Consumer complaint received 2025-07-29 00:00:00
Product: Mortgage — FHA mortgage
Issue: Closing on a mortgage — Closing disclosure or other related disclosures
Company: Guild Holdings Company
State: TX

Complaint narrative:
I am submitting this complaint to formally report loan origination fraud and regulatory violations committed by Guild Mortgage, XXXX XXXX XXXX XXXXXXXX, and senior loan XXXX XXXX XXXX ( XXXX  # XXXX ) during the federally insured FHA loan closing on XX/XX/XXXX. These violations occurred under XXXX direct oversight and include breaches of TRID disclosure rules, FHA lending standards, IRS reporting obligations, and facilitation of a transaction involving an unlicensed brokerage. 
Given the factual record and the supporting documentation I have submitted, the only possible defense would require intentional disregard of federal law and willful blindness to documentary evidence. I respectfully request that the CFPB and Texas Department of Savings and Mortgage Lending ( SML ) initiate a full investigation and provide a detailed, written explanation for any decision not to refer this matter for enforcement action and federal audit. 
Summary of Violations : XXXX. Use of Unlicensed Brokerage ( Cease and Desist ) On XX/XX/XXXX, the Texas Real Estate Commission ( TREC ) issued a formal Cease and Desist Order against XXXX XXXX XXXX XXXX XXXX, confirming it was never licensed to operate as a brokerage in Texas. Despite this, my federally insured FHA loanoriginated under the supervision of Guild Mortgage XXXX XXXX XXXX XXXX XXXX ( XXXX  # XXXX ) included a {$9400.00} real estate commission paid to XXXX XXXX XXXX XXXXXXXX, a name that is both misspelled and unlicensed. This commission was authorized by XXXX and her partners at XXXX XXXX XXXX XXXX, using federal funds in direct violation of FHA, HUD, and Texas Occupations Code. XXXX was the senior mortgage professional responsible for loan approval and document review. It was her duty to confirm the legality of all parties listed on the Closing XXXX and XXXX XXXX XXXX. Her failure to recognizeor willful decision to ignorethe fraudulent brokerage listing constitutes a fatal loan-level violation that invalidates the FHA insurance XXXX. This is not a technicality ; it is origination fraud, carried out under her watch. On page XXXX of my XXXX XXXX XXXX, a {$9400.00} commission is paid to XXXX RESIDENTIAL EQUITY, XXXX unlicensed entity never registered with XXXX. On page XXXX of the Closing Disclosure ( Contact Information section ), XXXX XXXX is listed as broker operating under XXXX XXXX XXXX XXXX ( note : incorrect spelling on the document ), further demonstrating the lack of legal standing of this entity. Next to this fake brokerage name, the document lists Texas license number XXXX, which is XXXX personal broker license, not a brokerage licensemaking the substitution both inaccurate and unlawful. No licensed professionalnot XXXX XXXX, not settlement agent XXXX XXXX, not listing agent XXXX XXXX, and not supervising broker XXXX XXXX of All City Real Estateflagged or corrected this obvious regulatory violation. Despite the presence of a fake, misspelled brokerage name and an incorrect license number, the loan was funded and closed with no objections from XXXX Mortgage or XXXX herself. My complaint to XXXX triggered an official investigation, which determined that XXXX XXXX had been operating under the unlicensed name XXXX XXXX XXXX, XXXX for over 3 years, illegally conducting brokerage activity without a valid license. TRECs Cease and Desist Orderissued within 10 days of my reportconfirmed the fraud and cited violations under Texas XXXX XXXX XXXX, ordering the entity to immediately cease all real estate operations. Please be advised : The name XXXX XXXX XXXX XXXX listed on my federally regulated Closing Disclosure has now been confirmed to be an illegal, unlicensed brokerage. The XXXX loan file processed by XXXX XXXX XXXX this entity despite its illegality and despite being paired with a personal brokers license number ( XXXX ), in clear violation of XXXX, FHA, and state law. This matter can not be siloed as a real estate issueit is a direct loan origination failure involving XXXX Mortgage and XXXX XXXX as certifying loan XXXX. I formally request that the Consumer Financial Protection Bureau ( CFPB ) initiate a full-scale investigation and enforcement review into the systemic use of a fake and unlicensed brokerage across multiple real estate transactions. This is not limited to government-backed loans. It includes every transactionconventional or