{"took":348,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":5,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"15077225","_score":11.903896,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Complaint Title Delayed check and Account Closure PNC Holding {$200000.00} Without Justification Complaint Narrative 1. Overview of the Problem On XX/XX/year>, I deposited two cashier check of $ XXXX that's amount the sum of $ XXXX. \nThe {$200000.00} cashiers check, I deposited into my newly opened personal PNC Bank account ending in XXXX.The funds were transferred from my legitimate personal account at XXXX XXXX , The purpose of this transfer was to move the money into a new account for future investment. \n\nShortly after the deposit, unknown third-party deposit transactions began appearing in my PNC account . I had no knowledge of these deposits or their sources.i reported for the reversal of the unknown deposit in my account I received a letter from pnc to extending the hold on my account for ten business days but not suspension of online account. \nAfter that my account I can't have access, online access suspended and now my XXXX is credited and available at my PNC account PNC then begin accepting deposits and never offer protection to my account, PNC suspended my entire account, including all online banking access. I never had access to my account my card was suspended too. \nI received no explanation or warning, only general letters stating that the account was placed on extended hold. \n\nThe original cashiers check I deposited was placed on a standard 710 day hold and then kept on extended hold indefinitely. I sent an official letter via XXXX XXXX requesting an explanation for the prolonged hold, but I received no response. I also visited multiple PNC branches, including XXXX XXXX, where I was told a refund check would be mailed and the account would be closed and the unknown funds would be reverse.However, I only received {$1200.00} check The XXXXcheck never arrived, and I was never given any written confirmation It should be : I made a call to PNC customer care in XXXX, placed me on hold then hung up on me. I called back again, and did same thing. PNC dropped the calls on me. PNC x customer care ignored to assist me about my accounts.They never called back Later, I learned that PNC placed my funds into a DRU ( Dispute Resolution Unit ) and claimed that the IRS would reclaim my funds, which is completely unsubstantiated. The funds came from my personal XXXX XXXX account, and there is no IRS claim, seizure notice, or legal action against my account.\n\n2. Attempts to Resolve I have made multiple good-faith attempts to resolve this directly with PNC : I visited multiple branches, including XXXX XXXX I sent a formal written demand via XXXX I made several phone calls and sent emails asking for status updates I requested my account be closed and a refund check issued I have received no detailed explanation, no tracking number, and no refund to date 3. Supporting Documents ( Available to Upload ) Cashiers check deposit proof from XXXX XXXX Account closure letters dated XX/XX/XXXX and XXXX XXXX Copy of my XXXX  letter to PNC requesting release of funds Screenshots of similar case successfully resolved via CFPB and OCC Timeline and written notes of my communications and visits 4. Resolution Requested I respectfully request that PNC Bank be required to : 1. Release and mail my {$200000.00} check immediately 2. Provide written confirmation and tracking information 3. Explain in writing the reasons behind the prolonged hold and the XXXX placement 4. Ensure no negative reporting is made to XXXX  or credit bureaus due to this issue 5. Harm Caused I have lost access to a large sum of money for over three months PNC failed to provide proper notice, justification, or communication Ive experienced financial stress, repeated inconvenience, and time wasted traveling to branches and writing follow-ups 6. Urgency PNC promised to issue a check within 10 business days of closing my account. That timeline has long passed, and I still have no access to my funds. I am requesting your immediate help in resolving this issue and holding PNC accountable","date_sent_to_company":"2025-08-04T14:06:37.000Z","issue":"Problem with customer service","sub_product":"Money order, traveler's check or cashier's check","zip_code":"94066","tags":"Servicemember","has_narrative":true,"complaint_id":"15077225","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"PNC Bank N.A.","date_received":"2025-08-04T13:36:27.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["<em>Complaint</em> Title Delayed check and Account Closure PNC Holding {$200000.00} Without Justification <em>Complaint</em> <em>Narrative</em> 1. <em>Overview</em> of the Problem On XX/XX/year>, I deposited two cashier check of $ <em>XXXX</em> that's amount the sum of $ <em>XXXX</em>."]},"sort":[11.903896,"15077225"]},{"_index":"complaint-public-v1","_id":"16700491","_score":10.385346,"_source":{"product":"Vehicle loan or lease","complaint_what_happened":"Complaint Packet : Santander Consumer USA XXXX XXXX. \n* * Complainant : * * XXXX XXXX * * Agency : * * Consumer Financial Protection Bureau ( CFPB ) * * Loan Type : * * Auto Financing To Whom It May Concern, Please find below my formal complaint against Santander Consumer USA , Inc., along with a summary of evidence from my account records. I have also attached my full transaction history ( XX/XX/XXXX XX/XX/XXXX ) to substantiate my claims. \n\n* * * Complaint Narrative I am filing this complaint against Santander Consumer USA , Inc. for failing to properly apply my auto loan payments.\n\nWhen my loan began, my balance was * * {$33000.00} * *. After one full year of consistent paymentsincluding multiple payments in some months to avoid repossession threatsmy balance is still * * {$31000.00} * *, a reduction of only about * * {$2700.00} * *. \n\nDuring this period, I paid * * well over {$9000.00} * *. However, Santanders own transaction history shows that the majority of my payments were applied to * * interest and fees * * rather than reducing the principal. In some cases, entire payments were applied only to interest, with no reduction in principal. Santander also posted miscellaneous fees that offset my payments and kept my balance from decreasing. \n\nThis pattern demonstrates that Santander is not properly applying my payments toward reducing my loan balance. Instead, they are disproportionately allocating funds to interest and fees, leaving me trapped in a cycle where my balance barely decreases despite consistent payments. \n\nI have contacted Santander multiple times to resolve this issue, but their responses have been vague and unhelpful. Meanwhile, I remain at risk of repossession despite fulfilling my obligations. \n\nThis is not an isolated incident. Santander has received * * hundreds of thousands of consumer complaints * * through the XXXX XXXX XXXX and other platforms. Numerous XXXX groups document similar experiencesmisapplied payments, unexplained fees, and aggressive collection tactics despite proof of payment. \n\nI am requesting the CFPBs assistance in investigating Santanders practices and ensuring that my payments are properly credited to my loan balance. I am prepared to provide full documentation, including my transaction history, payment records, and correspondence with Santander. \n\n-- - # # Evidence Summary ( from Santander Transaction History ) * * Account Overview * * - Starting Balance : {$33000.00} - Current Balance ( after 1 year ) : {$31000.00} - Total Reduction : {$2700.00} - Total Payments Made : Over {$9000.00} * * Sample Payment Applications * * | Date| Payment Amount | Applied to Principal | Applied to Interest | Notes XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXX/XX/XXXX | {$790.00} | {$0.00} | {$790.00} | Entire payment to interest | | XXXX XXXX, XXXX | {$790.00} | {$110.00} | {$680.00} | Minimal principal reduction | | XX/XX/XXXX | {$900.00} | {$340.00} | {$550.00} | Majority to interest | | XX/XX/XXXX | {$790.00} | {$330.00} | {$450.00} | Split, but still interest-heavy | | XX/XX/XXXX | {$790.00} | {$170.00} | {$610.00} | Disproportionate interest | | XX/XX/XXXX | {$790.00} | {$360.00} | {$430.00} | More to interest than principal | | XX/XX/XXXX | Multiple {$330.00} fees XXXX XXXX XXXX XXXX XXXX  Miscellaneous fees offset payments | XX/XX/XXXX XX/XX/XXXX {$330.00} {$31000.00} -- {$330.00} -- XXXX. Fees -- XX/XX/XXXX XX/XX/XXXX {$20.00} {$31000.00} -- -- -- XXXX. Fees {$20.00} XX/XX/XXXX XX/XX/XXXX ( {$330.00} ) {$31000.00} -- ( {$330.00} ) -- XXXX. Fees -- I am looking forward to promptly resolving this matter with Santander Consumer USA.","date_sent_to_company":"2025-10-20T23:00:23.000Z","issue":"Managing the loan or lease","sub_product":"Loan","zip_code":"80237","tags":null,"has_narrative":true,"complaint_id":"16700491","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"SANTANDER HOLDINGS USA, INC.","date_received":"2025-10-20T20:31:24.000Z","state":"CO","company_public_response":null,"sub_issue":"Billing problem"},"highlight":{"complaint_what_happened":["I have contacted Santander multiple times to resolve this <em>issue</em>, but their responses have been vague and unhelpful. Meanwhile, I remain at risk of repossession despite fulfilling my obligations. \n\nThis is not an isolated incident. Santander has received * * hundreds of thousands of consumer <em>complaints</em> * * through the <em>XXXX</em> <em>XXXX</em> <em>XXXX</em> and other platforms."]