no role in ordering, paying for, or influencing appraisals.

UWMs claim that this is common practice is a direct lie contradicting federal statute.

Evidence Attached to this complaint is the appraisal invoice showing : UWM loan officer XXXX XXXX XXXX XXXX XXXX card Paying the fee for XXXX XXXX XXXX XXXX acting under a dissolved LLC ( XXXX XXXX XXXX ) This makes the appraisal per XXXX illegal under TILA and Dodd-Frank .

3. UWM FALSELY CLAIMED BROKER PAYMENTS ARE ALLOWED FEDERAL LAW SAYS THE OPPOSITE UWM wrote : The prepayment of an appraisal fee by a mortgage broker on behalf of a client is common practice.

This is absolutely false and violates : 12 C.F.R. 1026.42 ( c ) ( 1 ) ( v ) Prohibits : any thing of value provided to an appraiser by loan originators A broker is legally defined as a loan originator under : 12 U.S.C. 5102 ( 3 ) SAFE Act Therefore : A broker can not legally pay an appraiser.

A loan officer can not legally pay an appraiser.

A loan originators personal credit card payment is a federal violation.

4. UWM FALSELY CLAIMED IT WAS NOT INVOLVED IN ORDERING THE APPRAISAL DOCUMENTS PROVE OTHERWISE UWM attempts to distance itself by saying : Any questions regarding the appraisal should be directed to Class Valuation.

This is deceptive.

FACTUAL REALITY UWM routes all wholesale appraisal orders through Class Valuation.

The appraisal was ordered EXCLUSIVELY for a UWM loan.

UWM controlled the entire underwriting process.

UWM approved the tainted appraisal and used it to pressure a lower contract price.

UWM knew or should have known : the appraiser was operating under a dissolved LLC the XXXX accepted a loan officers credit card the valuation contradicted market comparables That makes UWM responsible for accepting and using a fraudulent appraisal.

5. FEDERAL ENFORCEMENT TRIGGER : UWM USED THE FRAUDULENT APPRAISAL TO ALTER A CONTRACT After receiving the fraudulent undervalued appraisal, UWM : pushed to change the signed {$440000.00} contract attempted to coerce a new price matching the illegal appraisal misrepresented Paragraph 40 of the contract This violates : 15 U.S.C. 1639e ( b ) 12 C.F.R. 1026.42 ( c ) ( 1 ) 12 U.S.C. 5531 ( UDAAP ) Any attempt to influence contractual terms using a tainted valuation is federal mortgage fraud.

6. THIS APPRAISAL FRAUD SCHEME TRIGGERED YEARS OF PROPERTY LOSS AND EQUITY THEFT Because of UWMs unlawful conduct : My sale collapsed I was forced into years of litigation False lawsuits were filed using the fraudulent appraisal as the foundation My property rights were stripped I suffered over $ 1.4M in liens, sanctions, and financial losses I lost full possession of my home This is classic equity theft arising from appraisal fraud.

7. REQUEST FOR CFPB ACTION I request immediate escalation to : CFPB Enforcement For violations of : Dodd-Frank 1639e TILA Regulation Z 1026.42 UDAAP 5531 SAFE Act Mortgage origination rules Department of Justice ( DOJ ) For potential : appraisal fraud wire fraud ( 18 U.S.C. 1343 ) false statements in a federally related mortgage transaction ( 18 U.S.C. 1001 ) Federal Trade Commission ( FTC ) For : unfair and deceptive business practices affecting thousands of consumers.

8. FINAL STATEMENT United Wholesale Mortgage knowingly submitted a false and misleading statement in their XX/XX/XXXX CFPB response. 

The evidence proves : the appraisal was illegally paid for the XXXX relationship was misrepresented the contract was manipulated the consumer was financially destroyed federal law was violated I request immediate oversight, subpoena authority, and federal enforcement. 

Respectfully submitted, XXXX XXXX

Company response to consumer: Closed with explanation