Consumer complaint received 2025-10-05 00:00:00
Product: Mortgage — VA mortgage
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: Rhode Island Housing and Mortgage Finance Corporation
State: RI

Complaint narrative:
On XX/XX/year>, my servicer Rhode Island Housing removed {$3900.00} from my escrow account and routed the same amount back to itself with no tax or insurance payee. Three records line up same date/same amount : My monthly mortgage statement shows Escrow to investor {$3900.00}. ( Escrow is intended to pay third-party taxes/insurance ; an internal routing to the servicer/investor is atypical and raises misuse concerns. ) The companys internal Task Sheet/record notes a {$3900.00} withdrawal labeled XXXX XXXX XXXX XXXX XXXX XXXX  ) and a same-day check noted XXXX XXXX XXXX XXXX 

A same-day check # XXXX for {$3900.00} is made payable to Rhode Island Housing . ( The Task Sheet and the check image appear together in one XXXX XXXXXXXX document Exhibit XXXX. ) The Task Sheets reliability is questionable : it contains an original digital e-signature block and an original digital account number ( later crossed out ), but nearly everything elseincluding the date written next to the signatureis a handwritten addition made after signing, with no author or time-stamp on the face of the document.

Why this matters / consumer harm : Escrow funds are supposed to pay taxes or insurance, not be cycled back to the servicer. This suggests improper escrow use and weak record controls. My escrow balance was reduced without a real payee, creating risk of tax delinquency or insurance lapse, potential escrow shortages ( higher monthly payments ), and significant time/stress to address a servicer-caused problem. I have received evasive replies ( under litigation, already provided ) instead of a direct explanation tied to an actual payee. I consent to the CFPB publishing my complaint narrative in whole or in part to inform other consumers and stakeholders. I am a XXXX XXXX XXXX XXXX XXXXXXXX  v. Rhode Island XXXX XXXX XXXX XXXXXXXX XXXX, reflecting similar issues and potential systemic risk. 

Regulatory concerns for CFPB review ( investigation/supervision focus ) : RESPA / Regulation X Escrow use ( 12 C.F.R. 1024.17 ( k ) ) : Were escrow funds on XX/XX/year> applied to bona fide escrow items ( taxes/insurance ), or cycled internally to the servicer/investor? 

RESPA / Regulation X Servicing records & controls ( 12 C.F.R. 1024.38 ) : Electronically signed record later filled with post-signature handwritten entries indicates inadequate record-integrity/version control. 

RESPA / Regulation X Error-resolution responsiveness ( 12 C.F.R. 1024.35 ) : Pattern of evasive responses instead of addressing the specific XX/XX/year> transaction. 

UDAAP ( 12 U.S.C. 5531, 5536 ) : Cycling escrow to the servicer and issuing altered post-signed records may be unfair or deceptive and likely to cause substantial consumer injury.

E-SIGN Act ( 15 U.S.C. 7001 ( d ) ) : Retained electronic records must accurately reflect the information and remain accessible ; post-signature handwritten additions undermine that standard. 

Requested CFPB action ( on the record ) : Open an inquiry/ refer to Supervision regarding the XX/XX/year> escrow handling and the record-control environment that allowed post-signature handwritten additions. 

Consider a look-back for similarly situated borrowers ( use of Escrow to investor entries to cycle escrow ). 

Ask the company, on the record, to state : Whether Escrow to investor is a legitimate escrow disbursement to a third-party payee and to identify that payee for XX/XX/year> ; Whether any tax authority or insurer received {$3900.00} on XX/XX/year> ; if not, why the escrow balance was reduced ; Whether post-signature handwritten edits to an e-signed Task Sheet comply with company policies and with XXXX XXXX XXXX XXXX. 

Attachments : Exhibit XXXX : XXXX XXXXXXXX single document containing both : ( i ) the Task Sheet noting XXXX XXXX XXXX XXXX XXXX XXXX  XXXX XXXX XXXX XXXX XXXX with handwritten additions, and ( ii ) the check # XXXX image ( front/back ) for {$3900.00} payable to Rhode Island XXXX XXXX 

Exhibit XXXX : Monthly statement page ( XX/XX/year> ) showing Escrow to investor {$3900.00}.

Company response to consumer: Closed with explanation