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BBB Accreditation

A BBB Accredited Business since

BBB has determined that Liberty Home Equity Solutions, Inc. meets BBB accreditation standards, which include a commitment to make a good faith effort to resolve any consumer complaints. BBB Accredited Businesses pay a fee for accreditation review/monitoring and for support of BBB services to the public.

BBB accreditation does not mean that the business' products or services have been evaluated or endorsed by BBB, or that BBB has made a determination as to the business' product quality or competency in performing services.


Reason for Rating

BBB rating is based on 13 factors. Get the details about the factors considered.

Factors that raised the rating for Liberty Home Equity Solutions, Inc. include:

  • Length of time business has been operating
  • Complaint volume filed with BBB for business of this size
  • Response to 9 complaint(s) filed against business
  • Resolution of complaint(s) filed against business


Customer Complaints Summary Read complaint details

9 complaints closed with BBB in last 3 years | 5 closed in last 12 months
Complaint Type Total Closed Complaints
Advertising/Sales Issues 1
Billing/Collection Issues 0
Delivery Issues 0
Guarantee/Warranty Issues 0
Problems with Product/Service 8
Total Closed Complaints 9

Customer Reviews Summary Read customer reviews

1 Customer Review on Liberty Home Equity Solutions, Inc.
Customer Experience Total Customer Reviews
Positive Experience 0
Neutral Experience 0
Negative Experience 1
Total Customer Reviews 1

Additional Information

BBB file opened: May 24, 2004 Business started: 01/02/2004 in CA Business started locally: 01/02/2004 Business under new ownership as of: 04/03/2013 Business incorporated 09/05/2003 in CA
Licensing, Bonding or Registration

This business is in an industry that may require professional licensing, bonding or registration. BBB encourages you to check with the appropriate agency to be certain any requirements are currently being met.

These agencies may include:

Department of Business Oversight
1515 K St. Suite 200, Sacramento CA 95814
http://www.dbo.ca.gov
Phone Number: (866) 275-2677
The number is 6072619.

National Mortgage Licensing System- NMLS

The number is 3133.

Type of Entity

Corporation

Business Management
Ms. Pamela Rodriguez, Operations Marketing Manager Ms. Melody Craigie, Compliance Team Lead Mr. James Fine, Assistant in Legal Dept. Ms. Meredith Manz, Compliance Marketing Review Analyst
Contact Information
Customer Contact: Mr. James Fine, Assistant in Legal Dept.
Principal: Ms. Pamela Rodriguez, Operations Marketing Manager
Business Category

Mortgage Lender Financial Services Reverse Mortgage

Products & Services

Liberty Home Equity Solutions, Inc. provides reverse mortgage services.


Customer Review Rating plus BBB Rating Summary

Liberty Home Equity Solutions, Inc. has received 0 out of 5 stars based on 0 Customer Reviews and a BBB Rating of A+.

BBB Customer Review Rating plus BBB Rating Overview

Additional Locations

  • 10951 White Rock Rd Ste 200

    Rncho Cordova, CA 95670 (800) 218-1415

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BBB Customer Review Rating plus BBB Rating Overview


BBB Customer Reviews Rating represents the customers opinions of the business. The Customer Review Rating is based on the number of positive, neutral and negative customer reviews posted that are calculated to produce a score.

Customer Review Experience Value
Positive Review 5 points per review
Neutral Review 3 points per review
Negative Review 1 point per review

BBB letter grades represent the BBB's opinion of the business. The BBB grade is based on BBB file information about the business. In some cases, a business' grade may be lowered if the BBB does not have sufficient information about the business despite BBB requests for that information from the business.
Details

BBB Letter Grade Scale

BBB Rating Value
A+ 5
A 4.66
A- 4.33
B+ 4
B 3.66
B- 3.33
C+ 3
C 2.66
C- 2.33
D+ 2
D 1.66
D- 1.33
F 1
NR -----
Star Rating scale

  Average Score
5 stars 5.00
4.5 stars 4.50-4.99
4 stars 4.00-4.49
3.5 stars 3.50-3.99
3 stars 3.00-3.49
2.5 stars 2.50-2.99
2 stars 2.00-2.49
1.5 stars 1.50-1.99
1 star 0-1.49

BBB Customer Review Rating plus BBB Rating is not a guarantee of a business' reliability or performance, and BBB recommends that consumers consider a business' BBB Rating and Customer Review Rating in addition to all other available information about the business. If the BBB Rating is NR then only Customer Reviews are used for the Star Rating.

Complaint Detail(s)

7/15/2015 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: I got into contract with Liberty some years ago with the reverse mortgage company. I took out money to have my floors done and I was paying $138.00 a month. I took out about $800 one time and paid the money back. The reverse mortgage company switched to Genworth reverse mortgage and then back to Liberty. So my house has been paid off since 2000 and now that I am sickly they are trying to say I owe $7000 and is trying to take me to court knowing I am elderly. This company is trying to take my home from me and I am trying to put my house on the market and move into a senior home and I need my deed to my house.

Desired Settlement: DesiredSettlementID: Other (requires explanation) I would like them to close the account out and send my deed to my house back to me. They can send it to **** ****** ** **** ***** ******* **** ******** *** *****. This man has been taking care of all my business and taking care of me very well. You can reach him at ************

Business Response: Liberty has sent a full explanation to the borrower regarding the origination of the loan and the loan's current status.  The loan in question was originated in 2009 which included paying off a prior mortgage.  The $7,000 mentioned in the complaint was not part of the initial loan balance; this amount reflects funds that were advanced by Liberty to pay for outstanding property charges such as tax and insurance.  This is amount remains unpaid and has caused the loan to go into a default status as required on a Home Equity Conversion Mortgage.  Liberty tries to work with all borrowers when events such as this occur, however we are required to follow specific servicing guidelines on FHA insured loans, especially when there are funds advanced to pay for delinquent property charges.

Consumer Response: I am rejecting this response because:I am rejecting this because my husband used his VA Loan to buy this  house. The loan I took out was for my floors and that was not that much. I took one loan and never used it again. So where do you get that small loan to a huge amount. I am 81 years old and I am no fool. The loan companies switched twice  from gentile to liberty and now you are trying to take my house.