},"sort":[10.385346,"16700491"]},{"_index":"complaint-public-v1","_id":"6119288","_score":7.9096265,"_source":{"product":"Checking or savings account","complaint_what_happened":"REQUEST FOR RECONSIDERATION XX/XX/2022 TO : Bank of America Fraud Department Fax : ( XXXX ) XXXX FROM : XXXX, AZ XXXX Phone : OVERVIEW : I request reconsideration of the initial denial of my fraud claim, # XXXX, which I filed on XX/XX/2022 after transactions unauthorized by mei.e., without my permission and unbeknownst to XXXX made by third parties to steal money from my Bank of America XXXX BoA XXXX checking account and via my BoA credit card. Federal lawe.g., Regulation Erequires BoA to reimburse me for such unauthorized transactions. \n\nBelow, I provide a narrative of the fraudulent activity occurring on XX/XX/2022, as well as an account of what has since happened between me and BoA regarding my claim. I also note that I reported the third parties fraudulent activities on the day they occurred and, thus, provided timely notice of the fraud. Additionally, it is worth noting that I have a three-decades-long and spotless history with BoA. \n\nFRAUD CLAIM : Fraudulent Activity On the morning of XX/XX/2022, I made two phone calls to ( XXXX ) XXXX to inform XXXX ( XXXX ) that I was receiving packages that I had not ordered. Neither call was answered. Thus, I googled Amazons customer-service number, and my search returned the number ( XXXX ) XXXX. \n\nI dialed the latter number at XXXX. The person who answered purported to be an XXXX representative, and he explained that he would refer my complaint about the unordered packages to the appropriate department, after which another XXXX representative would call me. \n\nI received a telephone call at XXXX from ( XXXX ) XXXX. This caller also purported to be an XXXX representative, and I explained to him the issue about receiving unordered packages. At no time did I provide any information regarding my BoA checking account or credit card, as such information had nothing to do with the issue I was attempting to bring to XXXX attention. \n\nMoreover, I became suspicious of the caller once he mentioned that I needed to go to XXXX to buy XXXX gift cards. In fact, I decided to drive to a nearby XXXX to ask them if they had received such requests before and to alert them that this caller was likely attempting to involve them in fraudulent gift-card activity. Once there, I talked with a cashier, who thought it was a good idea to check with my bank just in case the caller was up to some other type of fraud. \n\nI drove to my BoA branch, which was also nearby. There, I learned that third parties had made an unauthorized transaction on my credit card and made a series of unauthorized electronic transfers of money out of my checking account. I tried several times to contact BoAs Fraud Department by phone, but no call was successful because I did not have a good connection at the bank. Finally, I used my bankers desk phone to report the fraud and make a claim. My banker also helped me to close my BoA credit-card and checking accounts to prevent further fraud. \n\nPost-Claim Events Since XX/XX/XXXX, I have attempted to obtain copies of all relevant documents related to my BoA accounts and the fraudulent transactions on numerous occasions. This has often involved waiting two or more hours on the phone to be connected to BoAs Fraud Department, to no avail. \n\nI eventually received a letter from BoA denying my fraud claim. In the denial letter, BoA alleges that an authentication code [ was ] sent to a valid phone number belonging to a signer on the account, seemingly in connection with authorizing the fraudulent transactions. However, on XX/XX/XXXX, I did not request any such authentication code, nor did I receive XXXX on my cellphone ( the only electronic device I use, and the only phone I have ) and, consequently, I could not have responded to any supposed authentication-code request. In short, I did not authorized the electronic transfers of money out of my BoA checking account, nor did I authorize the cash-advance transaction on my BoA credit card. \n\nThe denial letter also stated that I have the right to request the documents [ BoA ] relied on in making [ its ] determination and that BoA would mail the information to [ me ] for [ my ] records. On XX/XX/2022, I called BoAs Fraud Department to request these documents. A BoA agent from the Fraud Department said that he would call me back regarding the documents. He never did. \n\nOn XX/XX/2022, I again called BoAs Fraud Department. Instead of agreeing to provide copies of the relevant documents, this BoA agent suggested that I file a request for reconsideration. I do so here, while noting that I do so without any being able to specifically respond to BoAs supposed evidence of authorization given that I still have not been provided with the relevant documents. \n\nOn XX/XX/2022, I reported the third parties fraudulent activity concerning my BoA credit card and checking account to the XXXX Police Department ( police report # XXXX ). \n\nCONCLUSION : I request that the denial of my fraud claim be reversed. Pursuant to federal law, I am entitled to relief for the monetary losses I suffered as a result of the third parties fraudulent activity with respect to my BoA checking account and credit card. \n\nIf, on the other hand, BoA continues to refuse to make me whole for the losses caused by the unauthorized transactions on my BoA accounts, then I demand, again, that BoA mail me all the documents BoA relied on to conclude that I purportedly authorized the third parties fraudulent activity ( relatedly, this letter also serves as a notice of litigation hold in relation to future legal action ). \n\nThank you for your reconsideration of my claim. \n\n\nSigned : Date : _____________________________ ______________________________ I believe these unauthorized transactions total {$3400.00} with respect to my BoA checking account and {$1500.00} with respect to my BoA credit card. However, I have been unable to definitively determine the extent of the fraudulent activity because BoA has not provided me with the necessary documentation even though I have requested it numerous times. \n\nIn addition, a call came in at XXXX from ( XXXX ) XXXX, which I did not answer. A text had been sent from the same number at XXXX asking if I had purchased the gift cards yet. \n\nI have requested copies of all relevant documents regarding my claim and I have not received any.","date_sent_to_company":"2022-10-23T23:04:22.000Z","issue":"Managing an account","sub_product":"Checking account","zip_code":"85201","tags":"Older American","has_narrative":true,"complaint_id":"6119288","timely":"Yes","company_response":"Closed with monetary relief","submitted_via":"Web","company":"BANK OF AMERICA, NATIONAL ASSOCIATION","date_received":"2022-10-23T21:57:34.000Z","state":"AZ","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Deposits and withdrawals"},"highlight":{"complaint_what_happened":["The person who answered purported to be an <em>XXXX</em> representative, and he explained that he would refer my <em>complaint</em> about the unordered packages to the appropriate department, after which another <em>XXXX</em> representative would call me. \n\nI received a telephone call at <em>XXXX</em> from ( <em>XXXX</em> ) <em>XXXX</em>. This caller also purported to be an <em>XXXX</em> representative, and I explained to him the <em>issue</em> about receiving unordered packages."]