Consumer complaint received 2025-12-08 00:00:00
Product: Mortgage — Conventional home mortgage
Issue: Trouble during payment process — Escrow, taxes, or insurance
Company: Shellpoint Partners, LLC
State: CA

Complaint narrative:
This is a Notice of Error ( NOE ) under RESPA 1024.35 and a follow-up to CFPB Complaint # XXXX ( closed inadequately on XX/XX/XXXX with Shellpoint 's unsubstantiated " no error '' claim, ignoring my pivot analysis showing {$750.00} net overpayments from irregular refund loops in XXXX ). Shellpoint continues predatory lender-placed flood insurance ( FPI ) practices on Loan # XXXX ( Property : XXXX XXXX XXXX  # XXXX, XXXX XXXX XXXX CA XXXX ), despite proof of continuous HOA master policy coverage. 
In # XXXX, Shellpoint disbursed {$230.00} FPI on XX/XX/XXXX, ignoring my XX/XX/XXXX upload of compliant COI ( XXXX XXXX XXXX {>= $1,000,000} coverage via Philadelphia Indemnity ; Exhibit B confirmation ). They bundled it deceptively in {$320.00} " Escrow ( Taxes and Insurance ) '' without itemizing, violating TILA Reg Z 1026.41 ( d ) ( 2 ) for clear breakdowns. Their response falsely claimed my COI was expired ( XXXX ), but I provided current evidence. 
To directly refute Shellpoint 's " no error '' claim and prove refundable overpayments, I analyzed their own payment history data ( downloaded from servicing.shellpointmtg.com on XX/XX/XXXX ) using a pivot table filtering for " Insurance Premium Disbursement '' vs. " Insurance Refund '' transactions. This data, exported directly from their portal, shows {$5900.00} in total insurance premiums disbursed from my escrow since XXXX, offset by only {$5000.00} in refunds, resulting in a net overpayment of {$870.00} ( see attached Insurance_Premium_Disbursement_vs_InsuranceRefund.csv and XXXX for the full table ). This net figure includes irregular " refund loops '' ( e.g., multiple refunds in XX/XX/XXXX totaling {$3500.00} that appear to correct prior errors but still leave a deficit ) and recent unwarranted FPI ( {$350.00} in XXXX ), proving errors in escrow application and failure to fully refund improper charges. Shellpoint 's data itself demonstrates these discrepancies, contradicting their denialCFPB must compel a full audit to verify and refund this {$870.00} net overpayment, which supports my demand for {$1100.00} in total XXXX refunds ( {$750.00} historical net + {$350.00} recent, adjusted for unrefunded items ). CFPB supervisory highlights ( Issue XXXX, XXXX ) require servicers to cancel XXXX and refund premiums for overlapping periods upon proof, reinforcing the need for refunds, reversals, and taxes-only analysis in my demands. 
New violations since closure : Shellpoint 's XXXX portal complicates, hides, and provides no feedback on upload reviews or results, creating a " black hole '' that enforces FPI charges and late fees without consumer awareness. Uploads yield only generic confirmations ( e.g., email : " assigned to insurance department '' ), with no status tracking, rejection details, or dashboardviolating RESPA 1024.37 ( e ) timely notices and UDAAP against deceptive processes that confiscate escrow funds. For example, if a consumer uploads a master policy with the wrong expiration date, you continue billing and threatening lates without explaining why, leaving the consumer unaware despite believing proof was provided. Similarly, if the consumer uploads but misses scrolling to and clicking " submit '' ( button buried at the bottom ), the policy remains unprocessedyou don't notify of the incomplete status, enabling XXXX to proceed unchecked. As of XX/XX/XXXX, you have failed to update my account within the XXXX business hours promised in the XXXX email confirmation for my XX/XX/XXXX upload ( " A customer service representative will review your policy information and update your account within XXXX business hours '' ). This written promise, when not honored, constitutes a deceptive act under CFPB 's UDAAP authority ( 12 U.S.C. 5531, prohibiting unfair, deceptive, or abusive acts/practices ) and may violate FTC Act 5 equivalents, as it misleads consumers about timelines for error resolution and insurance verification, leading to unwarranted charges. 
On XX/XX/XXXX, disbursed another {$110.00} FPI ( attached payment history export dated XX/XX/XXXX ), despite my re-upload of XXXX COI on XX/XX/XXXX ( effective XXXX, {>= $1,000,000} property coverage via XXXX XXXX XXXX ; Exhibit J confirmation from XXXX XXXX XXXX This ignores HOA 's RCBAP-equivalent coverage under NFIP 44 C.F.R. 61.13 and Davis-Stirling Act 4125/4775/5805, violating RESPA 1024.37 ( g ) ( must cancel FPI within 15 days of proof ). 
Assessed {$65.00} late fee on XX/XX/XXXX and marked " late '' status, retaliatory for my timely P & I payment of {$1300.00} on XX/XX/XXXX. Pre-disbursement escrow balance ( {$2200.00} ) covered the {$2000.00} tax payout on 11/18/2025 ( leaving {$200.00} cushion ), so no delinquency absent disputed FPI. Violates RESPA 1024.35 ( i ) ( no adverse reporting during 60-day NOE ), 1024.17 ( k ) ( 2 ) ( must advance escrow for legitimate items ), and FCRA 1681s-2 ( a ) ( 3 ).

Even more deceptively, the {$320.00} monthly " Escrow ( Taxes and Insurance ) '' is padded beyond the true property tax needs ( ~ $ XXXX for {$3900.00} annual taxes ), allowing occasional invalid FPI charges like {$110.00} to be absorbed without dropping the balance below minimum levels or triggering immediate alerts. This hidden accounting layerevident in the payment history where FPI deductions don't cause visible shortagesobscures improper disbursements, making them inaccessible to consumers, elders like me, or auditors ( e.g., CFPB officials ) without deep analysis. It violates RESPA 1024.17 ( c ) escrow limits ( 1/12th + 1/6 cushion max ) and CFPB UDAAP prohibitions on deceptive practices that mislead about costs and account status, while enabling illicit FPI profits XXXX 
XX/XX/XXXX escrow statement shows {$540.00} shortage from unwarranted {$590.00} XXXX, projecting new payment {$1800.00} effective XX/XX/XXXX. Demands {$2000.00} total due ( mailed statement ) vs. {$1600.00} online portalmismatched and deceptive. " Escrow ( Taxes and Insurance ) '' lumps {$320.00} without separating ~ {$330.00} tax from invalid {$110.00} XXXX, forcing seniors like me to calculate, violating UDAAP and elder protections ( Elder Justice Act, CA EADACPA ).

As a senior, this constitutes financial exploitation via ignored proofs, illicit commissions, and withheld surplus ( ~ {$2300.00} XXXX ). Total XXXX overpayments now {$1100.00} ( {$750.00} historical + {$230.00} + {$110.00} ). My XX/XX/XXXX QWR ( Exhibit F ) remains unaddressed. 
Demand : Refund {$1100.00} FPI + {$65.00} fee, reverse late status/no reporting, honor HOA policy, itemize escrow ( taxes separate ), confirm taxes-only escrow with updated analysis, suppress adverse actions, and add portal feedback/tracking. 
Attachments : - Payment History Export ( XX/XX/XXXX ) - Escrow Statement ( XX/XX/XXXX ) - XXXX COI Renewal - Exhibit J ( XX/XX/XXXX Upload Confirmation ) - Prior Exhibits ( XXXX, pivots, statements ) - Portal Screenshot ( expressinsuranceinfo.com ) - Insurance_Premium_Disbursement_vs_InsuranceRefund.pdf ( pivot table )

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