Business Response: The borrower closed her reverse mortgage loan on June 11, 2009; this was not a small loan with a purpose to only pay for small repairs.  The loan initially paid off a prior lien with **** ** ******* which totalled $117,018.08 and is evidenced by the enclosed Final HUD-1 Settlement Statement as well as a Payoff from **** ** *******.  The borrower has been in litigation with Liberty Home Equity Solutions, Inc. since 2012 over this foreclosure matter.  Since the filing of this matter with the Chancery Division of Cook County, IL; the borrower has appeared in court where she would have been able to review or dispute any facts in this foreclosure matter. 

5/26/2015 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: I was misinformed regarding the requirements for the reverse mortgage. When I originally spoke with the ***** *****, I explained fully my financial position and why I was seeking knowledge on this type of loan. I was informed that to qualify for this loan I needed to have 50% to put down on a new purchase and the required mortgage insurance fees and closing costs. I would be responsible for the insurance, taxes, HOA fees and maintenance of the property. It was required that I be at least 62 years old. As no loan payments were required there were no further qualifications. I requested an application and Liberty Home Equity Solutions sent a notary with documents to meet with me. She explained all the documents as they were signed and the application was submitted. Upon request of a new purchase home I requested a prequalification letter and it was provided in the amount of $121,000. I was required to complete a counseling session at my own expense of $125.00, which took approximately 15 mins on the phone and the process of the loan was started. After the inspections were completed $280.00 and after the appraisal was completed $450.00, then I was informed that I would need to meet Debt to income ratios and that the qualifications for this loan was the same as any other loan. So as a result I incurred expenses of $855.00, only to realize that I was not going to qualify for this loan. As I said I was given a prequalification letter when there was no possible way I would qualify for this loan.I also lost my earnest deposit, $1000.00, as a result of this. THIS IS AN APPLICATION PROCESS THAT SUPPORTS EVERYONE EXCEPT THE BORROWER, THUS TAKING ADVANTAGE OF THE ELDERLY.

Desired Settlement: I want to be reimbursed for all of my expenses.

Business Response: Dear Ms ********:

 

I am writing to you in response to
a recent complaint submitted to the BBB regarding your loan application with Liberty
Home Equity Solutions, Inc. (“Liberty”).  In your complaint you state that you were not aware of the income
requirements for the Home Equity Conversion Mortgage (“HECM”) for purchase that
you were applying for and then withdrew your application.  The income requirements are in place to show
whether or not a potential borrower will be able to maintain the prospective
property along with any retained properties. 


 

Due to the sale of your current residence not taking place this income requirement would have come into effect
for this HECM for purchase transaction.  This was listed as one of the conditions to be satisfied on the
prequalification letter you mentioned in your complaint.  Item number five of conditions to be fully
satisfied on the prequalification letter states:

 

”You must provide us with evidence of sufficient income to maintain the costs
associated with the new home including the mortgage payment, taxes and insurance
of any retained properties”

 

Additionally, you state that youpaid out of pocket for an appraisal fee of $450.  Our records show that you received an
Appraisal Hardship Waiver which effectively waived the upfront appraisal fee of$300.  As for the earnest money deposit
that was provided to the seller’s escrow company per the terms of the purchase contract you entered with the sellers;
Liberty has no control over those funds and did not provide any guidance for the release of those funds. 

 

I would like to thank you for selecting Liberty for your potential home purchase and I do apologize if there
was any confusion over the loan requirements.  Unfortunately, Liberty will not be able to issue a reimbursement
for the loss of earnest money deposit, counseling fee or inspection fee.  The income requirement was addressed
with you per the conditions listed on the prequalification letter.  Also, it may be important to note that this
loan application was not declined by Liberty and it was actually withdrawn by you. 

 

If you have any additional information pertaining to your complaint or would like further clarification on
anything please feel free to contact me directly at ***** ********. 

 
 

Sincerely,

 


***** ****

Risk Mitigation Specialist

5/14/2015 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: After filing for a Reverse Mortgage, we were told that our home was only worth $33,000.00, according to our appraised value. We received a copy of the appraisal, and it said that our home is worth $77,000.00. That's a big difference. We were told that our loan would be $23,000.00, and we recieved 17,000.00 cash. I believe that we were subjected to a predetory loan

Desired Settlement: Please make up the differance between $33,000.00 and $77,000.00 in a line of credit.

Business Response: During the origination process of this loan in 2013 our direct endorsment underwriters and appraisal review team found discrepancies with the initial appraisal and the comparable sales used to value the subject property at $77,000.  After review and a separate "drive by" appraisal (which was not charged to the borrower) a value of $38,000 was determined to be more accepatble.  As a direct endorsement lender approved by the FHA it is our responsibility to approve lending values that are most appropriate for the subject property.  Although the appraiser used for this transaction was an independent FHA approved appraiser the lender still has authority to determine a lower property value if there are reasonable discrepancies.  The lowering of the value was addressed with the borrower prior to the closing of the loan and the borrower was also given a 3 day rescission period after reviewing and executing all of the closing documents.  We have reached out to the borrower and will be following up with any requests he may have. 

5/11/2015 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: I am very disappointed. The interest rates are touted as very low, which they are, but the total costs, including fees, amounted in my case to effectively changing the rate to borrow money from a little over 2% to over 13%, and the fees were downplayed until the last minute in each case, so I was encouraged to go ahead with the deal since I had already spent more than I could afford to unless I got the loan. The appraiser that they sent out came back with an appraisal that was ridiculously and suspiciously low, under 77% lower than both an appraisal I had only weeks before and the tax assessor's appraisal I received only days after their appraisal was done. Then the time that the whole process would take was said to be less than half of what it actually turned out to be. But the straw that broke this camel's back is this: After the entire mess was completed on Friday, and I was told that my money would be deposited directly in my account by the following Wednesday, it was not. Now it is the following Friday, and although I have e-mailed repeatedly and made numerous telephone calls asking for an explanation, all I am told is that the money was disbursed. When I asked for a 15 digit transit number, per the request of customer service at my bank so they could investigate the matter further, I was told that I would get a call back within 30 minutes with the number. It has now been over 24 hours, and I can not get a response to either e-mail or telephone calls. I am not only disappointed. I am disgusted and angry.

Desired Settlement: It is too late for them to rectify any of my complaints except the last one. That is, they need to do what they committed to do, and although they have already missed the date and time, they could at least do it as soon as possible, and in the meantime, they could do me the courtesy of responding to either my e-mail or my phone calls with an explanation or at least with the information which I requested and which, unless this is some sort of fraud, they should be able to provide in 30 seconds.

