(Violation of TILA and Regulation Z)   26.  On or about September 23, 2005, Plaintiff took out a mortgage, secured by her  residential property, located at 4382 Dongounery Cove, in Memphis, Tennessee (“the  Property”), for the principal amount of $156,370.00 (“the Mortgage”).  The footer of the  Mortgage’s Deed of Trust states it is an “FHA TENNESSEE DEED OF TRUST—MERS,”  which indicates that it conforms to the servicing requirements established by the United States  Department of Housing and Urban Development (“HUD”).    27.  Section Four of the Mortgage’s Deed of Trust, entitled “Fire, Flood and Other  Hazard Insurance,” requires the Borrower to maintain property insurance, and provides that the  insurance policies “shall be held by Lender and shall include loss payable clauses in favor of,  and in a form acceptable to, Lender.”    46.  Plaintiff brings this suit as a class action on behalf of herself and on behalf of  others similarly situated pursuant to Federal Rules of Civil Procedure, rules 23(a), 23(b)(2),  and/or 23(b)(3) (the “Class”).  The proposed Class consists of:  all borrowers that have or had mortgages serviced by Defendant, on property located  within the United States, (i) who may receive or are entitled to receive payoff  statements; or (ii) who have received mortgage payoff statements from Defendant,  which failed to disclose the amount of insurance proceeds held by Defendant.    47.  The members of the Class are so numerous that joinder is impracticable.   Defendant is one of the largest mortgage servicers in the country.  According to a news release  dated April 14, 2015, Defendant reported a residential mortgage servicing portfolio of $1.7  trillion, and $1.5 billion in mortgage banking noninterest income in its last quarter.  There are  over eighteen Wells Fargo branches in Tennessee alone.    48.  Plaintiff’s claims are typical of the claims of the entire Class because Defendant  failed to account for insurance proceeds in its payoff statement to Plaintiff.  Defendant has a  common course of conduct of failing to account for such funds in payoff statements regarding  other Class members.   55.  Plaintiff repeats the allegations in the above paragraphs as if fully set forth  herein.   Defendant’s Rights Under the Mortgage to Administer Insurance Proceeds  