Smith v. PennyMac Loan Services, LLC

CourtDistrict Court, S.D. Ohio
DecidedFebruary 11, 2025
Docket3:24-cv-00116
StatusUnknown

This text of Smith v. PennyMac Loan Services, LLC (Smith v. PennyMac Loan Services, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. PennyMac Loan Services, LLC, (S.D. Ohio 2025).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

JASON SMITH, Plaintiff, Case No. 3:24-cv-116

Vv. Judge Walter H. Rice : Mag. Judge Peter B. Silvain, Jr. PENNYMAC LOAN SERVS., LLC, Defendant.

ND ORDER OVERRULING MOTION TO STRIKE OF PLAINTIFF JASON SMITH (DOC. #14) AND OVERRULING AS TO CLAIM ONE AND SUSTAINING AS TO CLAIMS TWO AND THREE MOTION FOR JUDGMENT ON THE PLEADINGS OF DEFENDANT PENNYMAC LOAN SERVICES, LLC. (DOC. #12); CLAIMS TWO AND THREE FROM PLAINTIFF’S COMPLAINT (DOC. #1) ARE DISMISSED WITHOUT PREJUDICE TO REFILING WITHIN TWENTY-EIGHT (28) DAYS OF ENTRY ee This case is before the Court on Defendant PennyMac Loan Services, LLC’s

(“PennyMac” or “PLS”) Motion for Judgment on the Pleadings. (“Rule 12(c) Motion,” Doc. #12). Plaintiff Jason Smith has also moved to strike the declarations of Johnny Morton and Robert T. Lieber, Jr., PennyMac’s counsel, which were attached to the Rule 12(c) Motion. (“Motion to Strike,” Doc. #14, citing J. Morton Decls., Docs. #12-1, 12-2; R. Lieber Decl., Doc. #12-5). For the

reasons set forth below, Plaintiff’s Motion to Strike is OVERRULED and Defendant’s Rule 12(c) Motion is SUSTAINED IN PART and OVERRULED IN PART.

I. Factual Background and Procedural History A. Rule 12(c) Motion As PennyMac’s Motion arises under Rule 12, the Court treats as true all well-pleaded factual allegations in the Complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Plaintiff Jason Smith purchased residential real property on or about

March 13, 2020; ten days later, PennyMac assumed the servicing of his mortgage. (Compl., Doc. #1, PAGEID 3, 44 15, 17). In January 2022, PennyMac made two

payments out of Plaintiff’s escrow account to his insurer, Hippo Insurance Services (“Hippo”), but canceled one of the payments. (/d. at PAGEID 4, q{ 25-27). Hippo canceled Plaintiff’s policy for non-payment in April 2022. (/d. at { 30). Plaintiff's

house subsequently suffered water damage, for which he was unable to receive

payment from an insurer, and PennyMac put a “Forced Place Insurance” (“FPI”) policy on the property, which raised his rates. (/d. at PAGEID 5, ¥§ 31-32). Plaintiff made an initial qualified written request (“First QWR”) to PennyMac, seeking information “including but not limited to, failing to properly account the

escrow balance and adding other improper fees and charges to the Mortgage Loan.” (Doc. #1, PAGEID 5, § 35). He claims that PennyMac failed to address the

matters raised in the First QWR; specifically, PennyMac failed to explain why it

canceled the first escrow payment and failing to producing documents related to

the COVID forbearance plan into which Plaintiff had entered in early 2022. (/d. at

PAGEID 6, 38-39, 43-44). Plaintiff made a Second QWR, to which PennyMac responded by turning over numerous documents that had not previously been

disclosed, despite being requested in the First QWR. Those documents included: a

letter in which PennyMac purportedly conceded that its cancellation of the escrow

payment resulted in Hippo canceling Plaintiff’s policy, and accounting records, which revealed significant errors with respect to Plaintiff's escrow account. (/d. at