Consumer Response:

I filed a complaint yesterday, and everything I said in it was true, but about 3 hours later, my money finally came in, so I am now modifying my complaint in that particular part of the complaint. Everything else remains true.

I don't require a settlement now because, although I did not like the way they did it or the time it took, they did finally send me the money.

4/29/2015 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: I initiated a reverse mortgage months ago with Liberty Home Equity Solutions. In speaking with their representative, ****** ******, the process was supposed to be a piece of cake. However, this process turned into a nightmare. I was not informed on the front end that the appraisal would be used to qualify or disqualify me for a reverse mortgage. After the appraisal was received by the company, I was informed that there were several repairs/work to be completed before the loan could be completed. I received labor estimates for the work required. I was told that funds were being set aside to pay for this work. However, after the work was done, there were other hoops to jump through before the contractor could be paid. I was not informed up front that all work would have to be completed in order to get the funds released. Funds had been set aside, but I could not get them until all the work was completed. This meant I would have to pay for the repairs and maybe I would get reimbursed. All work has now been completed. Two weeks ago I asked for an inspection and was told the inspector would contact me within 3-5 business days. After the 5 days had passed and I had heard from no one, I called to inquire on April 15.. I was told the inspection had been placed on hold until an inspector accepted the job. I called again today, April 21, and was told they could not get an inspector to accept the job, therefor funds could not be released. They could not give me any timetable for when this might be resolved. In the meantime, the contractor has indicated he may have to take legal action to get paid. I would never recommend this company to anyone considering any type of mortgage. Liberty Home Equity Solutions has the worst customer service I have ever dealt with. At no time, even after I called them, did they ever contact me to advise me of anything. Worst company I have ever dealt with.

Desired Settlement: I would like this company to immediately provide an inspector to verify the work has been done and release the funds to pay for the work done.

Business Response: Liberty Home Equity Solutions, Inc. ("Liberty") has confirmed with the borrower that an inspector has been assigned and the inspector did reach out to the borrower.  Liberty has apologized for the borrower receiving anything other than exemplary customer service as that is what Liberty strives to provide to every customer.  Also, it was relayed to the borrower that the only reason for the delay in scheduling an inspector was due to the rural location of the subject property and the lack of FHA approved appraisers in the area.  Once Liberty received acceptance of the inspection from an FHA approved appraiser the borrower was contacted immediately. 

Consumer Response: I am rejecting this response because:  The entire process of obtaining a Reverse Mortgage has been one complete nightmare.  This company through it's representative ***** ******, never fully disclosed everything necessary for qualification for the mortgage.  I initiated the process in April of 2014.  It has taken a year, and everything is still not done.  The appraisal had to be recertified at an extra cost because time expired on getting some things done.  Disclosure of everything required should be made on the front end, not several months later.  I will state again,  lIBERTY hOME eQUITY sOLUTIONS, iNC HAS THE WORST CUSTOMER SERVICE OF ANY COMPANY i HAVE EVER DEALT WITH.  Their excuse of my having a rural home was never discussed with me.  I was told that after I requested a final inspection, it would take 3-5 business days for the inspector to call.  I was not contacted by an inspector or Liberty to inform me of the delay.  I had to call twice to find out why I had not heard anything.  They could not give me a definite answer as to when the inspection would be made.  There is a deadline of May 10 to get the work done and inspected or the loan will be called.  I was finally contacted on April 22 and told the inspector had tried to contact me but could not get in touch.  On April 25, the inspector called and scheduled the visit for April 27.  So, from the time I requested the inspection until the time the inspection was completed, was 17 business days.  I would not recommend this company to anyone who is applying for any type of mortgage.

5/19/2014 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: in jan 2014 i did a reverse mortage with liberty. at that time i asked **** ***** of liberty what all the fees were. she failed to tell me that with the appraisal of my home they would assess what my home needed for repairs. they had a notary come to my home with a 2 inch stack of documents for me to sign. i never knew of this provision. plus i have to pay for someone to see if i completed the repairs. i did not know of this and they are witholding $3500 of my money. i have received 8k so far, and to get out of this fraud, misrepresentation, and out right lies by this company, they want me to give them 15k plus to get out of this. the interest is supposed to be only on the money i have received which is like 3%. this is outright theft of an at risk adult, and a 2 time cancer survivor. this company preyed on me and my illness. i never got the full cost of this. this is my home and they think they can tell me how to run it. this place is a ripoff and i think they are crooks, they load you up w paperwork and put in stuff they never told me about. they are thieves.

Desired Settlement: they can have their money back but i will not pay 100% interest. i have gotton 8k so far and will refund that, but i will not give them 15k to get out of this. if we can come to an amicable solution, fine. but this is my home and they want to steal it by hidden costs and failure to inform me of all the fees. they are acting like its their home and im a renter and they can tell me what to do. they agreed on 97% on a line of credit when my home wa

Business Response:

this letter is to acknowledge our receipt of the correspondence submitted to you on April 22, 2014 regarding ****** *******' reverse mortgage loan with Liberty Home Equity Solutions, Inc. ("Liberty").
 
We are looking into the issues Mr. ******* asked us to address and you should expect our reply dated within the next 30 days.
 
We appreciate your taking the time to provide us with Mr. *******' feedback and we take his concerns seriously.
 
If you have any additional information relevant to his concerns or have any questions, please feel free to contact me.
 

Consumer Response: I am rejecting this response because: this whole process is bogus. i was never told about all the fees like the appraiser, unknown to me, also appraised what he thought were need repairs and after i do the repairs they send someone else out to ok the work and they charge me for that  inspection. i sent liberty $8100 though i received less than 2k a month for thr 4 months. now they say i still owe them almost another 8k over 4 months i was involved with this. i am willing to call it even and i will pay the appraisers cost if i receive a copy of the appraise** if not i will join a class action suit against liberty or sue them my self. the misrepresented their program and left out all the fees . they have a notary come to my house that knows nothing of the deal and cant explain it to me. and they have a 2 inch stack of documents for me to sign. if i could afford a lawyer to figure all this out, i would not need a reverse mortgage. this is about people,  not tricking people to do what they want without full disclosure. liberty said  they would give me 70% of my home value, but gave me only 97k when they appraised my home at 215k. this is fraudulent in itself. they take advantage of at risk adults just to make a sale. **** ***** was the agent that continued to call me about this and purposely misled me on the entire dea** i told her my whole situation, a 2 time cancer survivor and how i got swindled out my life savings. she used this info to delude me. she will also be a defendant if this suit as a liberty employee. this is a scam, so if liberty wants to settle this, ok. if not i will go pulic here in denver through the tv news stations, the denver post and westword newspaper. so the ball is in their court. i am prepared to sue them. i worked hard to buy my home and they are trying to scam me out of it. there is no place for this thievery whether they call it legal or not and i will sue hud also for false representation.