otherwisewhere XXXX XXXX XXXX ( or any variant spelling ) appeared on a legally binding mortgage document. This request specifically calls for review of : All mortgage transactions in which XXXX XXXX XXXX ( or any misspelled variant ) is listed as the brokerage entity ; Any loan involving XXXX XXXX Texas real estate broker license ( # XXXX ), whether as a primary agent or as supervising broker ; Every transaction involving agents sponsored by XXXX XXXX, including but not limited to : XXXX XXXX XXXX XXXX ( License # XXXX ) XXXX XXXX ( License # XXXX ) XXXX XXXX XXXX ( License # XXXX ) All closings facilitated or overseen by Guild Mortgage XXXX XXXX XXXX XXXX ( XXXX  # XXXX ) in which the unlicensed brokerage was listed or received commission payment. The attached documentation shows that for over XXXX years, XXXX XXXX and his sponsored agents used a fake brokerage name that was neither licensed nor authorized, and XXXX XXXX closed loans under that name without objection or correction. The CFPB can not defer this to real estate boards or state commissions alone. These violations occurred during the origination and funding of mortgage loanssquarely within federal lending oversight. Consumers were exposed to illegal actors under the guise of a licensed ecosystem. This warrants a federal audit of all transactions linked to the unlicensed entity, and all Guild Mortgage loans closed under XXXX XXXX authority. XXXX. Coercive Funding Pressure Immediately After XXXX Delivery On XX/XX/XXXX, at XXXX PM, I received my Closing Disclosure ( CD ) via email from XXXX XXXX, Senior Loan Officer at Guild Mortgage ( XXXX  # XXXX ). Within the body of the same email, XXXX XXXX instructed me to send the wire transfer for closing immediately, despite the XXXX being freshly issued that same day. This direct instruction violated the federally mandated three-business-day waiting period under TRID ( TILA-RESPA Integrated Disclosure ) rules, which require that borrowers be given time to review, ask questions, and make an informed decision prior to funding. Only XXXX minutes later, XXXX XXXX of XXXX XXXX XXXX XXXX sent XXXX separate emails in rapid succession ( within XXXX minutes ), escalating the pressure : Urging me to wire the funds without delay ; Requesting confirmation of message receipt ; Demanding a quick response despite the rushed timeline. 
Then, on Sunday, XX/XX/XXXX at XXXX XXXX, XXXX XXXX emailed me again, stating : I know you didnt receive your Closing Disclosure until Friday late afternoon Would you like to go over it this afternoon before you send your funds to title and close tomorrow? 
This direct quote confirms that Guild Mortgage was aware of the late CD delivery and still expected me to fund and close the next business dayMonday, XX/XX/XXXX, XXXXviolating the required TRID waiting period. 
This was not a clerical error or scheduling mix-up. It was a coordinated effort by XXXX XXXX and XXXX XXXX to pressure me into prematurely funding the loan, without allowing the mandatory review period to elapse. 
These actions directly subverted TRID regulations and robbed me of my federally protected right to review the terms of my loan. The rushed timeline also precluded me from catching the false and fraudulent elements that later emerged, including the use of an unlicensed brokerage, mismatched license numbers, and falsified contractor documentationerrors that I may have uncovered if not pressured to close under duress. Falsified Down Payment Contribution ( Undercounted and Misapplied ) My Closing Disclosure does not reflect the full down payment contribution I made, nor does it comply with FHAs 3.5 % minimum investment rule. This failure was validated and approved by XXXX XXXX ( XXXX # XXXX ), who originated and structured this loan as Guild Mortgages responsible officer. On Page XXXX of the CD, in the Calculating Cash to Close table, the line Down Payment/Funds from Borrower shows {$5700.00}, both in the Loan Estimate and Final columns. This figure equals only 1.81 % of the {$310000.00} purchase price. FHA XXXX XXXX requires a minimum 3.5 % investment equal to {$11000.00} in my case. I brought {$19000.00} to closing ( see Page XXXX, Section XXXX, Cash to Close From Borrower ), which easily met the requirement. However, only a small portion of this was recorded as down payment. The rest was miscoded under general closing costs and never attributed to equity. 
There is no gift letter, no grant, and no supplemental sourcing in the file to reconcile this discrepancy yet the loan was submitted as FHA-compliant and HUD-insurable. 
