What brokers can take away from servicer complaints
Just because the Consumer Financial Protection Bureau (CFPB) has diminished in size over the last year doesn’t mean that mortgage complaints haven’t still been rolling in.
In total, 24,616 mortgage complaints were filed with the CFPB in 2025. There was an annual increase in the number of complaints regarding “trouble during payment” and “struggling to pay mortgage.”
In 2025, 12,652 complaints were filed regarding trouble during the payment, up from 11,748 in 2024. Complaints about people struggling to pay mortgage checked in at 5,962 in 2025, up from 5,144 in 2024.
Both of these complaint types put mortgage servicers in the crosshairs, but there are important takeaways mortgage brokers can use on the front end of the process. One executive said servicing switching hands, combined with increased delinquencies, has likely led to an increase in complaints.
Mirza Hodzic (pictured top), managing director and founder of BlackWolf, has worked with the CFPB and the Office of the Comptroller of the Currency (OCC) on compliance and audit issues over his more than 20 years in the industry. He said the number of actual complaints is likely much higher.
“These complaints that were sent to the CFPB don't include your regular complaint that comes in,” Hodzic told Mortgage Professional America. “So I'll tell you, as someone who's managed the process on the compliance side, and as someone who does a lot of work with complaints right now, it was expected.”
Delinquencies and mergers causing issues
Affordability is one of the biggest issues in the mortgage industry right now. While that can refer to a potential homebuyer out shopping for a new home, it also applies to existing homebuyers trying to deal with inflated costs in their daily budget.
These challenges are leading to an increase in mortgage delinquencies. While they are still very low across the board, the surge in FHA loan delinquencies is concerning because these loans typically include very small down payments, meaning there might not be equity for these customers to refinance for savings.
This can lead to situations where the borrower struggles to make a payment, which could lead to some of these CFPB complaints.
“When I look at kind of the two areas that were most prominent on the CFPB side, we’re looking at the trouble during payment type of complaints, but also the struggle to pay the mortgage,” Hodzic said. “You can see some correlation with some other reporting that we've seen over the past couple of months, with FHA delinquencies having gone up. This translates into the customer struggling to pay.”
The other area where things have changed on the servicing side is the series of recent mergers and acquisitions, which could be confusing for the homeowner who suddenly has to change how they’re submitting payments to their new servicer.
“The mortgage complaints that come in for trouble during payment could be related to delinquencies,” Hodzic said. “But it also relates to significant transfers where there could be a breakage regarding payments, like ACH doesn't transfer over, the borrower is confused about where to send a new payment to, and they're not getting the answers they're supposed to.
“In a way, it’s kind of understandable seeing those complaints rise, but servicers obviously can do a lot to reduce that.”
Hodzic said it is on these companies that acquire servicers to have systems in place to be able to bring these new loans in-house without a major disruption to the end customer.
“If you acquire a place, and they have 250,000 loans, you need to prepare for that,” he said. “You need to have staff. Customers come from all walks of life. They may not understand the change. Someone else owns the loan. It's almost like a standard transfer. Who do I call now? My payment changes regarding who I send it to. You have to consider that when you're doing these acquisitions and mergers.”
An evolving compliance landscape
One of the final related challenges is the shift in enforcement and oversight from the CFPB to individual states.
“We've definitely seen a bit of a shift over the years,” Hodzic said. “I think we have states stepping in a bit more now with their oversight and with how they manage this piece. States used to focus heavily on mortgage lending, and now we're seeing more involvement with the servicing side.”
Even with some of the enforcement moving to the state level, there is already talk of the CFPB starting to emerge once again in the wake of President Donald Trump’s housing executive order, which will require rule-writing by the CFPB. Hodzic cautions servicers to be prepared for things to change again.
“While the CFPB is reduced at the moment, and slower to do things, I still caution everyone when I speak to people, that you cannot relax,” he said. “Because things may change two years down the road.”
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