Business Response:

This letter is in response to the correspondence you received on April 22, 2014 regarding ****** *******' reverse mortgage loan with Liberty Home Equity Solutions, Inc. ("Liberty"). We review all customer inquiries promptly and we sincerely appreciate you bringing to our attention the concerns related to Mr. ********' loan transaction.
 
We understand Mr. *******' concerns to be in regards to the required repairs on his home as a condition of the loan. We also understand he has concerns about the closing fees and the interest rate on his loan.
 
Our review of the file reflects that we provided Mr. ******* with supporting documentation to evidence Liberty's careful compliance with federal lending requirements, including evidence that Liberty properly provided him with all mandatory disclosures regarding the fees, interest rate and loan terms. Under the Real Estate Settlement Procedures Act ("RESPA:"), the loan originator is required to provide the borrower with a Good Faith Estimate ("GFE") within three business of receiving a completed  loan application. Mr. *******' application was executed on November 23, 2013 and he acknowledged receipt of the GFE on the same day. The HUD-1 Settlement Statement was executed by him on January 15, 2014, together with other loan documentation, which properly disclosed the  closing costs and other charges related to the reverse mortgage loan as required under RESPA. The documentation found in the file reflects that Mr. ******* was provided with all required REPSA information regarding closing costs enabling him to make an informed and educated decision to enter into the HECM loan transaction.
 
In addition, as a requirement and prerequisite to obtaining a HECM loan, the borrower is required to attend counseling with an independent third party counseling agency approved by HUD. The counseling session is designed to ensure that a prospective borrower fully understands all aspects of the revers mortgage, including loan fees, rates, terms, borrower obligations, qualifications of the home and any required repairs. As indicated by the Certificate of HECM Counseling, Mr. ******* was counseled and on November 21, 2013, by a third party counselor.
 
The Home Equity Conversion Mortgage ("HECM") guidelines that all appraisals must be performed by a Federal Housing Administration ("FHA") approved appraiser. The appraisal dated December 12, 2013 was performed by ******* ** **** Appraisal Services. Mr. **** is an FHA approved certified residential appraiser whose current license is valid untilDecember 31, 2015. In his report, Mr. **** indicated that the appraisal for the subject property is subject to certain repairs being completed. The subject property was Repair Rider on January 15,2014 ($3,050) from the initial Principal Limit under the Loan Agreement to be used for the purpose of bringing the property up to the property standards as required by the Department of Housing and Urban Development ("HUD") by repairing the following: scrape and paint all peeling paint on the exterior of the home and garage. A copy of the executed Repair Rider has been included for your reference. 
 
Mr. *******' loan is currently being serviced by Celink. Once the repairs have been completed, he will need to contact Celink's Borrower Care Department at ###-###-####.
 
In response to his inquiry regarding the fees charged for the loan, please be advised that the loan origination charge for a HECM loan is prescribed by HUD. 
The purpose of this fee is to compensate the lender for processing the loan application and underwriting the borrower's qualifications for the loan. As per the HECM guidelines, the lender can charge 2% of the first two hundred thousand dollars ($200,000) of the home's value plus 1% of the amount over two hundred thousand dollars ($200,000). HECM origination fees are capped at six thousand dollars ($6000). In this case, Mr. *******' home was appraised at two hundred ten thousand dollars ($210,000). Therefore, Mr. ******* was charged on origination charge of four thousand one hundred  dollars ($4,100). The remaining ninety five dollars ($95), as reflected on the HUD-1, is the document preparation fee which is a required fee that is paid to a third party vendor.
 
The mortgage insurance premium ("MIP") provides FHA insurance on the loan as required under the federal HECM program. As such, the MIP is paid directly to HUD and cannot be waived by Liberty. Under the HUD requirements, the borrower is charged an initial MIP of 0.50% of the Maximum Claim Amount when the sum of the borrower's initial disbursement at closing and other required or available disbursements during the first twelve (12)  month disbursement period is 60% or less of the Principal limit. The Maximum claim Amount is the lesser of the appraised value of the home, the sale price or the FHA lending limit of six hundred twenty five thousand ($625,000). Since the appraised value of two hundred ten thousand dollars ($210,000) is the lesser amount, the MIP is based on this figure, The HECM program also charges an annual MIP of 1.25%  of the loan balance. Although the 1.25% rate is an annual rate, it is calculated and added to the loan balance on a monthly basis. The title charges of one thousand seven hundred thirty six dollars and thirty cents ($1,736,.30) are also third party fees which Mr. ******* can address the title company, Unisource National Lender Services,LLC, as Liberty did not determine nor retain those fees.
 
Mr. ******* obtained a HECM Monthly LIBOR reverse mortgage which funded on January 21, 2014. This type of loan is based on the LIBOR index(London Interbank Offered Rate), and therefore, the interest rate can vary on a monthly basis over the life of the loan. While the FHA does not require an interest rate cap on monthly adjusted HECM loans, Liberty's guidelines do require that the interest rate cannot increase by more than 10% above the initial rate. The Good Faith Estimate ("GFE") indicates that Mr. ******* wold be charged an initial interest rate of 2.368%. The Total Annual Loan cost Rate Disclosure ("TALC") also references the initial rate of 2.368%. The HECM Disclosure form explains the monthly adjusting variable rate feature of the HECM loan in detai** Mr. ******* signed both the TALC and HECM Disclosure on November 23, 2013. 
 
Upon loan closing, the interest rate dropped from 2.368% to 2.360%. The 2.360% rate can be seen on the Final HUD-1. In addition, the executed Note shows both the interest rate of 2.360% and rate will never increase above 12.360% (initial rate of 2.360% + 10%= 12.360%). Furthermore, Mr. ******* signed the Payment Plan (Exhibit 1) on January 15, 2014, as well as other loan documentation which disclosed sufficient information regarding the interest rate. Based on the documentation found in the file, it appears clear that he was provided with sufficient information regarding the interest rate for his loan.
 