PAGEID 7, 4 49, 53). In Claim One, Plaintiff alleges that PennyMac’s actions and inactions violated the Real Estate Settlement Procedures Act of 1974 (“RESPA”) and the Consumer Financial Protection Bureau’s (“CFPB”) Regulation X. (/d at PAGEID 8-9, 9¢ 58-71, citing 12 U.S.C. § 2605(e); 12 C.F.R. §§ 1024.35-36). In

Claim Two, Plaintiff alleges that PennyMac violated its RESPA obligations as to Plaintiff's escrow account and Regulation X's “Prompt Payment Rule.” (/d. at PAGEID 9-10, 4 72-80, citing 12 U.S.C. § 2605(f-g); 12 C.F.R. § 1024.34(a)). In Claim Three, Plaintiff alleges that PennyMac’s failure to make proper escrow

payments constituted common law breach of contract. (/d. at PAGEID 10-11, qq 81-91). In the Rule 12(c) Motion, PennyMac argues that Claim One fails “because, despite Plaintiff’s allegation that PLS failed to properly respond to the First OWR, the First OWR, on its face, is a generic letter that did not reference any issues,

concerns, qualms or problems related to the hazard insurance payment, and PLS

properly responded to the First QWR.” (Doc. #12, PAGEID 550 (emphasis in original)). Moreover, PennyMac asserts, Plaintiff’s allegations of wrongdoing are conclusory, and his allegations of “damages are not causally connected to purported RESPA violations.” (Doc. #12, PAGEID 550). PennyMac notes that a

loan servicer’s response is proper under RESPA so long as it “fairly meet[s] the

substance of the QWR.” (Doc. #12, PAGEID 558 (internal quotation marks omitted), quoting 12 C.F.R. § 1024.36(f)(iv); Marais v. Chase Home Fin., LLC, 24

F. Supp. 3d 712, 725 (S.D. Ohio 2014) (Smith, J.); citing 12 U.S.C. 8 2605(e)(2)(A-C)). It argues that Plaintiff, in the First QWR, only disputed “the

amount due, principal owed, deferred interest, the loan due date, and the escrow

account balance” (/d. (internal quotation marks omitted), quoting First QWR, Doc.

#1-1, PAGEID 36), and that PennyMac provided all of that information in response. (id. at PAGEID 559, quoting First QWR Response, Doc. #8-6, PAGEID 120). As

the “First QWR did not mention any issues with Plaintiff’s hazard insurance... , PLS was under no obligation to answer a question that was never posed.” (/d.). As to Claim One, PennyMac also asserts that it cannot be held liable under

12 C.F.R. § 1024.35(a, b) (“Regulation X”) for failing to address the “noted errors”

in Plaintiff's QWR. (Doc. #12, PAGEID 559, citing Doc. #1, PAGEID 9, {{ 64-65). While PennyMac acknowledges that a loan servicer must investigate an allegation of error upon receipt of the borrower's Notice of Error (“NOE” or “Notice”), it claims that it need not do so if the Notice is: (1) duplicative of a previous notice; (2) overbroad; or (3) untimely. (/d. at PAGEID 560, citing 12 C.F.R. § 1024.35{a), (e)(1)(i)(A-B), (g)(1)(i-iii)). Here, PennyMac argues, the First QWR referenced only “the amount due, principal owed, deferred interest, the loan due date, and the

escrow account balance”; as PennyMac provided information regarding those topics, it complied with the QWR, and judgment is appropriate even at this early

stage. (/d. at PAGEID 560-61, citing Blair v. PNC Bank N.A., No. 21-cv-766, 2022

WL 2986868, *6 (S.D. Ohio July 28, 2022) (Black, J.).; Aazami v. Wells Fargo Bank, N.A., No. 17-cv-01564, 2019 WL 281286, *14-15 (D. Or. Jan. 22, 2019)). PennyMac notes that the First QWR did not mention hazard insurance, or any other

topic with such reasonable specificity that PennyMac was required to provide information, and PennyMac also informed Plaintiff why it was not providing other documentation.

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Smith v. PennyMac Loan Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-pennymac-loan-services-llc-ohsd-2025.