CFPB Updates Servicing Exam
Written by: Bill Dolan, CMB, AMP
The CFPB examiners are focusing on evaluating mortgage servicers’ policies and procedures, assessing whether servicers are complying with applicable laws, and identifying risks to consumers related to mortgage servicing.
Attention is being given to covering forbearances and other tools that servicers had used during the COVID-19 national emergency. Tools include streamlined loss mitigation options that satisfy the temporary flexibilities within the CFPB’s mortgage servicing rules established by COVID-19 related amendments.
CFPB expects servicers to continue to utilize all the tools at their disposal – including, streamlined deferrals and modifications that meet the conditions of CFPB’s COVID-19 related mortgage servicing rules in their efforts to keep consumers in their homes.
The CFPB is also focusing their attention and questioning areas such as fees being assessed by servicers who charge borrowers in areas such as phone pay fees, and misrepresentations related to foreclosure. Specific attention is also being given on how servicers are communicating with borrowers abut homeowner assistance programs. If you are not aware, funds from the Homeowners Assistance Fund (HAF) can help homeowners avoid foreclosure, but only if servicers are working directly with state housing finance agencies as well as HUD -approved housing counselors to assist borrowers in completing the HAF application process.
SCA’s Servicing Consultants are here to address these and other types of challenges facing servicers each, and every day. Ask yourself the following:
Will my current policies and procedures meet and/or exceed CFPB, FDIC, OCC, FRB as well as the GSEs’ regulations and guidelines for their next exam or audit?
Are you currently in balance when it comes to Investor Accounting Remittance and Reconciliations with your Investors or are we padding and just remitting what is being called for?
Does your P&I and T&I Custodial Accounts tie in with your General Ledger Accounts? How long has it been since that happened?
If you answered NO to any of the above, isn’t it time you contacted SCA to turn for help and get your accounts turned around? Don’t wait for the regulators, examiners or the GSE’s to drop the hammer!
Contact Bill Dolan, Director at (617) 694-2627 or email Bill at: Wdolan@scapartnering.com. While you are at it, visit: www.scapartnering.com to learn more about SCA’s consulting services surrounding Compliance, Technology, Servicing, Outsourcing, Strategic Planning, Quality Control, Asset Sales & Purchases, Due Diligence, Training & Staffing.