},"sort":[7.9096265,"6119288"]},{"_index":"complaint-public-v1","_id":"17114085","_score":4.281603,"_source":{"product":"Mortgage","complaint_what_happened":"Consumer Financial Protection Bureau XXXX XXXX and XXXX Framework Submission Subject : Coordinated Mortgage Servicing Fraud, Accounting Manipulation, and Enrichment Scheme Primary Entities : XXXX XXXX XXXX, NewRez LLC, Shellpoint Mortgage Servicing, XXXX XXXX XXXX XXXX XXXX XXXX XXXX Supporting Evidence : CFPB Complaint XXXX # ( list XXXX XXXX ) + audio transcripts + servicing ledgers + metadata images Introduction XXXX XXXX and Corrupt Organizations ( XXXX ) Framework This submission establishes the existence of a continuing criminal enterprise composed of XXXX XXXX XXXX, its wholly owned subsidiaries NewRez LLC and Shellpoint Mortgage Servicing, and its retained legal counsel XXXX, XXXX, XXXX XXXX XXXX XXXX XXXX XXXX, with the participation and enrichment of multiple investment banks and insiders. The enterprises conduct spans mortgage servicing, securities reporting, and legal certification functions, coordinated for the purpose of financial enrichment through deception, concealment, and coercion. Its operational nucleus lies in a single integrated servicing system that manipulates consumer payments, falsifies corporate disclosures, and insulates its actors throu Systemic Consumer Harm and Market-Wide Impact The pattern of conduct established in both pending and resolved actions against NewRez LLC XXXX Shellpoint Mortgage Servicing XXXX and parent XXXX XXXX XXXX demonstrates that the violations are not isolated clerical errors, but symptoms of a uniform servicing architecture that injures every consumer whose mortgage is routed through these entities. XXXX. Structural Misapplication of Payments Across multiple jurisdictionsincluding XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ), and the current CFPB complaint databaseborrowers report identical failures to credit payments as of the date received. Your own account shows more than {$100000.00} held in unapplied suspense, yet monthly statements assess delinquency and fees. This mirrors the XXXX v. NewRez allegations of inflated unapplied balances and phantom late fees. Under XXXX C.F.R. XXXX ( c ) ( XXXX ) ( XXXX XXXX ) and XXXX XXXX. XXXX ( k ) ( XXXX ) ( C ) ( RESPA ), this practice constitutes a prohibited servicing act. The systemic replication of that violation across portfolios means every consumers amortization schedule, credit history, and equity position is corrupted. XXXX. False XXXX and XXXX XXXX Servicers routinely threaten foreclosure even when internal ledgers acknowledge that funds are present but misallocated. In your evidence, Shellpoint agents confirmed receipt of payments on XX/XX/XXXX yet issued non-payment threats on later callsconduct meeting the XXXX XXXX, XXXX U.S.C. XXXX, definition of extortion under XXXX of right. The same fact pattern appears in XXXX v. NewRez LLC ( XXXX. XXXX. ) and XXXX v. Shellpoint Mortgage Servicing ( XXXX. Md. ), establishing a nationwide blueprint for coercive servicing. XXXX. Obstruction of Error Resolution and Federal Oversight The enterprises wrong company response to RESPA Notices of XXXX that complaints were mis-directed despite consolidated ownershipis a deliberate obstruction under XXXX U.S.C. XXXX and violates XXXX C.F.R. XXXX ( XXXX ). Every consumer invoking statutory review rights is met with the same misrepresentation, depriving the public of the protections XXXX codified through XXXX XXXX XXXX XXXX ). XXXX. Economic and Psychological Damage Consumers suffer cumulative harms that regulators have recognized as unfair, deceptive, or abusive acts or practices ( UDAAPs ) under XXXX U.S.C. XXXX : XXXX : late fees, negative amortization, inflated escrow shortages, and loss of refinance eligibility. Credit : false delinquency reporting to XXXX XXXX XXXX U.S.C XXXX XXXX ( a ). Emotional : stress, reputational harm, and loss of housing stabilitythe same categories compensated in CFPB XXXX XXXX XXXX Bank XXXX. ( XXXX XXXX XXXX ). Your recordwhere Shellpoint issued a foreclosure threat while holding documented fundsdemonstrates these harms at the micro level, while the national docket of similar suits proves macro-level replication. XXXX. Market Integrity and Investor Deception Because XXXX XXXX consolidates subsidiary servicing income and uses those revenues to justify public equity sales ( as in its {$750.00} XXXX ATM program ), every falsified consumer ledger inflates corporate earnings. This constitutes a false statement of material fact under XXXX U.S.C. XXXX ( b ) and XXXX C.F.R. XXXX, mirroring SEC precedents such as SEC v. XXXX XXXX XXXX. XXXX. XXXX ). When millions of consumer accounts are handled through the same unlawful accounting method, both retail borrowers and capital-market investors are defrauded simultaneouslythe dual-victim hallmark of a racketeering enterprise. Conclusion : Public Harm Beyond Individual Accounts The identical misconduct confirmed in your casefunds sequestered, statements falsified, wrong company denials, and intimidation via foreclosure noticesappears across dozens of federal dockets, CFPB complaint records, and settlement orders. This establishes : XXXX. Continuity : the enterprise has operated with the same unlawful methods for years ( XXXX ). XXXX. Relationship : the acts are interdependent across XXXX, NewRez, and Shellpoint structures. XXXX. XXXX XXXX : every consumer loan they service is exposed to the same risk of financial and legal injury. Accordingly, the matter transcends private dispute and constitutes a systemic threat to consumer financial protection and market integrity, warranting full enforcement under XXXX U.S.C. XXXX ( b ) and referral to the DOJ and SEC for coordinated XXXX and securities-fraud prosecution. Introduction & Background of Servicing Entities The mortgage-servicing group composed of XXXX XXXX XXXX XXXX XXXX parent ), NewRez LLC XXXX XXXX subsidiary ) and Shellpoint Mortgage Servicing ( operating arm ) has drawn increasing regulatory, consumer-class action, and investor scrutiny over multiple jurisdictions and legal theories. These exposures provide a credible backdrop for alleged enterprise misconduct under the XXXX XXXX and Corrupt Organizations Act ( XXXX ) and federal consumer protection statutes : In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing, No. XXXX ( D. Md. ), borrowers alleged that Shellpoint systematically failed to provide required notices under the Real Estate Settlement Procedures Act ( RESPA ) and imposed fees in violation of the Maryland Consumer Debt Collection Act and the Maryland XXXX XXXX XXXX. In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing and The Bank of New York XXXX XXXX XXXX XXXX XXXX ( D. XXXX. ), the complaint alleges a pattern of zombie second-mortgage practices : inflated balances, failure to send statements to XXXX bankruptcy borrowers, and foreclosure threats on dormant liens. In XXXX XXXX NewRez LLC XXXX Shellpoint Mortgage Servicing, XXXX ( S.D. XXXX. ), a class action alleges that Shellpoint ( via acquired entity SLS ) charged pay-to-pay telephone payment fees up to {$7.00} far above processor cost thereby over-charging borrowers in violation of the Texas Fair Debt Collection XXXX and like statutes in other states. Consumer-complaint data filed with the CFPB show multiple narratives against NewRez/Shellpoint for XXXX XXXX XXXX, including failure to timely credit or apply payments, inadequate responses to RESPA Notices of XXXX, and misleading statements of arrearage. Recent media reporting characterises XXXX XXXX XXXX a legal and foreclosure storm in XXXX as lawsuits mount and servicing portfolio issues proliferate. Independent class-action settlements exist : for example, Shellpoint agreed XXXX a {$500000.00} settlement in XXXX to resolve claims of misleading statements sent to borrowers in XXXX XXXX forbearance. Corporate disclosures and filings indicate Rithm Capital ( formerly New Residential ) consolidates the servicing revenues of NewRez and Shellpoint and sells equity via XXXX ( ATM ) offerings tied to those revenues. I. Overview The enterprise consists of XXXX XXXX XXXX and its wholly-owned subsidiaries NewRez LLC and Shellpoint Mortgage Servicing, aided by XXXX XXXX XXXX XXXX XXXX counsel and XXXX investment banks as distribution agents for XXXX {$750.00} XXXX ATM equity program. Evidence demonstrates an ongoing pattern of servicing manipulation, false disclosures, and investor enrichment through unapplied-fund misallocation, constituting predicate acts under XXXX U.S.C. XXXX, XXXX, XXXX, XXXX, XXXX, and XXXX ( d ). XXXX. Organizational Structure and Control Layer Function Primary Actors Parent Entity Controls mortgage revenues, SEC reporting, and stock issuances XXXX XXXX ( XXXX ), XXXX XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ) Servicing Subsidiary Implements accounting and fund allocation policies XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX Operating Arm Executes collection and ledger activity XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX Provides filing cover and opinion letters XXXX XXXX XXXX ( XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX XXXX XXXX ) Investor Syndicate Profits from inflated earnings XXXX, XXXX XXXX, XXXX, XXXX, XXXX XXXX, XXXX, XXXX XXXX XXXX. Statutory Violations and XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX C.F.R. XXXX ( c ) ( XXXX ) ; XXXX U.S.C. XXXX ( a ) ( XXXX ) ( A ) XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) Payments diverted into unapplied accounts ; late fees assessed contrary to XXXX XXXX XXXX Failure XXXX C.F.R. XXXX XXXX XXXX Bank XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX. XXXX XXXX ) Ignored or false responses ( wrong company ) to RESPA notices. XXXX XXXX XXXX XXXX. XXXX ( a ), XXXX ( a ) ( XXXX ) ( B ) CFPB XXXX XXXX XXXX Bank XXXX. ( XXXX XXXX XXXX ) False statements of delinquency and corporate responsibility. Mail / XXXX XXXX XXXX U.S.C. XXXX, XXXX XXXX v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ) XXXX of fraudulent statements and records through interstate channels. Bank XXXX XXXX XXXX. XXXX United States v. