Perron v. J.P. Morgan Chase Bank, N.A.

Dist. Ct. did not err in granting defendant-bank’s motion for summary judgment in plaintiffs-homeowners’ RESPA action, alleging that defendant failed to supply them with sufficient information regarding their mortgage escrow account, when dispute arose regarding defendant’s payment of home insurance premium from said escrow account to wrong insurance company. Erroneous payment of insurance premium was caused by plaintiffs’ failure to inform defendant that they had changed insurance company, and information supplied by defendant, that included detailed accounting of loan’s payment history, as well as breakdown of principal, interest and escrow payments, sufficiently complied with RESPA. Fact that defendant did not identify insurance company that had received erroneous escrow payment or provide reasons for holding plaintiffs’ mortgage payment “in suspense” did not require different result where defendant had previously supplied such information to plaintiffs. Ct. further rejected plaintiffs’ claim that they could recover emotional damages associated with dissolution of their marriage as result of instant alleged RESPA violation.