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August 22, 2022

Should Servicers Be Worried About the CFPB's Key Observations?

The industry is migrating from forbearance to foreclosure, and mortgage servicers are seeing another change in the makeup of their default servicing portfolios. Forbearance volume is plateauing as the number of loans entering forbearance more closely parallels the volume of forbearance exits. At the same time servicers are becoming anxious as foreclosure activities, from filings to auctions, increase month over month. This type of continued volatility in delinquency activity, whether it’s a change to overall volume, delinquency reasons, relief options, or regulatory requirements, creates severe risk for servicers.

Man moving the risk needle from high to low


If your organization is ill-prepared for more change, then increased risk exposure without the appropriate automated checks and balances can be costly and ruinous. And the Consumer Financial Protection Bureau(CFPB) is watching. In their efforts to protect consumers, the CFPB is rigorous when evaluating your default servicing operations and subsequent handling of distressed borrowers. This heightens the need for automated exception and audit processes that encompass intelligent business process workflow to help you identify and address issues before they become problematic.

Our June blog looked closely at the CFPB’s five key observations as published in their May report. These areas of concern were derived from data and metrics collected from multiple servicers over an eight-month period of time and will almost certainly be evaluated during your next examination.


CFPB Observations – Continuing Risks Facing Borrowers

  1. Call center hold time variability.
  2. Delinquency at time of forbearance exit.
  3. Servicer data challenges.
  4. Borrower demographic inaccuracies.
  5. Insufficient Limited English Proficiency support.

The CFPB views these risks to be yet another indication that mortgage servicers are underperforming and lack industry uniformity. Are you prepared? Did you consider our “Take Action” suggestions in each of these five areas? How do you plan to guard against regulatory scrutiny and consumer protections? Many of these areas can be impactful across your organization, not just in default servicing. It’s time to take action and protect your borrowers, your controls, as well as the governance of your business processes with CLARIFIRE®.


Let CLARIFIRE® Do the Heavy Lifting.

The brilliance of automation and innovation is that you gain the capacity to instantly respond to change and rapidly mitigate CFPB published concerns and regulatory requirements. There are endless automation opportunities that your organization will benefit from as you address risk exposure and modernize business process automation. CLARIFIRE® can help by keeping the customer at the heart of the servicing processes. Just to highlight a few ways that we’re here to assist:

  • Provide real-time 24/7 automated responses to your borrowers including workout application statuses, approvals, and options. Easy interactions with documents, guided displays on what documents are required, and workflow driving the processes to optimal results.
  • Proactively service your borrower needs with flexible and transparent real-time access to critical loan histories, communications, event timelines, and notifications, available in one dynamic view.
  • Automate and streamline all of your loss mitigation workout plans, including automated options aligned with all current programs, detailed application status, eligibility determination, and easy fulfillment.
  • Prevent risk with immediate exception notifications designed to catch discrepancies, instantly notify responsible parties, and intelligently compare data to assist in preventing future inconsistencies. All the while delivering robust, auditable workflows that track to CFPB metrics.

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Don’t wait for the CFPB to target your organization! Add workflow automation to the arsenal, so you’re positioned to mitigate risk, manage critical metrics, and ensure your servicing organization is both responsive and auditable. Don’t wait to eliminate concerns that applications, options, or requirements have been overlooked or mishandled. Let automated workflow, intelligent decisioning, and sheer innovation do the heavy lifting with the CLARIFIRE® suite of processes and features. No matter the scenario, CLARIFIRE® provides rapid, transparent, no-touch responsiveness while delivering seamless servicing and creating positive customer experiences and results.

Contact CLARIFIRE® today at 866.222.3370 or visit us at Let us show you how to future-proof your organization with truly BRIGHTER AUTOMATION®.


Jane Mason | @janemasonceo

Jane has applied her vast experience (over 25 years) operating process-driven businesses to successfully redefine client-focused service. Jane has worked with expert programmers to apply cutting-edge web-based technology to automate complex processes in industries such as Financial Services, Healthcare and enterprise workflow. Her vision confirms Clarifire's trajectory as a successful, scaling, Software-as-a-Service (SaaS) provider. A University of South Florida graduate, Jane has received many awards related to her entrepreneurial skills.


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