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Diversion of mortgage payments to internal pools to inflate revenue. False SEC Disclosures XXXX U.S.C. XXXX ; XXXX U.S.C. XXXX SEC XXXX XXXX, XXXX XXXX XXXX ( C.D. XXXX. ) Certifying filings omitting subsidiary liabilities and CFPB exposure. Extortion ( XXXX XXXX ) XXXX U.S.C. XXXX United States v. Enmons, XXXX XXXX XXXX ( XXXX ) Foreclosure threats despite acknowledged funds ; coercive collection. Obstruction of XXXX XXXX U.S.C. XXXX XXXX v. XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Concealment of violations after CFPB / TNDFI notice. XXXX XXXX XXXX U.S.C. XXXX ( d ) H.J. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ; United States XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( D.D.C. XXXX ) Coordinated enterprise across subsidiaries and agents for ongoing fraudulent gain. IV. XXXX XXXX and XXXX Closed-ended continuity : XXXX repetitive predicate acts ( payment misallocation, false notices, threats ). Open-ended continuity : Enterprise structure persists, creating ongoing risk to consumers and markets. Each act satisfies the pattern of racketeering activity under XXXX, XXXX. v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ). Insider Trading and Certifier Liability Matrix Integrated Legal Interpretation Tier XXXX XXXX XXXX XXXX ( Parent Entity ) XXXX XXXX XXXX XXXX XXXX Form XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} {$1.00} XXXX value. XXXX : XXXX XXXX XXXX XXXX ( XXXX ) : Converted Class B Profit Units to cash during active concealment of NewRez/Shellpoint liabilities ; violates Rule XXXX, SOX XXXX, and XXXX where certifiers profit from materially misstated consolidated results. XXXX XXXX XXXX Chief Financial XXXX Form XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares + XXXX Class B Profit Unit tranches @ {$11.00} {$1.00} XXXX. Enrichment ( XXXX ) : Granted equity based on overstated servicing-segment earnings ; as CFO and SOX certifier, bears primary liability under SEC v. XXXX, XXXX XXXX XXXX. XXXX XXXX ( S.D.N.Y. XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX XXXX Transaction ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00}. Enrichment ( XXXX ) : Oversaw subsidiary legal reporting ; participated in filing false SEC certifications while supervising ongoing RESPA and XXXX XXXX violations direct predicate acts under XXXX U.S.C. XXXX ( XXXX ) ( XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Benefited from director-stock issuance while subsidiary revenues were inflated through improper capitalization of unapplied mortgage payments. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Timing aligns with inflated XXXX XXXX earnings attributed to the Servicing segment, satisfying the XXXX v. XXXX XXXX inference of scienter for XXXX actions. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Profited from compensation plan executed during known violations of XXXX C.F.R. XXXX ( c ) ( XXXX ) ( payment-crediting ). XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( XXXX XXXX XXXX ). XXXX ( XXXX ) : Stock granted within XXXX days of CFPB escalation regarding NewRez payment allocationwillful ignorance sufficient for reckless misrepresentation liability. XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX / XXXX / XXXX ) : XXXX shares @ {$11.00} ( AIF XXXX XXXX XXXX ). XXXX ( XXXX ) : Equity award contemporaneous with Shellpoints classification of unapplied-funds income as revenueconstitutes unjust enrichment under XXXX ( XXXX ) of Restitution XXXX. Tier XXXX NewRez LLC ( Servicing Subsidiary ) Corporate Officers : XXXX XXXX ( XXXX ), XXXX XXXX ( Head of Originations ), XXXX XXXX ( Head of Servicing ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( Chief XXXX & XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ), XXXX XXXX ( XXXX ). Liability Vector : Each participated in or benefited from deferred-compensation plans indexed to XXXX stock appreciation, which was artificially supported by revenue from unlawfully retained borrower payments. Violations include XXXX C.F.R. XXXX ( b ) ( XXXX ) ( failure to correct payment-posting errors ) and XXXX U.S.C. XXXX ( k ) ( servicer duties ). Precedents : XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) ; XXXX XXXX XXXX Mortgage XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) both holding servicers liable for misallocation and misrepresentation of payments. Tier XXXX Shellpoint Mortgage Servicing ( NewRez Operating Arm ) Key Executives : XXXX XXXX ( XXXX ), XXXX XXXX ( Co-CEO ), XXXX XXXX ( VP Recovery ), XXXX XXXX ( VP Servicing Strategy & Process Improvement ), XXXX XXXX ( XXXX Bankruptcy ), XXXX XXXX ( XXXX XXXX ), XXXX XXXX ( XXXX Loss Mitigation ), XXXX XXXX ( XXXX XXXX Analytics ). XXXX XXXX : Performance bonuses tied to cash-flow throughput metrics incorporating unapplied-funds balancesdirectly contravening XXXX C.F.R. XXXX ( c ) ( XXXX ) ( payment-application rule ) and XXXX C.F.R. XXXX ( XXXX ) ( error-resolution ). Such actions further qualify as predicate acts of mail and wire fraud under XXXX U.S.C. XXXX and XXXX, sustaining XXXX jurisdiction ( Sedima v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ). XXXX XXXX XXXX XXXX. Consolidation under XXXX ASC XXXX : XXXX XXXX certifies the financials of NewRez and Shellpoint, creating joint and several responsibility for any misstatement. XXXX. False Wrong Company Responses : constitute willful misrepresentation under XXXX XXXX. XXXX and deceptive-practices violations of XXXX U.S.C. XXXX ( CFPB XXXX authority ). XXXX. Investor Reliance : Each insider sale occurred after the deceptive wrong company filings were issued to regulatorsevidence of knowledge and motive consistent with SEC XXXX Texas XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). XXXX. Pattern of XXXX : At least XXXX predicate acts ( mail fraud, wire fraud, securities fraud ) within 10 years satisfy XXXX U.S.C. XXXX ( XXXX ). Regulatory and Civil Exposure CFPB Complaints ( XXXX Filed XXXX ) : Demonstrate systemic failure to apply payments, issue XXXX acknowledgments, or correct errors within statutory deadlines. Tennessee XXXX Inquiry : Triggers multi-jurisdictional enforcement ; pattern meets criteria for referral under XXXX U.S.C. XXXX ( c ) ( XXXX ) and XXXX ( XXXX ). DOJ Exposure : Possible criminal referral for mail/wire fraud and obstruction of agency proceedings under XXXX U.S.C. XXXX. Damages and Relief Economic Loss : $ XXXX in unapplied funds and ledger distortion. Punitive and Statutory Damages : {>= $1,000,000} under RESPA XXXX ( f ) and XXXX XXXX ( c ). Emotional and Credit Damage : Resulting from false delinquency and threat letters while account was current. V. Regulatory Misrepresentation Wrong Company Defense XXXX and NewRez routinely responded to CFPB and XXXX complaints claiming wrong company. SEC filings prove 100 % ownership and consolidation of Shellpoint revenues. Statutory Exposure : XXXX U.S.C. XXXX ( k ) ( XXXX ) ( C ) ( RESPA misrepresentation ) XXXX C.F.R. XXXX ( XXXX ) ( XXXX ) ( i ) ( failure to provide substantive response ) XXXX U.S.C. XXXX ( b ) ; XXXX C.F.R. XXXX ( false material statement to investors ) XXXX U.S.C. XXXX ( false statement to federal agency ) XXXX U.S.C. XXXX ( SOX criminal certification liability ) Interpretation : The defense constitutes a knowing attempt to evade federal jurisdiction and maintain enrichment through false corporate distinctionqualifying as a XXXX predicate under XXXX ( XXXX ) ( B ). VI. Insider Trading & Certifier Liability Matrix Distribution and XXXX XXXX Investor XXXX XXXX XXXX Investor and XXXX XXXX XXXX XXXX and XXXX XXXX XXXX XXXX XXXX XXXX {$750.00} XXXX At-the-Market ( ATM ) Equity Offering, as disclosed in its Form XXXX ( XXXX XXXX XXXX ), enumerated XXXX co-managing sales agents and underwriters. Each agent acted under contractual authority to sell shares from time to time on XXXX behalf into the open market. These entities, and the individual officers identified below, were directly notified of the ongoing allegations of securities falsification and servicing-based enrichment. Their continued participation following notice creates exposure under XXXX U.S.C. XXXX ( d ) ( XXXX conspiracy ), XXXX U.S.C. XXXX ( a ) ( control-person liability ), and XXXX ( XXXX ) of XXXX XXXX ( b ) ( knowing participation in tortious conduct ). Institution / XXXX Affiliation Function in Enterprise Legal Exposure XXXX XXXX XXXX XXXX XXXX. Co-Manager / Sales Agent Received and executed XXXX ATM equity sales under XX/XX/XXXX Form XXXX ; notified of servicing-fraud exposure. XXXX U.S.C. XXXX ( wire fraud ), XXXX ( d ) ( XXXX conspiracy ) XXXX XXXX XXXX XXXX XXXX. Co-Manager/ XXXX XXXX Participated in continuing ATM program following CFPB escalation; acted despite knowledge of violations. XXXX U.S.C. XXXX ( money laundering ), XXXX ( d ) XXXX XXXX XXXX XXXX Distribution Agent Executed trades benefiting from inflated Rithm earnings derived from NewRez/Shellpoint revenues. XXXX U.S.C. XXXX ( b ) ; XXXX C.F.R. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Coordinated sales while institution simultaneously held investment interests in XXXX XXXX trusts. XXXX U.S.C. XXXX ( d ) ; XXXX U.S.C. XXXX XXXX XXXX XXXX XXXX XXXX XXXX Distribution Agent Processed transactional filings under identical metadata ; complicit in resale of tainted securities. XXXX U.S.C. XXXX ( securities fraud ) XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Co-Manager Received investor notice documenting enforcement risk; failed to halt program. XXXX U.S.C. XXXX ( d ) ; XXXX U.S.C. XXXX J.T. XXXX XXXX XXXX XXXX XXXX Co-Manager Continued capital-raising activities after notice ; integrated illicit revenue streams. XXXX U.S.C. XXXX, XXXX ( d ) XXXX XXXX XXXX XXXX XXXX XXXX Co-Manager Accepted direct written notification of scheme ; distributed proceeds via ATM sales. XXXX U.S.C. XXXX ( a ) ( XXXX ) ( B ) ( i ) ; XXXX ( d ) Underwriter / Enrichment Layer Under the XX/XX/XXXX {$750.00} XXXX ATM XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) XXXX XXXX ( XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) XXXX XXXX XXXX XXXX ( XXXX. XXXX ) XXXX XXXX XXXX XXXX ( XXXX XXXX ) Interpretation Each of these XXXX named officers served under institutions explicitly listed in Rithm Capitals XX/XX/XXXX Form XXXX ( Exhibit XXXX ) as sales agents for the {$750.00} XXXX ATM equity program. Because they were directly copied on communications documenting the servicing and accounting fraud, their subsequent participation satisfies the knowing agreement standard under XXXX U.S.C. XXXX ( d ) ( United States v. XXXX, XXXX XXXX XXXX ( XXXX ) ; XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ). Shellpoint Mortgage Servicing XXXX Layer Operational Arm of Enterprise Finding Shellpoint Mortgage Servicing ( SMS ), a division operating under the NewRez LLC license, functions as the servicing apparatus for XXXX XXXX XXXX Its executives and department heads directly executed the borrower-facing misconduct that generated unlawful cash-flow inflations later consolidated into Rithms reported earnings. Shellpoints personnel acted as the functional endpoint of the enterprise, producing the predicate acts of mail, wire, and accounting fraud that sustained the parent corporations securities gains. Evidence Internal call transcripts ( XXXX XXXX ) and CFPB complaint filings document continuous misapplication of payments, concealment of unapplied funds exceeding {$100000.00}, and issuance of deceptive delinquency communications while accounts were current. These actions were performed under the authority of Shellpoints servicing leadership and recorded within NewRez-branded portals. Title Name Primary Role Liability Nexus / Predicate Act XXXX XXXX XXXX Dual-hatted XXXX across NewRez and Shellpoint. Authorized application of borrower payments into suspense to inflate servicing liquidity ; predicate act under XXXX U.S.C. XXXX ( wire fraud ). XXXX XXXX XXXX XXXX sign-off on payment-application policy. Endorsed wrong company response protocol to CFPB inquiries ; violation of XXXX U.S.C. XXXX ( false statements ). XXXX XXXX XXXX XXXX, XXXX Oversaw collections and foreclosure pipeline. XXXX issuance of automated foreclosure threats while unapplied funds existedconstituting attempted extortion and unfair practice under XXXX U.S.C. XXXX ( a ). XXXX XXXX XXXX, Servicing Strategy & Process Improvement Engineered data-processing schema linking NewRez and Shellpoint systems. Enabled cross-system data manipulation that disguised unapplied-funds totals ; breach of XXXX C.F.R. XXXX ( c ) ( XXXX ) ( crediting of payments ). XXXX XXXX XXXX, Bankruptcy Managed borrower accounts under bankruptcy protection. Failed to apply post-petition payments timely, violating XXXX U.S.C. XXXX ( i ) and RESPA XXXX ( k ). XXXX XXXX XXXX, XXXX XXXX escrow and hazard-insurance remittances. Misallocated escrow surpluses into suspense accounts, creating false delinquency records. XXXX XXXX XXXX, XXXX XXXX XXXX loan-modification pipeline. Concealed payment re-application tasks confirmed complete in call logs ; violation of XXXX C.F.R. XXXX ( loss-mitigation process ). XXXX XXXX XXXX, XXXX XXXX XXXX for performance and audit metrics. Produced internal metrics rewarding retention of unapplied balances ; foundational to Rithms inflated cash-flow throughput. XXXX XXXX leadership orchestrated a servicing model that contravened federal consumer-finance statutes while enriching parent executives through distorted earnings. The call-record evidence establishes knowledge and pattern : each agent acknowledged unapplied funds, confirmed payments, and yet continued delinquency reporting. Key precedents amplify liability : XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) : servicer liability for misapplied payments under RESPA XXXX ( f ). Marais v. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) : failure to investigate borrower disputes constitutes independent damages. XXXX v. XXXX Mortgage XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) : repetitive misapplication satisfies pattern for treble damages. These rulings establish that each missed correction and false delinquency notice is a discrete statutory violation and XXXX predicate. When multiplied across tens of thousands of loans serviced under the same scheme, XXXX acts become the operational backbone of a XXXX ( c ) racketeering enterprise. XXXX XXXX XXXX. Criminal Exposure : Continuous misrepresentations to borrowers and regulators satisfy mail- and wire-fraud predicates ( XXXX U.S.C. XXXX, XXXX ) and false-statement liability ( XXXX ). XXXX. Civil Damages : Each RESPA error-resolution failure carries per-violation statutory damages up to {$2000.00} per borrower, multiplied across portfoliosplus treble recovery under XXXX XXXX ( c ). XXXX. Regulatory Sanctions : CFPB and Tennessee XXXX possess concurrent jurisdiction ; patterns mirror prior enforcement in In re XXXX XXXX, File No. XXXX. XXXX. XXXX XXXX : Shellpoints manipulation of ledgers directly increased XXXX XXXX reported earnings, establishing parent-subsidiary unity under XXXX XXXX XXXX and negating any separate-entity defense. XXXX. Damages Quantification : Current documented loss {$100000.00} in unapplied funds plus consequential and punitive damages of {$5.00} millionconstitutes both individual injury and representative harm warranting class treatment. Expanded Enterprise Roster NewRez LLC Leadership Layer Finding NewRez LLC operates as a wholly owned subsidiary of XXXX XXXX XXXX, functioning as the parents licensed mortgage originator and primary residential loan servicer. Despite public separation rhetoric, XXXX officers report upward to the XXXX XXXX XXXX committee, participate in the same deferred-compensation pool, and certify ledger data ultimately consolidated in XXXX XXXX and XXXX filings. Evidence Metadata from the SEC XXXX prospectus and NewRez organizational materials confirms direct hierarchical and financial integration between XXXX and its subsidiaries ( XXXX XXXX, XXXX ). Internal filings and CFPB complaint responses further reveal that all operational communications from Shellpoint Mortgage Servicing route through XXXX systems. Title Name Primary Role Liability Nexus / XXXX XXXX XXXX XXXX XXXX XXXX approval authority for all Servicing and Originations revenue reports. Authorized subsidiary attestations underpinning overstated cash-flow ratios used in XXXX equity-based XXXX formulastriggering exposure under XXXX U.S.C. XXXX ( b ) and XXXX C.F.R. XXXX. XXXX XXXX XXXX of XXXX XXXX broker and lender channels. Tied to improper cross-posting of fees into Servicing income lines, contravening XXXX C.F.R. XXXX ( d ). XXXX XXXX XXXX of XXXX / XXXX of Shellpoint XXXX role across entities. Maintained systems that converted unapplied borrower payments into cash-flow throughput performance metrics ; predicate acts under XXXX XXXX. XXXX ( wire fraud ). XXXX XXXX XXXX XXXX XXXX XXXX of servicing policy and data management. Failure to maintain XXXX error-resolution workflow in violation of XXXX C.F.R. XXXX ( XXXX ). XXXX XXXX XXXX XXXX XXXX XXXX reporting to XXXX XXXX enterprise analytics. Participation in consolidated reporting that ignored regulatory exposure, violating XXXX XXXX XXXX XXXX XXXX known trends and uncertainties ). XXXX XXXX XXXX XXXX & XXXX XXXX Provided internal certification to XXXX XXXX. Contributed to wrong company CFPB responses while acknowledging consolidated ownershipconstituting XXXX U.S.C. XXXX ( false statements ). XXXX XXXX XXXX XXXX XXXX XXXX subsidiary ledgers for consolidation. XXXX manipulated unapplied-funds balances ; liable under SOX XXXX XXXX and SEC v. XXXX XXXX XXXX XXXX. XXXX XXXX XXXX XXXX XXXX Managed cross-platform data link between NewRez and Shellpoint portals. Authorized data structures that misrepresented payment status, violating XXXX U.S.C. XXXX ( k ). XXXX XXXX XXXX XXXX XXXX Responsible for growth and partnership revenue. Benefited through incentive structures indexed to inflated cash-realization metrics. XXXX XXXX XXXX XXXX XXXX XXXX borrower-communication campaigns. Approved misleading account current messaging while internal ledgers showed unapplied balancesUDAAP breach under XXXX U.S.C. XXXX. XXXX XXXX XXXX XXXX XXXX XXXX bonus pool and performance metrics. Distributed incentive pay derived