This constitutes a face-value origination defect that XXXX XXXX and XXXX XXXX certified without correction. 
This Was a XXXX, XXXX XXXX XXXX XXXX gift letter appears in the record. 
No documented 3.5 % investment is present in XXXX XXXX, XXXX, or the HUD-endorsed settlement summary. The CD shows : A {$310000.00} sale price A {$300000.00} loan amount This structure implies only {$5700.00} in equity just 1.81 % far below the required FHA minimum. That figure was then misclassified and never disclosed as borrower-contributed equity. Systemic Failure : HUD, FHA, and XXXX XXXX This is not just an internal paperwork error. It is an open-record violation involving multiple parties : XXXX XXXX XXXX and approved a loan with a falsified equity structure. XXXX XXXX signed off and certified the figures. Guild Mortgage submitted the file for FHA endorsement. FHA and HUD issued an insurance certificate based on false down payment reporting. No HUD underwriter or post-closing reviewer caught the fact that my equity was below 2 % and that no source documentation was included. This is not a back-end calculation dispute. It is a bold-font, first-page violation of TILA/RESPA-integrated disclosure law and FHA insurance rules. It exposes the federal government to insured risk based on false borrower certification and it happened under XXXX XXXX direct supervision and signature. 
IRS Form 1098 + Closing Disclosure Down Payment Misrepresentation The IRS Form 1098 filed for my XXXX mortgage loan contains multiple material misrepresentations about my borrower contribution, supporting the false appearance of 100 % financing. These misstatements were reinforced by a falsified Closing Disclosure, certified by Guild Mortgage XXXX XXXX XXXX XXXX ( XXXX  # XXXX ), and jointly enabled by XXXX XXXX XXXX XXXX. 
IRS Form 1098 Misreporting Box 2 of my XXXX Form XXXX lists {$300000.00} as the mortgage origination amount, but fails to acknowledge that the contract purchase price was {$310000.00}. 
This gap creates the illusion that the entire property value was financed when in fact, I brought over {$24000.00} to closing. 
Specifically omitted from the XXXX : {$5000.00} XXXX money deposit ( shown in CD Page XXXX, Line XXXX Deposit ) ; {$19000.00} in final funds wired to title ( Page XXXX, Section XXXX Cash to Close From Borrower ) ; Total borrower contribution : {$24000.00}, exceeding FHAs required 3.5 % minimum ( {$11000.00} on {$310000.00} purchase ). 
XXXX XXXX Manipulation ( Points Paid on Purchase ) My XXXX Form XXXX, XXXX XXXX, reported {$6100.00} in points paid. 
However, in XXXX and XXXX, this field was changed to {$0.00} with : No corrected XXXX issued ; XXXX XXXX box checked ; No explanation filed with the IRS. 
Per the IRS Form 1098 Instructions ( Rev. XX/XX/XXXX ), any year-over-year correction to XXXX XXXX must be clearly marked as Corrected to avoid borrower misreporting and preserve HUD compliance XXXX That never occurred. These omissions supported the false narrative that I made no material payment toward the purchase a fiction disproven by both wire records and the original CD totals. CD Conflicts and FHA Contribution Fraud. The Closing Disclosure ( CD ) was internally inconsistent and misleading : On Page XXXX, under Calculating Cash to Close, Line XXXX : Down Payment/Funds from Borrower = {$5700.00} This amount equals 1.81 % of the purchase price well below the FHAs 3.5 % minimum requirement. Nowhere on the CD are the full {$24000.00} XXXX brought to closing properly categorized as a down payment or borrower contribution.There is no gift letter, no grant record, no cash-sourcing supplement and yet the loan was submitted to HUD for FHA endorsement and insurance as compliant. XXXX XXXX originated, validated, and funded this loan without disclosing that the required borrower equity was undocumented and unverified.Selective Accuracy Exposes Intent - Despite the false Closing Disclosure date of XX/XX/XXXX, both : The IRS Form XXXX and The homeowners insurance policy reported the actual, correct closing date : XX/XX/XXXX. This proves that the correct timeline was known and used in third-party filings but was intentionally falsified on the CD to fabricate TRID compliance ( which requires XXXX business days between CD delivery and consummation ). 
