Rocket Mortgage has sharpened its breach-of-contract lawsuit against United Wholesale Mortgage, adding new allegations that UWM provided brokers with lists of Mr. Cooper-serviced loans to target for refinancing and new data showing thousands of those loans ultimately returned to UWM.
Rocket filed its amended complaint Aug. 27 in the New York Supreme Court’s Commercial Division, roughly three months after first suing UWM over mortgage servicing rights Mr. Cooper purchased from the wholesale lender in 2024.
The core case has not changed. Rocket, as successor to Mr. Cooper, continues to bring a single breach-of-contract claim alleging UWM violated non-solicitation provisions covering nearly 182,000 mortgages with approximately $65 billion in unpaid principal balance.
Mr. Cooper paid UWM $773 million for the servicing rights to those loans under three agreements executed between January and June 2024. Those contracts barred UWM and parties working on its behalf from directly or indirectly soliciting the borrowers to refinance, while allowing general advertising and refinances initiated independently by borrowers.
Rocket alleges UWM later undermined the value of those servicing rights through refinance initiatives including Refi75, its AI-powered KEEP system and Refi Shield 100.
The amended complaint sharpens Rocket’s existing claim with more specific allegations about how UWM and its broker network allegedly targeted the loans and how much business UWM ultimately recaptured.
Rocket Names Broker In New Allegations
Among the most significant additions is Rocket's identification of Tim Barry, CEO of mortgage brokerage LitFinancial.
Rocket alleges that, after filing its original complaint, it received information from UWM-affiliated mortgage brokers, including Barry, that UWM sent brokers lists of loans to target for refinancing during the same period it rolled out Refi75 and Refi Shield 100.
According to the amended complaint, those lists included loans covered by UWM's non-solicitation agreements with Mr. Cooper.
Rocket further alleges that LitFinancial was contacted by UWM and supplied with lists of Mr. Cooper loans to solicit, along with pricing incentives intended to encourage borrowers to refinance.
"On information and belief, LitFinancial is just one example of a broader pattern," Rocket alleges, claiming other brokers received similar information and materials from UWM.
The original May complaint alleged UWM sent brokers "leads" identifying specific loans subject to the agreements, but did not identify LitFinancial or Barry or provide the same level of detail about how those lists were allegedly distributed.
More Than 15,500 Loans Refinanced
Rocket also adds new figures intended to connect UWM's alleged solicitations to the losses in Mr. Cooper's servicing portfolio.
By December 2025, more than 15,500 of the approximately 182,000 loans — more than 8% — had been refinanced, according to the amended complaint.
Rocket says more than 48% of those loans were refinanced with UWM, making it the largest refinancer of the affected loans with more than twice as many as the next-largest company.
Rocket argues that concentration supports its contention that UWM's solicitation efforts contributed to the unusually high runoff in the servicing portfolio.
The company previously alleged that prepayment rates among the loans were roughly 2.5 times those of comparable loan pools. The amended complaint goes further, saying Mr. Cooper performed a more granular comparison accounting for factors including loan vintage and coupon rate.
Rocket alleges there is "no factor other than UWM's solicitation" that explains the difference in prepayment rates between the disputed pools and comparable loans serviced by Mr. Cooper.
Damages Claim Climbs To At Least $100 Million
Rocket also provides a more detailed timeline of its alleged losses.
According to the amended complaint, Mr. Cooper first calculated damages around February 2025 to assess the impact of Refi75 and KEEP.
In June 2025, it sent UWM a letter alleging those solicitations had already caused "tens of millions of dollars in harm." Mr. Cooper later updated its analysis with data through December 2025.
"In just 10 months, the damages had skyrocketed to nearly $100 million," Rocket alleges.
The amended complaint now seeks compensatory damages estimated at "at least $100 million," compared with the original complaint's request for "approximately $100 million." Rocket is also seeking interest, attorneys' fees and other relief available under the servicing-rights agreements.
Rocket argues the increase coincided with the launch of Refi Shield 100 and UWM CEO Mat Ishbia's push for brokers to refinance loans previously sold to Mr. Cooper.
UWM launched Refi Shield 100 after Rocket announced in March 2025 that it would acquire Mr. Cooper. During a broker video, Ishbia encouraged brokers to pursue loans UWM had previously sold to Mr. Cooper and offered an additional 100-basis-point pricing incentive.
Rocket alleges that effort directly violated UWM's contractual promise not to solicit those borrowers.
Rocket Adds UWM Financial Pressure To Its Motive Theory
The amended complaint also expands Rocket's argument that financial and competitive pressures gave UWM an incentive to recapture previously originated loans.
Rocket alleges UWM faced margin compression, declining refinance demand and pressure to generate additional origination volume. It newly points to UWM's Aug. 6, 2026 earnings call, alleging the company announced losses exceeding $450 million and required a capital infusion from a major distressed-debt investor.
Rocket characterizes its refinance programs as part of a broader strategy in which UWM could profit first from originating a loan, again from selling its servicing rights and then a third time by refinancing that borrower back through UWM.
Those assertions remain allegations and have not been proven in court.
Despite the added detail, Rocket's legal theory remains straightforward: UWM allegedly sold Mr. Cooper the servicing rights and exclusive rights to directly solicit those borrowers for future refinances, then used its own technology, pricing incentives and broker network to win some of those loans back.
The amended complaint asks the court to hold UWM responsible for the resulting loss in servicing value and award Rocket at least $100 million in damages.
UWM has not responded to NMP’s request for comment as of publication.