from illegal income recognition, satisfying the financial gain element under XXXX U.S.C. XXXX ( XXXX ) ( B ) ( XXXX ). Interpretation Each XXXX occupied a node in the servicing data chain that transformed borrower payments into revenue and bonus metrics. The identical timing between their internal certifications and Rithms XXXX XXXX insider-trading window supports the inference of coordinated knowledge and profit motive ( XXXX XXXX XXXX XXXX & Rights, XXXX XXXX XXXX XXXX XXXX ) ). Under XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ), servicers are directly liable for failure to investigate and correct payment errors regardless of parent directives. Because XXXX consolidates NewRez results, every misapplied dollar inflates parent earningsbinding both tiers under XXXX ASC XXXX and SOX certification liability. XXXX XXXX XXXX. Regulatory Exposure : Repeated breaches of RESPA XXXX ( k ) and TILA XXXX expose both NewRez and XXXX to CFPB XXXX and DOJ referral. XXXX. Civil Exposure : Pattern of misapplied payments and false delinquency threatens class-action replication ( Rawlings v. XXXX Mortgage XXXX XXXX XXXX ). XXXX. XXXX XXXX : Coordinated enrichment through data manipulation and insider sales sustains a XXXX XXXX ( c ) enterprise theory with predicate acts of wire fraud, mail fraud, and securities fraud. XXXX. Investor XXXX : Earnings distortion and insider disposition reduce investor confidence, aligning with the reckless disregard standard in XXXX re XXXX XXXX XXXX, XXXX. XXXX. XXXX XXXX and XXXX XXXX {$100000.00} in payments documented as unapplied in violation of XXXX C.F.R. XXXX ( c ) ( XXXX ). Psychological and financial harm from false delinquency and foreclosure threats. Material credit damage and increased interest costs. Aggregate enterprise enrichment through inflated servicing income and XXXX","date_sent_to_company":"2025-11-08T20:10:51.000Z","issue":"Trouble during payment process","sub_product":"VA mortgage","zip_code":"37066","tags":"Servicemember","has_narrative":true,"complaint_id":"17114085","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Shellpoint Partners, LLC","date_received":"2025-11-08T20:01:57.000Z","state":"TN","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Payment process"},"highlight":{"complaint_what_happened":["Consumer-<em>complaint</em> data filed with the CFPB show multiple <em>narratives</em> against NewRez/Shellpoint for <em>XXXX</em> <em>XXXX</em> <em>XXXX</em>, including failure to timely credit or apply payments, inadequate responses to RESPA Notices of <em>XXXX</em>, and misleading statements of arrearage. Recent media reporting characterises <em>XXXX</em> <em>XXXX</em> <em>XXXX</em> a legal and foreclosure storm in <em>XXXX</em> as lawsuits mount and servicing portfolio <em>issues</em> proliferate."]},"sort":[4.281603,"17114085"]},{"_index":"complaint-public-v1","_id":"3377698","_score":3.3758297,"_source":{"product":"Credit card or prepaid card","complaint_what_happened":"COMMUNICATION BETWEEN XXXX XXXX AND CITI : I'm a XXXX-year-old single  XXXX woman who has lived in my home for over 40 years. I XXXX in XX/XX/XXXX for medical reasons. Since then Ive depleted my XXXX and have been doing my best to live on XXXX XXXX. Its only possible because I have a reverse mortgage and, therefore, no mortgage payments. Of course, the downside is that the mortgage company owns most of the equity in my house. My responsibility under the terms of the reverse mortgage is to pay my insurance premiums and keep my house in good repair. So, when my air conditioner flooded my bedroom and living room, it was my responsibility to get the damage repaired. \n\nIn XX/XX/XXXX, I hired XXXX XXXX XXXX XXXX to replace the floors throughout my house and to replace the walls and closets in the master bedroom which had been damaged by the flood. The contracts I signed total {$22000.00}. I paid XXXX XXXX {$18000.00} which included all of my savings, half of the insurance money awarded, and {$9000.00} charged to my Citi MasterCard. A {$3500.00} charge on XX/XX/XXXX to Citi for  XXXX XXXX was an obvious duplicate of the same charge on the previous day. It was removed from my account on XX/XX/XXXX, after I brought it to Citi 's attention. The remaining {$5500.00} remained on my MasterCard. I dont know if Citi recovered the {$3500.00} duplicate charge from the Mr. XXXX XXXX. \n\nMr. XXXX XXXX of XXXX XXXX abandoned the job on XX/XX/XXXX, after providing only a fraction of what he had promised to do and significantly damaging my home. Most important, he stole the money I had paid him to buy flooring for my entire house which he never bought. At that time, Citi suggested I dispute the charges for XXXX XXXX on my MasterCard because I had not received the services promised. The man in Citi Customer Service told me, Dont you worry, Citi has your back. The charges were removed from my account when I filed my dispute. \n\nOn XX/XX/XXXX, I received notice that my disputes were open and Citi sent forms for me to complete for the transactions on XX/XX/XXXXfor {$2000.00} and XX/XX/XXXX for {$3500.00}. On XX/XX/XXXX, since the two transactions I was disputing were identical, I submitted both of them on one Citi dispute form. With the form I sent copies of the contracts, a detailed explanation of the dispute, sales receipts, receipts of my payments, a list of all my email contacts with the merchant since he left and disconnected his phone, and photos of the damage to my property inside and out. \n\nOn XX/XX/XXXX, I received a letter from Citi saying they had completed the review of my {$2000.00} dispute for the charge on XX/XX/XXXX but did not have enough information to support the claim. The conditional credit, interest and fees were being reversed from my account, and they told me I should contact the merchant. There was no mention of the {$3500.00} charge on XX/XX/XXXX that I submitted with the {$2000.00}. \n\nI called Citi Billing Disputes when I received the letter. Because I submitted the two transactions on one dispute form with one set of attachments and their computer can only recognize one, it confused the computer. The {$3500.00} transaction was being processed and the {$2000.00} transaction was rejected since it appeared to the computer that it was submitted without documentation. They agreed to move the documentation attached to the {$3500.00} claim over to the {$2000.00} claim and reconsider it. \n\nOn XX/XX/XXXX, I received an email from Citi Billing Disputes regarding both claims. They needed three things : ( 1 ) If the service involved merchandise, I should make it available for the merchant to pick up, and they needed the date I attempted to return the merchandise with the merchants response to the return request for credit ; ( 2 ) The last date I received service ( which Id already clearly given to them in answer to the same question on the forms they had me complete and in the narrative I wrote ) ; and, ( 3 ) A review from second similar merchant with proof directly comparing the contracts with all items purchased and the comparison may not include only simple overviews. They noted that their system can only support black and white PDF copies. ( My color photos never made it to the Dispute Dept. ) The next day, XX/XX/XXXX, I called Billing Disputes and told them ( 1 ) I didnt receive credit from the merchant because I purchased services not supplies and had nothing to return for credit. Also, the merchant moved and was nowhere to be found ; ( 2 ) The last date of service was XX/XX/XXXX ; ( 3 ) I will obtain a report from a professional comparing the condition of my house to what was promised in the contracts. \n\nOn XX/XX/XXXX, I received an email from XXXX in Billing Disputes asking for the same information they had asked for on XX/XX/XXXX and I had answered by phone on XX/XX/XXXX. On XX/XX/XXXX I sent an email responding that ( 1 ) The dispute was for services only ; no merchandise was involved to return for credit ; ( 2 ) Last date of service was XX/XX/XXXX when Mr. XXXX XXXX sent his assistant to do some plaster work for a few hours ; ( 3 ) The XXXX   County Building Inspector who examined my home on XX/XX/XXXX in regard to the XXXX XXXX contracts agreed to follow up his visit with a report to Citi specifically explaining what he found compared to what had been promised. I would forward that report as soon as received. \n\nOn XX/XX/XXXX, I received an email from Billing Disputes which was a duplicate of the prior emails on XX/XX/XXXX and XX/XX/XXXX. I emailed them that I had sent the first two items of information requested and apologized for the delay sending the written review from the building inspector. I said Id follow-up and get back to them right away. \n\nOn XX/XX/XXXX, I talked to XXXX in Billing Disputes about the {$2000.00} transaction that was still on my statement. She said shed have an investigator reconsider the {$2000.00} dispute and take it off my statement while it was being reviewed. She told me to send the information they requested as soon as possible. \n\nOn XX/XX/XXXX, Citi Customer Service Team sent a letter to me