CFCU Community Credit Union

To whom it may concern,My complaint (#***) with the Cornell Federal Credit union has been resolved amicably.Let me know if you require additional information.Thanks,*** ***

Please let this letter serve as CFCU Community Credit Union's ("CFCU") response to your Revdex.com letter dated June 15, 2017 (see attached "Exhibit A") and to the complaint ("Complaint") filed by CFCU member ("Member") on June 14, 2017 (see attached,"Exhibit B"). Pursuant to the...

received Complaint, CFCU has conducted an internal investigation for the issues raised by Member and the transactions in question. The result of CFCU' s investigation is a finding that Member did not incur any excessive or incorrect charges or assessments, that CFCU acted appropriately and by the terms of the agreements with Member,and that based on these findings there is no justification for a refund nor any alteration of credit reporting to date.

July 8, 2015Revdex.com100 Bryant Woods SouthAmherst, NY 14225Attn: [redacted], Complaint HandlerRE: Complaint ID [redacted]Dear [redacted]:This letter is made on behalf of Usa W[redacted], CEO ofCFCU Community Credit Union ("CFCU"), and is in response to a complaint submitted to your...

organization by [redacted] "Member"), as referenced by the complaint identification number above (the "Revdex.com complaint") and as attached ("EXHIBIT A"). Prior to receiving the Revdex.com complaint, CFCU received a written complaint from [redacted] containing the same allegations set forth in the complaint [redacted] submitted to your organization (the "internal complaint").As a point of clarification and by way of background, there are several types of insurance related to mortgage loans. One type of insurance is homeowner's or "hazard" insurance which protects the mortgagor and mortgagee against certain types of damage or loss to the mortgaged property. While borrowers do have the ability to shop around for hazard insurance, it is required for all mortgage loans made by CFCU, and in [redacted]'s case, this insurance amounted to approximately $100 per month at the time the loan in question was made to [redacted]. Another type of insurance is credit life/credit disability insurance ("CLD insurance"), which is optional and voluntary for the borrower. CFCU offers this type of insurance as an option to borrowers at the time the loan is made, and borrowers also can obtain CLD insurance from other providers. In the case of credit life insurance, this coverage pays off the loan in the event of the death of an insured borrower. In the case of credit disability insurance, the coverage pays monthly payments during the period of a verified disability of the borrower that prevents the borrower from regular employment. Premium payments for this type of insurance are calculated based upon a percentage of the outstanding loan balance. In [redacted]'s case, the combined CLD insurance premium was approximately $95 per month at the time the loan was made and approximately $65 per month'at the time the insurance was canceled by [redacted]. CFCU's understanding of [redacted]'s reference to the insurance at issue is CLD insurance. Immediately upon receiving [redacted]'s internal complaint, CFCU conducted an internal investigation to determine whether the allegations [redacted] made were supported with facts. The investigation included the following steps: Telephone CommunicationsCFCU's Vice President of Member Experience reached out to Member on June 15,2015 to get a better understanding of the situation. During the conversation Member agreed to send copies of the paperwork she had from the time of application (May 17,2011) up to the loan signing (June 16,2011), so that these documents could be reviewed while at the same time the original loan file was being retrieved. The member stated that she felt she and the co-borrower were "coerced" into opting for two voluntary insurance products at the time of closing and stated that they were told by a CFCU representative that if they did not take it they would not get the loan. When asked why she signed the documents if she was feeling this way, she replied that they had home repairs in process and needed the money, so they "had no choice." The VP of Member Experience asked if she spoke to the manager in the branch or tried to contact someone at the main office at the time of the loan signing and the reply was "she should have been able to trust her Loan Officer." The VP of Member Experience tried to explain that CFCU has a process in place to help with Member concerns or complaints, including but not limited to escalating concerns to a manager or contacting CFCU's Supervisory Committee, and asked [redacted] whether she had spoken to anyone else regarding her concern over the CLD insurance at the time of obtaining the loan. [redacted] responded that she felt that she shouldn't have had to do so as she should have been able to trust the statements of her