Mr.*******' Reverse Mortgage Advisor, **** *****, explained to him that all closing costs must be paid at loan closing. His total closing costs came to seven thousand six hundred twenty six dollars and twenty two cents ($7,626.22) and were financed as part of the loan. His closing costs bread down as follows:
 
Origination Fee-$4,100.00
Document preparation Fee-$95.00
Appraisal Fee-$325.00
Credit Report-$19.92
Flood Gentrification-$8.00
Mortgage Insurance Premium-$1,050.00
Title Charges-$1,736.30
Government Recording Charges-$929.00
 
At closing, Mr. ******* elected to take a two thousand dollar ($2,000) draw, he elected to receive his loan proceeds as monthly term payments of two thousand dollars ($2,000). Therefore, each month he accrues interest and ongoing MIP on the loan balance, as would be the case with any loan.
 
HECM guidelines allow the borrower the option to pay off their loan at any time without penalty. As mentioned above, Mr. *******' loan is currently being serviced by Celink. Should he choose to pay off his loan balance in full, he will need to contact Celink directly. Again, he can reach Celink's Borrower Care Department at ###-###-####.
 
We apologize that Mr. ******* are not completely satisfied with his reverse mortgage transaction. Liberty strives to ensure excellent service and customer satisfaction. We believe that we have adequately addressed all of Mr. *******' concerns. Should he have any new concerns, please do not hesitate to notify us and we will be more than happy to address any new concerns he may have
 

Consumer Response: I am rejecting this response because: they lie. i was not informed of all the fees involved. **** ***** did not comply to my request for all fees involved. if i would have know all the fees i would not have did a reverse mortgage. they act like i am renting their house and expect me to do unneccessary repairs just so they can charge me more. this is a rip off. i will see them i court. they take advantage of at risk adults. and withold information saying dont worry about it, it will be rolled into your loan and there is no out of pocket cash from you. they want to steal my house. even the hud counselor never told me about all the fees and how they could charge me for anything. they are thieves.

Business Response: This letter is in response to the follow up correspondence you received on May 5, 2014 regarding ****** *******' reverse mortgage loan with Liberty Home Equity Solutions, Inc. ("Liberty"). We review all customer inquiries promptly and we sincerely appreciate you bringing to our attention the concerns related to Mr. *******' loan transaction.

 
We understand Mr. *******' new concern to be in regards to receiving 70% of his home value.
 
The amount of proceeds a borrower can receive through a HECM reverse mortgage loan is based on the borrower's age, current interest rates and the lesser of the appraised value of the home, sale price or the maximum lending limit. Our review of the file reflects that the lesser amount in Mr. *******' loan transaction was the appraised value of his home which was determined to be two hundred ten thousand dollars ($210,000). This calculation results in what is known as the principal limit, which is the maximum amount the borrower can receive from the HECM loan. As determined by HECM guidelines, Mr. *******' principal limit was calculated to be on hundred eleven thousand five hundred ten dollars ($111,510).
 
According to HECM requirements, borrowers may access the greater of 60% of the principal limit amount or all mandatory obligations, plus an additional 10% during the first twelve (12) months after loan closing. The combined total of mandatory obligations plus 10% cannot exceed the principal limit amount established at loan closing. Mr. *******' total mandatory obligations  were ten thousand six hundred seventy six dollars and twenty two cents ($10,676.22). His total mandatory obligations break down as follows:
 
*Initial Mortgage Insurance Premium- $1,050.00
*Other Closing Costs-$6,576.22
*Repairs-$3,050.00
 
Therefore, in Mr. *******' case, the greater amount was 60% of the principal limit. After the fires twelve (12)  months from the date of the loan closing, the borrower may access any remaining funds up to the principal limit. Mr. ******* chose to receive equal monthly payments of two thousand dollars ($2,000) for the life of the loan.
 
Mr. ******* did not send Liberty eight thousand one hundred dollars ($8,100) as he indicated in his correspondence. The only funds that Mr. ******* has paid are the closing costs of seven thousand six hundred twenty six dollars and twenty two cents ($7,626.22) which were financed as part of the loan.
 
As per Mr. *******' request, a copy of the appraisal report has been included for his reference.
 
As mentioned in our previous correspondence, Mr. ******* can pay off his reverse mortgage loan balance in ful** HECM guidelines allow the borrower the option to pay off their loan at any time without penalty. Mr. *******' loan is currently being serviced by Celink. Should he choose to pay off his loan, he will need to contact Celink directly. He can reach Celink Borrower Care Department at ###-###-####.
 
We apologize that Mr. ******* is not completely satisfied with his reverse mortgage transaction. Liberty strives to ensure excellent service and customer satisfaction. We believe that we have adequately addressed all of Mr. *******' concerns. Should he have any new concerns, please do not hesitate to notify us and we will e more that happy to address any new concerns he may have.

7/9/2013 Advertising/Sales Issues | Read Complaint Details
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Additional Notes

Complaint: GENWORTH DID THINGS WHICH WERE NOT IN MY BEST INTEREST. I WANTED TO ADD MY WIFE TO MY EXISTING REVERSE MORTGAGE. WE CONTACTED AMERICAN TRUST FUNDING MORTGAGE BANKER,LLC AND THEY SAID THAT THEY DID BUSINESS WITH GENWORTH FINANCIAL. WE PROCEEDED WITH FHA CASE NUMBER XXX-XXXXXXX AND THEN GENWORTH ALWAYS WANTED TO MAKE SOME CHANGES AND THAT CAUSED US TO HAVE TO PAY HECM COUNSELERS 2 TIMES BECAUSE GENWORTH WANTED THE APPRAISER TO MAKE CHANGES TO HIS APPRAISAL AND THEN THEY WOULD NOT ACCEPT HIS CHANGES. AFTER ABOUT 10 MONTHS WE WANTED TO TRANSFER THE CASE NUMBER TO ANOTHER COMPANY BECAUSE GENWORTH HAD REDUCED THE APPRAISED VALUE SO LOW THAT I WOULD HAVE TO PAY ABOUT $30.000 DOLLARS TO ADD MY WIFE AND THE OTHER COMPANY SAID THAT THEY MIGHT BE ABLE TO DO BETTER. GENWORTH ENTERED DATA ON SOME TRANSFER PAPERS THAT BLOCKED THE TRANSFER TO THE OTHER COMPANY UNTIL THE FHA CASE NUMBER COULD BE CLOSED OR RETIRED IN ABOUT 6 MONTHS AND WE COULD GET A NEW CASE NUMBER, WITHOUT GENWORTH BEING INVOLVED. THIS PROCESS WITH GENWORTH TOOK ABOUT 10 MONTHS. GENWORTH SENT A FORM THAT WAS CALLED FHA CONNECTION FOR APPRAISAL LOGGING AND THE FORM HAD CONFLICTING APPRAISAL DATES WHICH INDICATED A APPRAISED VALUE BEFORE THE CERTIFIED APPRAISER HAD COMPLETED AND SUBMITTED HIS FINAL APPRAISAL WHEN GENWORTH PUT IN A DATE OF 2-10-2013 AND THE CERTIFIED APPRAISAL IS DATED 2-27-2013 WHICH IS A 17 DAY DIFFERENCE. ARE THE GENWORTH PEOPLE THAT CHANGED OR CAN CHANGE THE APPRAISAL FROM A CERTIFIED AND LICENSED APPRAISER,CERTIFIED AND LICENSED TO DO APPRAISAL THEMSELVES? IF GENWORTH DID NOT WANT TO DO THE REVERSE MORTGAGE,WHY DID THEY NOT JUST DECLINE? GENWORTH CHANGED THEIR NAME TO LIBERTY HOME AFTER WE STARTED THE PROCESS

