I have XXXX complaints as a result of a refinance of our mortgage. Refinance was done with the same company servicing the original mortgage. First complaint is regarding a Forced Place Policy for Hazard Insurance put in place even though we never had a lapse in coverage. Second complaint is regarding the length of time it is taking to get a refund of our escrow money. 

1st complaint. On XXXX XXXX, XXXX I changed insurance companies. On XXXX XXXX, XXXX I cancelled the original policy. Ditech shows the cancellation notice, which was sent at the same time as the new declaration page for the new policy. In XXXX Ditech ( which was GreenTree at the time ) established a Force-Placed Policy and withdrew XXXX from the escrow account to pay for the policy. An amount that is excessive in nature ( My current annual premium is XXXX ), and should be addressed based on RESPA Section 6 ( l ) ( 3 ) Regulation X. My specific complaint is that they did not refund to us the amount in a timely fashion as identified in RESPA section 6 ( l ), which states payment should be made within 15 days. 

2nd Complaint. Once application was approved, processor did not agree with originator that funds from old escrow could be moved to new account ( which in my opinion would have helped the intention of HARP, by reducing debt and/or out of pocket expense for refinancing ). Ditech on several occasions has informed me that it can take up to 60 days from the day a loan is funded to receive a refund from the old, closed escrow account. This seems to differ from the RESPA Refund of Escrow Section 34 ( b ), which states " within 20 days ''. 

This information was found on CFPB website, at this link XXXXWhich Relates to the Dodd-Frank Wall Street Reform and Consumer Protection Act, which was signed into law, Number 111-203 in XX/XX/XXXX. 
Insurance issue was found on page XXXX and the Escrow refund on page XXXX. 

Thank you for your help. 