This inconsistency invalidates any clerical error defense and shows that : The actors involved knew the real closing date, but Chose to falsify the CD date to backdate borrower disclosure and avoid regulatory consequences.Summary : Systemic Reporting Fraud - This was not a paperwork oversight it was a cross-agency scheme to falsify borrower equity, delay disclosure timelines, and suppress FHA audit triggers : The CD omitted proper documentation of the 3.5 % borrower investment. IRS Form 1098 misrepresented down payment, points, and loan-to-value structure. Falsified Down Payment Contribution ( Undercounted and Misapplied ) - My Closing Disclosure does not reflect the full down payment contribution I made, nor does it comply with FHAs 3.5 % minimum investment rule. This failure was validated and approved by XXXX XXXX ( XXXX XXXX XXXX ), who originated and structured this loan as Guild Mortgages responsible officer. On Page XXXX of the CD, in the Calculating Cash to Close table, the line Down Payment/Funds from Borrower shows {$5700.00}, both in the Loan Estimate and Final columns. This figure equals only 1.81 % of the {$310000.00} purchase price. FHA XXXX XXXX requires a minimum 3.5 % investment equal to {$11000.00} in my case. I brought {$19000.00} to closing ( see Page XXXX, Section XXXX, Cash to Close From Borrower ), which easily met the requirement. However, only a small portion of this was recorded as down payment. The rest was miscoded under general closing costs and never attributed to equity. There is no gift letter, no XXXX, and no supplemental sourcing in the file to reconcile this discrepancy yet the loan was submitted as FHA-compliant and HUD-insurable. This constitutes a face-value origination defect that XXXX XXXX and XXXX XXXX XXXX XXXX correction. This Was a XXXX, XXXX XXXX XXXX XXXX gift letter appears in the record. No documented 3.5 % investment is present in XXXX XXXX, XXXX, or the HUD-endorsed settlement summary. The CD shows : A - {$310000.00} sale price B- {$300000.00} loan amount This structure implies only {$5700.00} in equity just 1.81 % far below the required FHA minimum. That figure was then misclassified and never disclosed as borrower-contributed equity. Systemic Failure : HUD, FHA, and Post-Closing Audit - This is not just an internal paperwork error. It is an open-record violation involving multiple parties : XXXX XXXX XXXX and approved a loan with a falsified equity structure. XXXX XXXX signed off and certified the figures. XXXX Mortgage submitted the file for FHA endorsement.FHA and HUD issued an insurance certificate based on false down payment reporting. No HUD underwriter or post-closing reviewer caught the fact that my equity was below 2 % and that no source documentation was included. This is not a back-end calculation dispute. It is a bold-font, first-page violation of TILA/RESPA-integrated disclosure law and FHA insurance rules. It exposes the federal government to insured risk based on false borrower certification and it happened under XXXX XXXX direct supervision and signature. IRS Form XXXX + Closing Disclosure Down Payment Misrepresentation- The IRS Form 1098 filed for my XXXX mortgage loan contains multiple material misrepresentations about my borrower contribution, supporting the false appearance of 100 % financing. These misstatements were reinforced by a falsified Closing Disclosure, certified by XXXX Mortgage XXXX XXXX XXXX XXXX ( XXXX  # XXXX ), and jointly enabled by XXXX XXXX XXXX XXXX. 
IRS Form 1098 Misreporting Box 2 of my XXXX Form 1098 lists {$300000.00} as the mortgage origination amount, but fails to acknowledge that the contract purchase price was {$310000.00}. This gap creates the illusion that the entire property value was financed when in fact, I brought over {$24000.00} to closing. 
Specifically omitted from the XXXX : {$5000.00} XXXX money deposit ( shown in CD Page XXXX, Line XXXX Deposit ) ; {$19000.00} in final funds wired to title ( Page XXXX, Section XXXX Cash to Close From Borrower ) Total borrower contribution : {$24000.00}, exceeding XXXX required 3.5 % minimum ( {$11000.00} on {$310000.00} purchase ). 