regarding both transactions requesting the same three pieces of information requested in the XX/XX/XXXX email. It directed me to return the letter with the requested information by XX/XX/XXXX so Citi could continue the investigation. ( Theres a single reference number on the correspondence referring to both disputed transactions : XXXX. ) On XX/XX/XXXX, I sent an email to Billing Disputes telling them I realized I owed them the report comparing the services received to the services promised. I said today, for the third time, Id contacted the county building inspector who surveyed the job and said he would write the report for Citi. I again expressed to him the urgency of this matter and explained that, if I didnt hear back from him in two days, Id hire someone else to do the comparison. I told Billing Disputes about my conversation with XXXX on XX/XX/XXXX to remove the {$2000.00}, and explained, once again, that Id sent the first two pieces of information ( which I repeated ). \n\nOn XX/XX/XXXX, I called Customer Service and spoke to XXXX who eventually transferred me to Billing Disputes where I talked to XXXX. I wanted to let someone know the report and last piece of information they needed was on the way and to ask that my dispute not be closed until they had it to complete the review. XXXX said there was nothing he could do to assure my dispute would stay open but I should send the information right away. XXXX said I may get a couple extra days before my cases were closed depending on the investigators case load. If the investigator had a heavy caseload, my disputes could sit on the desk for a day or two before review in which case they could be accepted after the deadline. However, if the inspector picked up the disputes to review them on XX/XX/XXXX and the  information requested was missing, the cases would be closed for good. Apparently, these are rules established by Mastercard, not Citi, and are not flexible. \n\nAt XXXX XXXX on XX/XX/XXXX, I sent an email to Billing Disputes explaining that Id tried to keep them updated on my attempts to get the letter they needed. I told them it was promised to me by the XXXX County Building Inspector who investigated the job in depth for the county hearing and, since the county needed the same information Citi was requesting, the inspector said he would write the letter to Citi from his report. I wrote that despite my phone calls and emails, he hadnt done so, and that Id had to hire someone else who was reviewing the job and contracts and emailing his report to them that day. I summarized my story, the money Id lost, how Id tried my best to provide everything Citi needed, and how important it was for them to decide in my favor. I pleaded with them to wait until they had the report later that day before making a final decision. \n\nAt XXXX XXXX on XX/XX/XXXX, as promised, I sent an email to Billing Disputes with a detailed 2-page letter from a professional ( approved in advance by Citi ) comparing the services  promised by XXXX XXXX XXXX to the services they actually provided and didnt provide. I said Id told them, at least six previous times, the last date of service was XX/XX/XXXX,  and that I had also explained several times that I received services and, therefore, had no supplies to return to this merchant. Also, that I had told them Mr. XXXX XXXX had moved from his apartment, disconnected his phone, closed his business and was nowhere to be found. \n\nOn XX/XX/XXXX, I received an email from XXXX in Billing Disputes referring to both transactions. He requested ( 1 ) the last date I expected service ; and, ( 2 ) a description of service with itemized invoice. \n\nOn XX/XX/XXXX, I emailed Billing Disputes that : ( 1 ) The last date I expected service was sometime prior to XX/XX/XXXX, when my homeowners insurance was due to expire. My policy was not being renewed due to the flood damage but I was told the company would consider reinstatement if the damage was repaired prior to the expiration of my current policy on XX/XX/XXXX. Mr. XXXX XXXX assured me the job would be finished in no more than two weeks when we signed the contracts in XX/XX/XXXX. I reminded him on a regular basis how important it was for him to complete the job before my insurance expired. ( 2 ) I attached copies of the contracts with detailed descriptions of the services to be performed and the charges. \n\nOn XX/XX/XXXX, I received a letter from Citi thanking me for sending the information they requested regarding the {$3500.00} transaction on XX/XX/XXXX disputed as of XX/XX/XXXX. \nOn XX/XX/XXXX, Citi Customer Service Team sent me a letter regarding both the {$2000.00} and {$3500.00} transactions. It said that Citi was not able to further assist me since I didnt respond to their request for documentation supporting merchandise was made available for pick-up. They said they needed this to support their request for credit from Mr. XXXX XXXX bank. The letter also said any further dispute would have to be directed to the merchant, that the Citi investigation was completed, and that the conditional credits for these charges + interest + fees were rebilled to my Citi MasterCard. \n\nI had clearly explained to Citi on numerous occasions that I received services not merchandise. I also had told them more than once that the merchant, Mr. XXXX XXXX, was nowhere to be found -- - not by me, the County, the police, or the State. I had explained to Citi that he had moved his family from their apartment, disconnected his phone, closed his business and his XXXX  XXXX XXXX bank account. \n\nI called Customer Service in response to the XX/XX/XXXX letter and explained the situation again. They told me that once a dispute was closed, it could not be reopened ( Mastercard rules, not theirs ) but that I could resubmit the disputes and they would be considered. \n\nNote : On XX/XX/XXXX,. before I had received Citi 's XX/XX/XXXX rejection letter, I called them to see when I could expect to see the charges on my bill conditionally removed. I was told it generally takes 7-10 days to remove dispute charges. I also called to check on the status of my claim and was told the person working on my disputes would call me in 3-5 days. \nOn XX/XX/XXXX, I resubmitted the disputes. I sent four emails to Citi, two for each transaction ( {$2000.00} and {$3500.00} XXXX because there were too many attachments for any single email, and I was required to send duplicates of all documents to allow each transaction to be processed independently. To further support my disputes, this time I was able to include the XXXX County Order that fined XXXX XXXX {$1000.00} and ordered them to pay me {$17000.00} for services they didnt provide. The Order also recommended I receive {$5000.00} from XXXX County, the maximum retribution they can pay. ( This has since been awarded to me. ) Mr. XXXX XXXX did not show up at either of the hearings. I followed up with Citi by calling Billing Disputes to assure they had received my new claims. They received them on XX/XX/XXXX and told me to give them 7-10 days to review. \n\nOn XX/XX/XXXX, Citi sent me a letter thanking me for providing the information they requested regarding the {$2000.00} dispute on XX/XX/XXXX and assigned it a claim number. \n\nOn XX/XX/XXXX, I received a call from Citi saying my account was overdue. I was automatically paying $ XXXX/mo. on my account toward a 0 % interest balance transfer so it would be paid off when due XX/XX/XXXX. Because they had added the conditional disputes, etc. back to my account, {$100.00} didnt cover my minimum payment. I told them Billing Disputes had received my disputes on XX/XX/XXXX and said it would be 5-7 days before the charges were conditionally removed from my account again ; therefore, I thought my {$100.00} payment would be more than required to cover my minimum payment. Obviously that hadnt happened so I paid the extra amount due. Then I talked to XXXX in Billing Disputes who told me he would assure the two transactions ( total {$5500.00} ) and the accumulated interest ( {$210.00} ) be removed from my account while my disputes were being  reviewed. \n\nOn XX/XX/XXXX, Citi Customer Service Team sent me a letter regarding both disputes. It said that, as they had told me in previous letters, Citi has no further recourse in this matter. The investigation was closed. The letter also said this was their final letter about the matter and I should consider this investigation complete. \n\nOn XX/XX/XXXX, before I received the XX/XX/XXXX letter, I received another collection call. I called XXXX in Billing Disputes and was told the interest would be removed and my account would be adjusted. He told me not to worry because, even if they denied my disputes and put them back on my account, they would not charge me interest for the time they were being reviewed. ( Unfortunately, XXXX was wrong. ) On XX/XX/XXXX, I called Billing Disputes and spoke with XXXX about the XX/XX/XXXX denial letter. XXXX told me to ignore the letter finalizing my claims, to tear it up. He explained that it was probably an old form letter sent out before the reviews