Loan Officer, and she had asked her Loan Officer on three different occasions about the CLD insurance and was told the same thing, so she "let it go." At this point in the conversation, theVP of Member Experience told her that he would look at the information she was sending in addition to Member's original loan file and would get back to her the following day. The VP of Member Experience called [redacted] on June 16,2015 to let Member know that the sent information had been received and was being reviewed, and that he would reach back out to her on June 17, 2015. On the 17th, the vp. of Member Experience contacted [redacted] again to say that senior management at CFCU was reviewing all information and updating the Supervisory Committee (as Member also sent notification to CFCU's SUEervisory Committee with her concerns). [redacted] stated that she would give CFCU until Friday, June 19 at noon to refund the paid premiums or she would take the matter to the Revdex.com, the NYS Attorney General, and the Consumer Financial Protection Bureau. On Friday, June 19, prior to noon, the VP of Member Experience once again called [redacted] and informed her that based upon its investigation of this matter (additional facts discovered in the investigation are set forth below), CFCU would not be issuing a refund of the premiums paid for the CLD coverage'. [redacted] responded, "So you are telling me that you are standing by your employee and telling me I am a liar?" The VP of Member Experience stated that based upon the documentation and information gathered, [redacted] had signed documents that clearly indicated that the CLD insurance products were voluntary and could be cancelled at any time by either borrower. At this point in the conversation, [redacted] began to talk over the VP of Member Experience, indicating that she would be reaching out to the three above mentioned agencies and possibly hiring an attorney. The VP of Member Experience thanked her for her time and [redacted] then terminated the call.Interview with Loan Officer who made the loan to [redacted]The Assistant Vice President of Compliance ("A VP Compliance"), who conducted the internal investigation, interviewed the Loan Officer who made the loan to [redacted] while working at the [redacted] [redacted] ("Cortland Branch"). The Loan Officer stated that she did not recall working with this specific member nor any instance of Member returning to complain about the insurance as stated by Member. The Loan Officer provided the procedures that are followed during this type of loan process and stated that she was trained and follows the steps outlined by CUNA Mutual ("CUNA") who is the CLD insurer that also provides training on this product to CFCU staff. She stated that this process involves asking the applicant what is an affordable payment, then using this along with the loan amount requested to both determine and provide the applicant with the loan terms and monthly loan payment with and without CLD. She stated that she has never advised anyone that CLD is mandatory and that a loan would not be approved without it. She defined this as not only inaccurate information but also an unethical business practice. At the time of this loan in 2011, the Loan Officer stated that the incentive program paid by CFCU to Loan Officers was $1 paid to the Loan Officer for life insurance being added to a loan, $1 for the disability, and an additional $1 ifboth were placed on the loan. She stated that at the time the loan was made to [redacted], the Loan Officer was processing approximately 30 loans per month.Interview with CFCU employee who had contact with [redacted] related to this loan and [redacted]'s allegationThe A VP Compliance also spoke with a Member Relationship Representative ("MRR") at the Cortland Branch where the loan in question was initiated. The MRR stated that on June 12,2015 she received a call from [redacted] inquiring if the CLD insurance on her home equity loan could be removed. Since the MRR was not completely familiar with this product, she conferred with the Cortland Branch Manager and was advised that the insurance could be canceled at any time. The MRR informed [redacted] of this, and on June 15,2015, [redacted] and the co-borrower came to the Cortland Branch to cancel the insurance with the MRR. [redacted] provided the MRR with copies of the paperwork they had received when the loan was closed, which included a copy of a credit insurance form indicating that the insurance was voluntary ("Exhibit C" - Please note that the handwritten marks on this form were added during subsequent investigation and review, and the form is being provided here as proof of signature at closing and acceptance of form.) [redacted] stated she was told the CLD was not optional. The co-borrower agreed with [redacted]'s version of events, although he was much calmer and more reserved than [redacted]. [redacted] did return to the Cortland Branch on either June 