XXXX XXXX Manipulation ( Points Paid on Purchase ) My XXXX Form XXXX, XXXX XXXX, reported {$6100.00} in points paid.However, in XXXX and XXXX, this field was changed to {$0.00} with : No corrected XXXX issued ; No Corrected box checked ; No explanation filed with the IRS. Per the IRS Form 1098 Instructions ( Rev. XX/XX/XXXX ), any year-over-year correction to XXXX XXXX must be clearly marked as Corrected to avoid borrower misreporting and preserve HUD compliance XXXX That never occurred. These omissions supported the false narrative that I made no material payment toward the purchase a fiction disproven by both wire records and the original CD totals. CD Conflicts and FHA Contribution Fraud - The Closing Disclosure ( CD ) was internally inconsistent and misleading : On Page XXXX, under Calculating Cash to Close, Line XXXX : Down Payment/Funds from Borrower = {$5700.00} This amount equals 1.81 % of the purchase price well below the FHAs 3.5 % minimum requirement.Nowhere on the CD are the full {$24000.00} XXXX brought to closing properly categorized as a down payment or borrower contribution. There is no gift letter, no grant record, no cash-sourcing supplement and yet the loan was submitted to HUD for FHA endorsement and insurance as compliant. XXXX XXXX originated, validated, and funded this loan without disclosing that the required borrower equity was undocumented and unverified.Selective Accuracy Exposes Intent Despite the false Closing Disclosure date of XX/XX/XXXX, both : The IRS Form XXXX XXXX homeowners insurance policy reported the actual, correct closing date : XX/XX/XXXX. This proves that the correct timeline was known and used in third-party filings but was intentionally falsified on the CD to fabricate TRID compliance ( which requires XXXX business days between CD delivery and consummation ). 
This inconsistency invalidates any clerical error defense and shows that : The actors involved knew the real closing date, but chose to falsify the CD date to backdate borrower disclosure and avoid regulatory consequences.Summary : Systemic Reporting Fraud- This was not a paperwork oversight it was a cross-agency scheme to falsify borrower equity, delay disclosure timelines, and suppress FHA XXXX triggers : The CD omitted proper documentation of the 3.5 % borrower investment.IRS Form XXXX misrepresented down payment, points, and loan-to-value structure. The Corrected box was never checked for years with amended point totals. The CD date was falsified to mask TRID violations. The insurance policy and IRS record, by contrast, reflect the true closing date proving that accurate information was available but intentionally altered. This represents clear and XXXX facie misrepresentation by : XXXX XXXX ( NMLS # XXXX ) Loan Originator, XXXX XXXX XXXX XXXX XXXX XXXX XXXX Mortgage Submitting FHA lenderHUD/FHA Endorsing insurer IRS Form XXXX filers Post-closing reporting agents : Each of these actors had direct access to the correct numbers, the closing timeline, and the borrower contributions and they actively concealed or altered those facts. These were not clerical oversights. This was coordinated deception across federally regulated systems, carried out to push a loan through underwriting and avoid triggering audit flags. The Corrected box was never checked for years with amended point totals. 
The CD date was falsified to mask TRID violations. The insurance policy and IRS record, by contrast, reflect the true closing date proving that accurate information was available but intentionally altered. This represents clear and XXXX facie misrepresentation by : XXXX XXXX ( NMLS # XXXX ) Loan Originator XXXX XXXX XXXX XXXX XXXX XXXX Guild Mortgage Submitting FHA lender HUD/FHA Endorsing insurer IRS Form 1098 filers Post-closing reporting agents. Each of these actors had direct access to the correct numbers, the closing timeline, and the borrower contributions and they actively concealed or altered those facts. These were not clerical oversights. This was coordinated deception across federally regulated systems, carried out to push a loan through underwriting and avoid triggering audit flags. XXXX. Violation of FHA Minimum Investment Requirement ( Facilitated by XXXX XXXX, XXXX  # XXXX ) FHA regulations require a borrower to contribute a minimum of 3.5 % of the lesser of the purchase price or appraised value as their Minimum Required Investment ( MRI ) in order to qualify for insurance. 
Source : HUD Handbook 4000.1, Section II.A.4.3. 