Desired Settlement: FIX THE PAPER WORK SO THAT WE CAN TRANSFER THE CASE NUMBER OR GET A NEW NUMBER INDEPENDANT OF GENWORTH /LIBERTY HOME.

Business Response: Business' Initial Response
This letter is in response to the information submitted to you on June 4, 2013 by **** **** regarding his reverse mortgage loan application with Liberty Home Equity Solutions, Inc. ("Liberty"), formerly known as Genworth Financial Home Equity Access, Inc. We review all customer inquiries promptly and we sincerely appreciate you bringing to our attention the concerns related to **** and **** ****'s loan transaction. Mr. **** expressed concern related to the appraised value of his home, adding Mrs. **** to the loan and transferring his case assignment to another lender. Our review of the file reflects that Mr. and Mrs. **** first applied for a reverse mortgage loan with Liberty on July 19, 2012. A Federal Housing Administration ("FHA") case number is assigned to all FHA insured loans, and since a HECM loan is an FHA insured loan, it requires a case number assignment. Initially, the appraisal effective date was July 11, 2012 and the FHA case assignment was pulled on July 13, 2012. However, FHA requires that the case number assignment be assigned prior to ordering the appraisal inspection. Therefore, we required an updated appraisal before we could proceed with his loan transaction. The updated appraisal expired on November 11, 2012 while in the process of pending additional information from Mr. ****'s broker, ******* ******** with America Trust Funding Mortgage Bankers LLC, needed to satisfy the loan conditions before proceeding to closing. Underwriting reviewed the appraisal to determine if an extension could be granted. However, an extension could not be granted because the appraiser, ***** ***** with **** *********** and ********** *********** **** stated that the property was in a declining market, making the property ineligible for an extension. Since we could not proceed with the loan transaction without a current appraisal, Mr. ****'s loan was cancelled on November 28, 2012. Mr. and Mrs. **** then applied for a reverse mortgage loan again on April 13, 2013 which required a new HECM counseling certificate. We received a new appraisal dated May 1, 2013. Once we receive the appraisal it is reviewed by our internal independent Appraisal Review team. We are obligated to review the appraisal report for accuracy, and as the lender, we are held accountable by HUD to ensure the value is supported based on the documentation in the appraisal report. Upon reviewing the appraised value of their home and the comparable sales, it was determined that the value was not supported. The comparable sales used by the appraiser appear to be in superior condition, including remodeling, superior finished basements and room count. Therefore, it was concluded by our Appraisal Review that the value of the subject property is $380,000. Due to the reduced appraised value of the home, Mr. **** requested his loan transaction be cancelled and that we transfer his case assignment. Per Mr. ****'s request, his loan was cancelled on June 3, 2013 and his case assignment was transferred to ******** ******* ***** Mr. **** also expressed concern in regards to adding Mrs. **** to the loan. Mrs. **** was born in March 1950, and therefore meets the age requirement for a HECM reverse mortgage loan. As long as both Mr. and Mrs. **** are on the title, both Mr. and Mrs. **** would be included on the loan as co-borrowers. We apologize that Mr. and Mrs. **** are not completely satisfied with their reverse mortgage transaction. Liberty strives to ensure excellent service and customer satisfaction. We hope that we have adequately addressed the concerns Mr. **** raised. Should he have any new concerns, please do not hesitate to notify us and we will be more than happy to address any new concerns he may have.

Consumer's Final Response
(The consumer indicated he/she DID NOT accept the response from the business.) THEY DID NOT ADDRESS ALL OF MY QUESTIONS.ETC:THE QUALIFICATIONS OF THEIR REVEIW PERSONS. THE DEMOGRAPHICS IN WASHINGTON DC HAVE INCREASED THE VALUE OF EVERYTHING.THEY BUILD CONDO'S AND APARTMENT BUILDINGS ON WHAT WAS A LOT FOR A SINGLE HOME. BBB CAN CONSIDER THE MATTER CLOSED.

