Servicing Becomes Regulators & GSEs Top Priorities
As mentioned in prior SCA blogs and newsletters, when originations tend to slow down, both Regulators and the GSEs focus their attention and oversight on mortgage servicing.
In the CFPB’s latest Response Metrics Report, though servicers may be so different and not alike whatsoever when it comes to their size, portfolio composition, delinquency rates, or other criteria, the CFPB is resolute in prioritizing their oversight of mortgage servicers to both identify and minimize risk for borrowers. Specific attention is being paid to proper management of forbearance exits and the loss mitigation process, ensuring that all servicers were responsive to homeowners relative to the pandemic and the ongoing recovery.
The same holds true for both Fannie Mae and Freddie Mac who are taking a far closer look and review through audits pertaining to Investor Accounting, reconciliations, remittances, and monthly reporting.
Because you are passing through the exact amount of fund requested by the GSEs monthly, does NOT mean you are in balance and that your custodial accounts are being reconciled properly, based on the remittance type.
Ask yourself if you are performing cash deposits to your P&I Custodial Accounts correctly?
Principal curtailments
Payments-in-full
Proceeds from 3rd party foreclosure sales
Repurchase proceeds
What about your T&I Custodial Accounts?
Partial payments
Property or flood insurance loss drafts
Payment overages or shortages
Rental income
Don’t wait for either an exam or an audit to find out that you have experienced out-of- balance conditions within your custodial accounts for months, or that it was uncovered that your servicing department did not provide the adequate help or assistance required in handling loan mods or proper forbearance during COVID-19.
Please reach out and contact Spillane Consulting Associates, Inc. to speak with one of our Senior Mortgage Servicing Consultants and subject matter experts, who can provide the tools and the necessary training needed to face these and other intricacies required to manage risk and empower your servicing team to conquer and resolve these complexities to excel in gaining both agility and accuracy in performing your day-to-day servicing functions.
For a free consultation, reach out and contact Bill Dolan, Director at (617) 694-2617 or email at wdolan@scapartnering.com. Visit our website at www.scapartnering.com or LinkedIn page to learn more about our other mortgage consulting services that we at SCA can offer you.