The sales price listed on Page XXXX of my federally regulated Closing Disclosure ( CD ) is {$310000.00}, making the minimum FHA borrower investment $ XXXX, the only amount disclosed as Down Payment / Funds from Borrower ( CD Page XXXX, Calculating Cash to Close ) is $ XXXX below the federal minimum requirement. I personally brought over {$24000.00} to the transaction, including : {$5000.00} XXXX deposit ( listed in CD Line XXXX Deposit ) {$19000.00} final wire ( CD Page XXXX, Section XXXX Cash to Close From Borrower ) {$220.00} title refund ( not properly itemized in FHA XXXX sourcing ) Despite this, none of those funds were credited toward the minimum FHA-required XXXX. There was no gift letter, no XXXX documentation, and no third-party sourcing included in the loan file.This shortfall is not a clerical oversight. It reflects intentional misreporting of borrower-paid fundsa violation of both : Federal FHA lending requirements Texas Department of Savings and Mortgage Lending ( SML ) disclosure and origination standards XXXX XXXX XXXX XXXX licensed senior loan XXXX responsible for this file, originated and submitted the FHA case knowing full well that the CD and FHA certification reflected an invalid borrower contribution. She signed off on the XXXX with a down payment entry ( {$5700.00} ) that equated to just 1.81 % equity on a {$310000.00} loan. She submitted the file for FHA case endorsement and HUD insurance with no supporting documentation to justify the discrepancy. She failed to update or correct the XXXX, and failed to ensure compliance with Handbook XXXX. What This Means for FHA Compliance and Federal Oversight -FHA minimum investment required : {$11000.00} CD falsely shows : {$5700.00} as Down Payment, Actual borrower contribution : over {$24000.00}. No proper allocation, no FHA disclosure, no valid sourcing of XXXX This is a material misrepresentation of borrower equity and investment. It is a false FHA certification, and a failure of Guild Mortgages internal review process. It was submitted and originated under the license of XXXX XXXX ( XXXX # XXXX ), who had a duty to ensure the accuracy and legality of this XXXX loan. XXXX. Violation of FHA Minimum Investment Requirement ( Facilitated by XXXX XXXX, NMLS # XXXX ) FHA regulations require a borrower to contribute a minimum of 3.5 % of the lesser of the purchase price or appraised value as their Minimum Required Investment ( MRI ) in order to qualify for insurance. Source : HUD XXXX XXXX, XXXX XXXX. The sales price listed on XXXX XXXX of my federally regulated Closing Disclosure ( CD ) is {$310000.00}, making the minimum FHA borrower investment {$11000.00}. However, the only amount disclosed as Down Payment / Funds from Borrower ( CD Page XXXX, Calculating Cash to Close ) is $ XXXX below the federal minimum requirement. I personally brought over {$24000.00} to the transaction, including : {$5000.00} XXXX deposit ( listed in CD Line XXXX Deposit ) {$19000.00} final wire ( CD Page XXXX, Section XXXX Cash to Close From Borrower ) {$220.00} title refund ( not properly itemized in FHA investment sourcing ) Despite this, none of those funds were credited toward the minimum FHA-required XXXX. There was no gift letter, no grant documentation, and no third-party sourcing included in the loan file. 
This shortfall is not a clerical oversight. It reflects intentional misreporting of borrower-paid fundsa violation of both : Federal FHA lending requirements 5. Violation of FHA Minimum Investment Requirement ( Facilitated by XXXX XXXX, NMLS # XXXX ) FHA regulations require a borrower to contribute a minimum of 3.5 % of the lesser of the XXXX Texas Department of Savings and Mortgage Lending ( SML ) disclosure and origination standards- XXXX XXXX, the licensed senior loan XXXX responsible for this file, originated and submitted the FHA case knowing full well that the CD and FHA certification reflected an invalid borrower contribution. She signed off on the XXXX with a down payment entry ( {$5700.00} ) that equated to just 1.81 % equity on a {$310000.00} loan. She submitted the file for FHA case endorsement and HUD insurance with no supporting documentation to justify the discrepancy. She failed to update or correct the CD, and failed to ensure compliance with Handbook XXXX. What This Means for FHA Compliance and Federal Oversight-FHA minimum investment required : {$11000.00} CD falsely shows : {$5700.00} as Down Payment Actual borrower contribution : over {$24000.00} No proper allocation, no FHA disclosure XXXX no valid sourcing of funds. This is a material misrepresentation of borrower equity and investment. It is a false FHA certification, and a failure of Guild Mortgages internal review process. It was submitted and originated under the license of XXXX XXXX ( XXXX # XXXX ), who had a duty to ensure the accuracy and legality of this FHA-insured loan. I am asking the CFPB to refer this origination for full audit and enforcement, and to notify HUD, FHA, and IRS accordingly. This was a willful and documentable violation of federal guidelines, not an isolated mistake. XXXX. Disbursement Date Misrepresentation ( XXXX XXXX Complicity in TRID Fraud ) The Closing Disclosure falsely listed XX/XX/XXXX, as the closing date, while disbursement did not occur until XX/XX/XXXX. This contradicts 12 C.F.R. 1026.38 ( a ) ( 3 ), which mandates the closing date reflect actual consummation. XXXX XXXX entered the false date, Guild Mortgage approved it, and loan XXXX XXXX XXXX transmitted the CD knowing it was inaccurate. This is not a clerical error it is a deliberate misrepresentation with federal implications. All downstream systems including IRS, HUD, and FHA used XX/XX/XXXX. XXXX is directly complicit in certifying a false closing. 