Business' Final Response
This letter is in response to the information submitted to you on June 20, 2013 by **** **** regarding his reverse mortgage loan application with Liberty Home Equity Solutions, Inc. ("Liberty"), formerly known as Genworth Financial Home Equity Access, Inc. We review all customer inquiries promptly and we sincerely appreciate you bringing to our attention the concerns related to **** and **** ****'s loan transaction. Mr. **** expressed concern relating to the appraised value of his home. Our review of the file reflects that Mr. and Mrs. **** first applied for a reverse mortgage loan with Liberty on July 19, 2012. The appraisal expired on November 11, 2012 while in the process of pending additional information from Mr. ****'s broker, ******* ******** with America Trust Funding Mortgage Bankers LLC, needed to satisfy the loan conditions before proceeding to closing. Underwriting reviewed the appraisal to determine if an extension could be granted. However, an extension could not be granted because the appraiser, ***** ***** with **** *********** and ********** Appraisers, Inc. stated that the property was in a declining market, making the property ineligible for an extension. Since we could not proceed with the loan transaction without a current appraisal, Mr. ****'s loan was cancelled on November 28, 2012. Mr. and Mrs. **** then applied for a reverse mortgage loan again on April 13, 2013. We received a new appraisal dated May 1, 2013. Once we receive the appraisal it is reviewed by our internal independent Appraisal Review team. We are obligated to review the appraisal report for accuracy, and as the lender, we are held accountable by HUD to ensure the value is supported based on the documentation in the appraisal report. If the appraised value is not supported then HUD will not insure the loan which puts both the borrower and the lender at risk. Upon reviewing the appraised value of their home and the comparable sales, it was determined that the value was not supported. The comparable sales used by the appraiser were all closed sales and were superior to the subject property in quality and condition. Additionally, all comparable sales used were renovated for the purpose of flipping the properties. The first comparable sales was completely remodeled including the kitchen, appliances, bathrooms, flooring, fixtures, paint, and molding. The second comparable sale had a much larger degree of updates including the kitchen, appliances, flooring, paint, fixtures, paint, molding, bathrooms and flooring. In addition, all three comparable sales have superior finished basements, more square footage and a higher room count. The appraiser later revised his report by adding an additional comparable sale. However, this comparison too was superior in condition to the subject property. Multiple Listing Service ("MLS") is a nationwide listing service that provides the details on the sales and listings that occur across America. MLS data indicates that a large degree of properties in the subject property area have had extensive updating and are in the process of being (or have been) renovated. Depending on room count and square footage, these range in prices from the mid $300,000's up to the mid $600,000's. Similar "row" style homes in this market with limited updating, similar to that of the subject property, appear to have sale prices closer to the mid $300,000's. This is consistent with the data contained in the Residential Appraisal Report. Therefore, it was concluded by our Appraisal Review team that the value of the subject property is $380,000. Please note that we did not change the value of the appraisal. The appraisal report still indicates the original value as when it was submitted. The Appraisal Review team simply reduced the appraised value based on their detailed analysis. In addition, it's important to note that any prior appraisals from another loan submission were not considered as part of this analysis as each appraisal report stands independently. Due to the reduced appraised value of the home, Mr. **** requested his loan transaction be cancelled and that we transfer his case assignment. Per Mr. ****'s request, his loan was cancelled on June 3, 2013 and his case assignment was transferred to Maverick Funding Corp. We apologize that Mr. and Mrs. **** are not completely satisfied with their reverse mortgage transaction. Liberty strives to ensure excellent service and customer satisfaction. We hope that we have adequately addressed the concerns Mr. **** raised. Should he have any new concerns, please do not hesitate to notify us and we will be more than happy to address any new concerns he may have.

3/20/2013 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: Started reverse mortgage w/Liberty, decided to transfer to another company. Difficulty getting appraisal transferred even though procedures followed. Case#XXX-XXXXXXX. We started a reverse mortgage with Liberty Home Equity Soluctions, Inc. but decided to change companies. Signed all papers required to do this. Only thing left was for Liberty to release the appraisal. 2/13/13, instructions received for release: cashier's check payable to Liberty in amount of $400 with invoice was to be sent to attention of ***** ******, Liberty Home Equity, Suite 200, Rancho Cordova, CA XXXXX-XXXX. Per instructions, if cashier's check sent to Ms. ******'s attention, appraisal would be released the same day as received. If not sent to her attention check would likely be forwarded to finance dept which could cause a 3-7 business day turn-time. If personal check sent, there is an automatic 5 day hold. 2/14/13, a cashier's check in the amount of $400 along with invoice was sent as instructed to Ms. ******'s attention via UPS overnight delivery. 2/15/13, verification from UPS shows delivered at 9:09 AM, signed by FINE. A letter dated 2/20/13, was sent from Liberty with invoice requesting the $400 payment for the release. This was received 2/23/13 by us. Monday, 2/25/13, an e-mail was sent to Ms. ****** to find out what was going on. That is when it was found that she was out of the office 2/18/13 thru 2/25/13. Tuesday, 2/26/13, Ms. ****** was called and she stated she didn't know where the check was. Yet, she was not out of the office until the 18th per her e-mail. 3/1/13, Liberty states they cannot locate the check, could we please furnish the check number. 3/2/13, via e-mail a copy of the cashier's check, mailing label, and written verification from UPS as to when delivery was received. Realize 3/2/13 was a Saturday but by end of the day today, Monday, 3/4/13, we have heard nothing from Liberty. Since there are only so many days the appraisal is good, we are working on a time schedule. It is necessary this matter be corrected as soon as possible. Per telephone call with our bank today, Monday, 3/4/13, cashier's check #XXXXXX went thru our bank Friday 3/1/13.

Desired Settlement: First would like our appraisal released to the other company immediately. And second,since we followed all instructions to the letter and it is now the 12th work day since they received our cashier's check, we feel they owe us the $61 it took to overnight the check and invoice to Ms. ******** attention.

Business Response: Business' Initial Response
RE: ****** Home Equity Conversion Mortgage ("HECM") loan application with Liberty Home Equity Solutions, Inc. NMLS# **** (formerly Genworth Financial Home Equity Access, Inc.) To Whom It May Concern, This letter is to acknowledge our receipt of the written correspondence Martin and ****** ****** submitted to Liberty Home Equity Solutions, Inc. ("Liberty") dated March 5, 2013 via the Better Business Bureau. We are looking into the issues the borrowers asked us to address and you should expect our reply dated within the next 30 days. We appreciate your taking the time to provide us with the borrower's feedback and we take their concerns seriously. If you have any additional information relevant to the borrower's concerns or have any questions, please feel free to contact me. Sincerely, ******** **** Compliance Analyst

