Consumer complaint received 2025-11-18 00:00:00
Product: Mortgage — VA mortgage
Issue: Trouble during payment process — Payment process
Company: Shellpoint Partners, LLC
State: TN

Complaint narrative:
NewRez XXXX XXXX XXXXXXXX XXXX : Resulting Illegitimacy of NewRez and XXXX XXXX XXXX * * ( XXXX XXXX XXXX | Full statutory citations | XXXX ) Submitted by : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Mortgage XXXX XXXX XXXX NewRez LLC has XXXX XXXX XXXX regulators that XXXX XXXX XXXX is not associated with NewRez/Shellpoint. 
This disavowal directly contradicts XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX filings Consolidated financial statements XXXX  certifications Beneficial XXXX XXXX XXXX XXXX XXXX XXXX statements Under federal law, both sets of statements can not be true simultaneously. 

If XXXX XXXX is taken as accurate, then : NewRez becomes an unparented, orphaned, non-consolidated servicer with no lawful controller, no XXXX pathway, no governance chain, and no oversight authority. 

And because Shellpoint functions as XXXX servicing division, Shellpoint would then be conducting servicing operations : * * Without a lawful controller Without a valid parent Without XXXX oversight Without governance Without required federal supervision Without legal authority under mortgage servicing law. * * This document details why this structure can not lawfully exist under federal statutes and the catastrophic implications. 



XXXX. Federal Law Requires a Servicer to Have a Parent, Controller, and Governance Chain XXXX Requirements Under RESPA & Regulation X 12 U.S.C. 2605 and 12 C.F.R. 1024.38 require : a designated entity responsible for servicing operations a governance framework oversight authority supervisory controls error resolution systems internal compliance infrastructure If NewRez has no parent, then : No entity exists to fulfill these federal requirements. 

A servicer can not lawfully operate in this vacuum. 



XXXX. Servicers Can not Operate Without a XXXXCertified XXXX XXXXXXXX, as parent, signs : XXXX XXXX XXXX XXXX XXXX internal control attestations risk and oversight committee approvals consolidated MSR valuations If NewRez XXXX XXXXXXXX, then : No XXXX exists who can legally sign XXXX certifications for : XXXX valuations internal controls consolidated reporting risk oversight servicing liabilities A company without XXXX pathway can not service mortgages. 

( Cited : XXXX XXXX of XXXX ; 15 U.S.C. 7241, 7262 ) Shellpoint relies entirely on these certifications. 

If the parent chain collapses, Shellpoint loses legal oversight. 



XXXX. XXXX XXXXXXXX, & Consolidation Rules Require a Valid Controller Under SEC Rule XXXX, XXXX C.F.R. 240.12b-20, and XXXX Auditing XXXX XXXX : A consolidated servicer ( NewRez/Shellpoint ) : must have a parent must have a controller with authority must maintain unified internal controls must maintain validated governance lineage If XXXX does not own NewRez : consolidation is fraudulent audits are invalid MSR valuations are unreliable internal controls collapse Shellpoint can not lawfully service loans under an invalid consolidation structure. 



XXXX. CFPB Supervision Manual : Servicers Can not Operate as Orphan Entities XXXX Mortgage Servicing Examination Manual ( 2023 edition ) requires servicers to have : a parent entity with supervisory authority effective board oversight documented governance structure auditable control systems clearly established accountability If NewRez XXXX XXXXXXXX : Shellpoint becomes a free-floating servicer operating with no lawful governance, in direct violation of CFPB supervision standards. 



XXXX. VA Loan Rules Require a Parent-Level Controller to Maintain Compliance For VA-backed loans XXXX 38 U.S.C. 3720 & VA Servicer Handbook XXXX. XXXX require : accurate accounting systems validated governance parent-level controls auditable supervision oversight by a financially responsible controlling entity Without a parent entity : Shellpoint can not meet VA loan servicing requirements.

Every VA loan on the platform becomes tainted. 



XXXX. If NewRez XXXX XXXX, XXXX Entire Servicing Operation Becomes Structurally Invalid Because Shellpoint is the functional servicing arm of NewRez : If NewRez is orphaned, then Shellpoint is : orphaned unparented unsupervised non-certifiable without required XXXX authority without SEC consolidation without CFPB-required governance without VA servicing authority without internal control lineage Under federal doctrine, this becomes : An unsupervised servicer a structure that is not permitted under XXXX mortgage XXXX. 



XXXX. Enforcement Consequences ( CFPB, SEC, FTC, VA, XXXX XXXX ) If XXXX XXXX is taken at face value, regulators must treat Shellpoint as : operating outside required governance frameworks servicing loans without legal authorization conducting consumer financial services without mandated oversight in violation of federal lending laws presenting systemic risk to borrowers, veterans, and mortgage markets This is grounds for : CFPB XXXX actions ( 12 U.S.C. 5531 ) SEC investigation into consolidation fraud FTC unfair practices enforcement VA loan program revocation State AG wide-scale consumer protection actions Closing Statement By stating XXXX is not associated with NewRez/Shellpoint, NewRez has XXXX a XXXX contradiction that collapses its own legal foundation and renders Shellpoints servicing operations incapable of meeting federal servicing, XXXX, XXXX, VA, CFPB, and state governance requirements. 

A servicer without a parent is not a servicer it is an unregulated financial risk operating outside the law. 

And Shellpoint, as the operating arm, inherits that illegitimacy.

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