on the resubmitted disputes began. He said something about my disputes being high dollar cases that took longer to be reviewed. He told me to wait 7-10 days and call back if I hadnt heard anything, and if I was asked for any more information, to give it to them asap. He also said that I should disregard anything else that was not from the investigator reviewing the second submissions. \n\nIn mid-XX/XX/XXXX, I called Citi to find out the status of the duplicate set of disputes I submitted. In summary, I was told the XX/XX/XXXX letter was correct and final and to drop it. For a month I tried to get the reason my disputes were denied. I talked to Customer Service and Client Focus and Billing Disputes on numerous occasions. I spoke to supervisors and managers and tried to obtain an email or other address for anyone who could at least tell me why I was denied. One man said it was because I didnt try to return the merchandise for credit as Citi had requested multiple times. When I told him there was nothing to return, the merchant was gone, and I had told Citi this many times, he said I should have ripped up the flooring that was installed and returned it to XXXX XXXX  for credit myself. Ridiculous! Who would have even thought to do this?! But I would have gladly had someone rip up the partial flooring and try to return it if anyone at Citi had told me that was what I needed to do to have them remove the {$5500.00} from my account! \n\nApproximately {$500.00} was spent on supplies and {$200.00} was estimated as the value of labor for all work done at my house before XXXX XXXX abandoned the job. I even asked Citi to deduct this entire amount from the {$5500.00} charged on my Mastercard and remove the remaining {$4800.00} from my account as payment for services not received. I already had sent Citi receipts for the few supplies purchased and statements from XXXX County and a letter from another professional detailing what little work was done before leaving my home looking like a war zone. My request to Citi was denied. I was told that, if I received any part of the services promised, no matter how insignificant, Citi had to treat my dispute as a complaint about receiving unsatisfactory services and any attempt to rectify the situation would have to be directed to the merchant. \n\nWhen Citi reversed the XXXX XXXX charges and interest back to my account, I didnt have the money to pay the bill in full. I increased my monthly payments to {$200.00} because so much of my payment was going to pay interest. ( Ive always paid my bills in full and dont remember ever paying interest on a charge account in 50 years -- - until now. ) I called Citi Customer Service and explained that my retirement savings were spent, and I was having difficulty trying to live on $ XXXX/mo. XXXX XXXX. I told them I had no idea how I could pay my routine expenses plus add this {$5500.00} for services I never received and pay a new contractor to do the work XXXX XXXX was supposed to have done. I pleaded with them, since I was a loyal, long-time customer, to at least lower my interest rate. \n\nOn XX/XX/XXXX, a letter was sent to me from XXXX XXXX, V.P. declining my request for payment assistance to amend some of the terms of your existing Credit Card XXXX because I didnt qualify as an extreme hardship case. \n\nOn XX/XX/XXXX, I called Citi Customer Service to ask for part of my payment to go toward paying down my balance transfer debt so I could pay it in full when it became due. They said my payment had to be applied toward the charges with the highest interest, XXXX XXXX {$5500.00} charges. \n\nOn XX/XX/XXXX, I called the number the XX/XX/XXXX letter directed me to call. After I went through my entire story and asked them to explain the letter, I was told they didnt handle extreme hardship in that department and transferred me to Client Focus. I explained my circumstances and asked why I didnt qualify as an extreme hardship case. They couldnt tell me. I asked for the definition of extreme hardship or a hypothetical case so Id better understand why I didnt qualify. They didnt answer. I ended up with the direct phone number to Client Focus and instruction to call them in a few weeks so they could further investigate my case. \n\nOn XX/XX/XXXX, I called Client Focus directly. After telling my story one more time, I was told they would reevaluate the extreme hardship decision and get back to me. I never heard back from anyone. \n\nI'm attaching what I think will be helpful to support my complaint including the contracts ; the report requested by Citi from a professional comparing the contracts to work done ; the page from my Citi MasterCard statement with XXXX XXXX charges ; the citation issued following the county hearing, and, receipts for all purchases by Mr. XXXX XXXX. I have copies of all my payments to Mr. XXXX XXXX ; a summary of all my emails to and from Mr. XXXX XXXX, the dispute forms sent to Citi ( three times ), and other documents I can make available if needed. \n\nI continue to work with an attorney from XXXX XXXX XXXX and with the attorney who has been assigned this case in the State Attorney 's office. The State recently located Mr. XXXX XXXX living in XXXX XXXX, FL,. He was arraigned by the State Attorney 's Office on XX/XX/XXXX and has a hearing scheduled for XX/XX/XXXX","date_sent_to_company":"2019-09-18T21:03:11.000Z","issue":"Problem with a purchase shown on your statement","sub_product":"General-purpose credit card or charge card","zip_code":"333XX","tags":"Older American","has_narrative":true,"complaint_id":"3377698","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"CITIBANK, N.A.","date_received":"2019-09-17T04:09:52.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Credit card company isn't resolving a dispute about a purchase on your statement"},"highlight":{"complaint_what_happened":["the contracts with all items purchased and the comparison may not include only simple <em>overviews</em>."]},"sort":[3.3758297,"3377698"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":5,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":5}]}},"product":{"doc_count":5,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking or savings account","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking account","doc_count":1}]}},{"key":"Credit card or prepaid card","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"General-purpose credit card or charge card","doc_count":1}]}},{"key":"Money transfer, virtual currency, or money service","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Money order, traveler's check or cashier's check","doc_count":1}]}},{"key":"Mortgage","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"VA mortgage","doc_count":1}]}},{"key":"Vehicle loan or lease","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Loan","doc_count":1}]}}]}},"issue":{"doc_count":5,"issue":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Managing an account","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Deposits and withdrawals","doc_count":1}]}},{"key":"Managing the loan or lease","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Billing problem","doc_count":1}]}},{"key":"Problem with a purchase shown on your statement","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit card company isn't resolving a dispute about a purchase on your statement","doc_count":1}]}},{"key":"Problem with customer service","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Trouble during payment process","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Payment process","doc_count":1}]}}]}},"timely":{"doc_count":5,"timely":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Yes","doc_count":5}]}},"company_response":{"doc_count":5,"company_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Closed with explanation","doc_count":3},{"key":"Closed with monetary relief","doc_count":1},{"key":"Closed with non-monetary relief","doc_count":1}]}},"submitted_via":{"doc_count":5,"submitted_via":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Web","doc_count":5}]}},"company":{"doc_count":5,"company":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"BANK OF AMERICA, NATIONAL ASSOCIATION","doc_count":1},{"key":"CITIBANK, N.A.","doc_count":1},{"key":"PNC Bank N.A.","doc_count":1},{"key":"SANTANDER HOLDINGS USA, INC.","doc_count":1},{"key":"Shellpoint Partners, LLC","doc_count":1}]}},"state":{"doc_count":5,"state":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"AZ","doc_count":1},{"key":"CA","doc_count":1},{"key":"CO","doc_count":1},{"key":"FL","doc_count":1},{"key":"TN","doc_count":1}]}},"company_public_response":{"doc_count":5,"company_public_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","doc_count":3}]}},"tags":{"doc_count":5,"tags":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Older American","doc_count":2},{"key":"Servicemember","doc_count":2}]}}},"_meta":{"license":"CC0","last_updated":"2026-07-14T12:00:00-05:00","last_indexed":"2026-07-14T12:00:00-05:00","total_record_count":16441818,"is_data_stale":false,"has_data_issue":false,"break_points":{}}}