XXXX. Fraudulent CD Delivery and TRID Evasion The CD was dated XX/XX/XXXX, listed a false close of XX/XX/XXXX, and was sent to me at XXXX p.m. on XX/XX/XXXX violating XXXX XXXX XXXX ( f ) ( XXXX ) ( XXXX ) ( A ), which requires XXXX days review. My signature aligns with XX/XX/XXXX, proving the real date. Emails from XXXX and XXXX confirm the XXXX was not available on XX/XX/XXXX. XXXX sent a comfort-check email XX/XX/XXXX, but took no corrective action. This shows full awareness and a calculated attempt to normalize fraud. 
XXXX. Co-Borrower Fraud and Gift Letter Omission Broker XXXX and XXXX, including XXXX, added a co-borrower who contributed nothing. My ALTA shows I paid all funds. XXXX failed to include a gift letter or justification, in violation of FHA XXXX XXXX. XXXX encouraged the structure, stating it was common and could be fixed later. The rent-to-mortgage imbalance ( rent : {$800.00}, mortgage : $ XXXX ) shows the loan was unaffordable. They processed it anyway. 
XXXX. XXXX XXXX XXXX and Falsified Undated Documentation I requested $ XXXX for flooring. Instead, the seller removed the flooring and issued a $ XXXX credit combining unrelated repairs. The only receipt referenced XXXX XXXX, not XXXX XXXX, and was undated. Emailed to myself and XXXX XXXX on closing day, it avoided HUD re-inspection or triggering reappraisal. XXXX accepted this by replying Thanks! finalizing a fraudulent FHA loan. Every licensed actor approved the closing despite knowing it violated FHA habitability rules. These acts were not mistakes. They reflect a coordinated pattern of calculated fraud, TRID evasion, repair deception, and false certification of FHA loan eligibility involving Guild Mortgage, XXXX XXXX XXXX XXXX, and licensed loan XXXX XXXX XXXX. Every participant in the origination pipeline had direct knowledge of the violations and each enabled the loan to close despite clear federal and state compliance breaches. What makes this case more alarming is the complete failure of oversight at all levels : lender underwriting, title compliance, real estate supervision, and post-closing FHA review. Every agency, from HUD to the Texas Department of Savings and Mortgage XXXX, had the authority and duty to intervene yet none did. As a XXXX female FHA borrower and first-generation homeowner, I was targeted with a defective loan structure, misrepresented documentation, and deliberate omissions that would not have been tolerated in a higher-income, non-minority file. The regulatory failure to stop this abuse before and after closing reflects a systemic indifference to the civil rights protections that are supposed to be guaranteed under federal lending law. XXXX XXXX also knew that I had fully liquidated my only retirement account a XXXX XXXX  just to qualify for this FHA purchase. She was fully aware that this was my last available savings, and yet she proceeded to close the loan knowing the property was uninhabitable and would require immediate repair spending just for me to move in. She knowingly sold me a home with no flooring, forcing me to pour the remainder of my retirement into making it livable. This was not just predatory it was exploitative, and it weaponized my economic vulnerability as a first-time XXXX homebuyer. 
This transaction is not just a financial fraud it is a civil rights violation. It shows how discriminatory patterns can be laundered through technical paperwork and normalized by licensed professionals. I request immediate federal enforcement, permanent license revocation, and full agency referral under the False Claims Act, RESPA, and Title XXXX of the Civil Rights Act. Litigation Hold Request XXXX XXXX and Affiliated Parties I formally request that the CFPB issue a litigation hold requiring XXXX XXXX ( NMLS # XXXX ), along with Guild Mortgage

Company response to consumer: Closed with explanation