16th or 17th to obtain a printout of the loan history for the loan at issue, which was provided by a teller at the branch.Interviews with managers at CFCU who supervise the consumer lending function and the sale of CLD insurance• Loan Process and Training Review: A VP Compliance interviewed the Chief Lending Officer ("CLO") and the VP of Consumer Lending who provided details on the procedures involved with home equity loans and the available insurances. These individuals stated that CFCU staff follow CUNA's guidelines provided during training, and that additional training on the CUNA guidelines involving home equity loans is provided by the CFCU training staff. The loan and insurance process stated by the VP of Consumer Lending and CLO matches the process that the Loan Officer described when interviewed. The training course and materials make it Clear to alltrainees that the CLD products are voluntary and not required, and that Loan Officers should make it clear to all applicants that they have the option to purchase this insurance. The CLO also verified that the Loan Officer who made the [redacted] loan participated in multiple training sessions for the CLD insurance products. • Loan Officer Insurance Sales Review: The CLO provided a report showing the home equity loans originated and closed by the Loan Officer who made the loan to [redacted], as well as the loans for 3 other CFCU Loan Officers from 2010 to current; the report also assesses whether or not there is CLD insurance on the loans. Based upon a review ofthis report, since 2010,59.% of the HE loans closed by the Loan Officer who made the loan to [redacted] included this insurance. Compared to her peers, the Loan Officer in question falls near the average and could not be considered a top seller of the CLD insurance products. Full review of the [redacted] loan file• The credit insurance document ("Exhibit B") signed by [redacted] at the time the loan in question was made clearly states that the insurance is voluntary and not required in order to obtain the loan. This is stated in bold on the 1st page of this document, which is signed Member ... Additionally, this page clearly states the total premium amount. The 2nd and 3rd pages clearly describe how the insurance may be cancelled & the coverage/benefits of the insurance. Again, this document was signed by Member at the time the loan was made, and a copy of the document was provided to the borrowers (evidenced by the fact that [redacted] provided a copy of this same document to MRR at the Cortland Branch on June 15th). • Also, included in the loan file are 2 printouts detailing the loan payment amounts, 1 with insurance coverage and 1 without insurance coverage ("Exhibit C"). Both printouts include the monthly loan payment amount, the total loan amount, the total finance charges, and the total premium amount, if any. These printouts were calculated at the time of application, as the first payment date reflects a June payment as do all disclosures from the time of Member's application, and all documents at closing reflect the actual first repayment date in July;· This indicates Member was provided documentation reflecting both options throughout the loanapplication process.• The loan application completed and signed by [redacted] and the co-borrower ("Exhibit D") shows that the borrowers indicated $500.00 as their affordable payment amount. The actual loan payment amount including the CLD insurance is $472.59 per month. Therefore, the loan terms offered to and agreed to by [redacted] and the co-borrower were within the affordable amount as set by Member.• The Commitment Letter ("Exhibit E") issued by CFCU to [redacted] and the co-borrower and signed by CFCU does not mention nor does it state that credit life and/or disability insurance is required. After reviewing all of the documentation and the results of the internal interviews that were conducted by CFCU's A VP Compliance, CFCU could find no evidence of any misconduct or coercion on the part of CFCU or the Loan Officer who issued the loan to [redacted]. All evidence points to the fact that [redacted] and the co-borrower knew or should have known that the CLD insurance was voluntary and could be canceled at any time by either borrower. Therefore, CFCU determined that no refund of the CLD insurance premium would be granted to these borrowers.We also find it important to note that CFCU has NEVER received a complaint of this nature from any of its members regarding coercion or mandating CLD insurance, despite the fact that CFCU has made over 11,000 loans since 2010 which included credit life insurance, credit disability insurance, or both. Please let us know if you require any additional information regarding this matter.Sincerely,Eliza S. M[redacted]Associate General CounselCFCU Community Credit UnionEncs.cc: [redacted]CFCU Supervisory CommitteeNew York State Department of Financial ServicesNew York State Attorney General's Office