Business' Final Response
: Home Equity Conversion Mortgage ("HECM") loan application with Liberty Home Equity Solutions, Inc. NMLS# **** To Whom It May Concern, This letter is in response to the information submitted to you on March 5, 2013 by Martin and ****** ****** regarding their reverse mortgage loan application with Liberty Home Equity Solutions, Inc. ("Liberty"), formerly known as Genworth Financial Home Equity Access, Inc. We review all customer inquiries promptly and we sincerely appreciate you bringing to our attention the concerns related to the ****** loan transaction. The ******'s expressed concern relating to the check they submitted for the appraisal and the difficulty in getting the appraisal released and transferred to American Advisors Group ("AAG"). Our review of the file reflects that the ****** originally submitted a loan application on August 8, 2012. This loan was initially declined on September 17, 2012 due to the unique nature of the home and the fact that the appraiser ******* *** *** with ***** Appraisal, was unable to obtain any comparable values in the area with a similar structure, resulting in a lack of marketability. Subsequently, the ****** realtor obtained additional comparables which were provided directly to the appraiser. Upon review of the updated appraisal our independent Appraisal Review Team did not feel that the appraised value was supported by the additional comparables and therefore reduced the value. We then received a case transfer request from ******** Mortgage and transferred the case on November I , 2012. On December 19, 20 I 2 the ****** submitted a second loan application reflecting Mr. ****** as the primary borrower. Therefore, we requested the case number be transferred back from ******** Mortgage to Liberty. However, by the time the transfer was complete, the appraisal and counseling certificate from the original file had expired. We received the borrowers new counseling certificate on January 4, 20 I 3 and a new appraisal on January 22, 2013. The ****** file was clear to close on February 1 20 I 3. Then on February 1 I 20 I 3 we received a case transfer letter from AAG and the case was transferred on February 13, 2013. In order to have the appraisal transferred to AAG the borrower's indicated that they sent a check for the appraisal to ****** ******'s attention, along with a copy of the invoice via UPS overnight delivery on February 15, 2013. Due to a series of events which included a weekend, followed by a holiday and Ms. ****** being out on vacation, Operations did not receive the check until February 20, 2013. Since Ms. ****** was out of the office, another employee processed the check without knowing the background on your particular loan transaction. As mentioned, we received the cashier's check on February 20, 20 I 3 in the amount of $400; however no copy of the invoice was included. The check only referenced Mrs. ******'s name but did not have any other identifiable information on it such as a loan number or FHA case number. As a result, the check was logged and routed incorrectly. On March 5, 20 I 3 we received a copy of the ******'s check from AAG and released the appraisal to them the same day. We sincerely apologize for any inconvenience this may have caused. As a gesture of good will, we are reimbursing the ******'s for the $400 cost of the appraisal, as well as the overnight UPS fee of $61 for any inconvenience they may have incurred. The check for a total of $461 is enclosed in the copy of the letter sent to the ******. Liberty strives to ensure excellent service and customer satisfaction. We hope that we have adequately addressed the concerns raised by the ******. Should they have any new concerns please do not hesitate to notify us and we will be more than happy to address any new concerns they may have.

11/12/2012 Problems with Product/Service | Read Complaint Details
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Additional Notes

Complaint: Failure to obtain reverse mortgage and reasons why. Poor customer service. After answering a internet add for Reverse Mortgage, we were contacted by Mr. Craig Prentice and agreed to meet with him. On July 26, 2012 my wife and I met with a Genworth Financial Advisor,Craig Prentice,in our home.Our first concerns were: can we get a reverse mortgage for our manufactured home? Yes,was the answer. If it is on a our own lot and sitting on a permanent foundation, it is. We then filled out and signed paper work to obtain a reverse mortgage. It was understood that we had no funds to pay for the appraisal fee, that it would be payed through the reverse mortgage proceeds. About three weeks later,no word from the Advisor, Meanwhile,during those three weeks our manufactured home is appraised. I called Mr. Prentice and asked him, how our reverse mortgage paper work is doing, assuming title companies and such were working on it, he tells me he was on vacation and does not know, he will get back to me. A week goes by and he calls back. He tells me our home is too old by 4 years. What? Our home was built in 1992. According to him, Genworth will not do loans on manufactured homes later than 1996. I say,Mr Prentice should have known that his company does not do loans on manufactured homes older than sixteen years old! It's a deal breaker!We would not have gone through all the paper work. The fee for the appraisal was to come out of the loan proceeds, my wife and I have no monies to pay for the appraisal. Mr. Prentice says he will try something else. Weeks go by of trying to get a hold of Mr Prentice by phone and email. He finally sent us a email on Oct. 5,2012. that he cannot do anything because of the appraisal fee. I then sent him an email offering to find someone to loan us the amount for the appraisal fee ,or he should pay it and we would pay him back with the loan proceeds after it goes through. No answer from him to date. WE ARE VERY CONCERNED NOW! I have sent an email to Genworth Financial on Wednesday,October 17,2012 asking their version of what has happened to our reverse mortgage application and telling them about the poor customer service we have received by Mr Prentice. No response yet. Today, is October 20,2012. I asked for a timely response. I am afraid of identity theft here. Have they processed the paper work to HUD or FHA to get my reverse mortgage loan proceeds for themselves ?

Desired Settlement: I want a full explanation of what has happened to our reverse mortgage application and a written apology .We feel that they should not or will not bring legal proceedings against us to pay for the appraisal fee and the HUD counseling fee. Unless ALL original paper work is returned to us, including the formal appraisal paper work and such.

Business Response: Business' Initial Response
Company states (JLS): This letter is in response to your correspondence which was submitted to Genworth Financial Home Equity Access, Inc. ("Genworth") on October 23, 2012 via the Better Business Bureau ("BBB"). We understand your concerns to be that you received poor customer service and communication regarding the status of your loan, which also led to concerns about identity theft. In addition, we understand that you have concerns about paying for the appraisal and counseling fees. We apologize that you did not have a good customer service experience with Genworth. We strive to provide excellent service and customer satisfaction, and we appreciate your feedback. We are required to follow a certain process in order to accurately evaluate eligibility on all reverse mortgage loan submissions. While this process can take some time, we apologize that you were not adequately informed during the processing of your loan application. In regards to your concern about identity theft, we can assure you that we protect all borrower information and hold customer's personal information in the strictest confidence. As per Genworth's Privacy Policy, we never disclose borrower's or customer's personal information without prior authorization from the borrower or customer. In addition, all borrower and customer information is protected by the Federal Privacy Act. Additionally, you expressed concern about being charged for the appraisal and counseling fees. Genworth did not collect or charge you any upfront appraisal or counseling fees. Genworth incurred the cost for the appraisal and will not be requesting any payment or reimbursement from you. In regards to the counseling fees, as the lender we are not authorized to pay for this service on your behalf. Please address any additional concerns regarding this fee with the counseling agency that performed the service, Smart Money Housing. Again, we apologize that you are not completely satisfied with your reverse mortgage transaction. We believe we have sufficiently addressed all of your concerns at this time. Should you have any new concerns that we have not already responded to in this letter, please do not hesitate to notify us. We will be more than happy to address any new concerns you may have. Very truly yours, ******** **** Compliance Analyst