Mortgage servicers, who continue to face scrutiny from oversight agencies, may have even more on their plate in the new year. The Bureau of Consumer Financial Protection (BCFP) examiners continue to identify errors in servicer handling of trial modification conversions. The issue was significant enough to gain mention in the BCFP’s most recent Supervisory Highlights report and will almost certainly remain an area of focus during future supervisory examinations. Being subjected to penalties, fines, or even enforcement action can be extremely costly for servicers. Conversely, errors in loss mitigation workflow can be easily avoided with the right workout rules management and automated workflow approach.
The Federal Deposit Insurance Corporation (FDIC) is the latest regulator to express concern over the rise of nonbank servicing. For nonbank mortgage servicers, the growing attention from regulators and other industry stakeholders, that include Ginnie Mae, whose concerns we spotlighted recently, could mean policy changes are on the horizon, as well as heightened scrutiny of rules and operational processes that align with mandated metrics.
Servicers should expect to face tougher scrutiny from Ginnie Mae in the coming months and year ahead. As the interest rate and lending environment has evolved, the government-backed mortgage-backed security (MBS) guarantor has expressed increasing concern with liquidity management. Agency representatives have hinted at new standards, tougher evaluations, policy changes, and credit ratings in the works. With enhanced oversight seemingly imminent, servicers should ensure they have existing requirements under control and be prepared for a ramp up in associated agency rules, operational disruption, and the need for workflow automation.
The Federal Reserve has given mortgage servicers a long and gradual runway to adapt to the realities of a higher interest rate environment. As consumers experience an increasing cost to carry debt, are faced with the inability to refinance into a lower interest rate mortgage, or find themselves faced with an increasing adjustable rate mortgage payment, we can expect to see a rise in delinquency, default and loss mitigation activity.
Interest rate increases, natural disasters, and seasonal changes can cause dramatic swings in delinquencies, oftentimes making it difficult for servicers to accurately forecast an uptick in foreclosure volume ahead of time. An annual September spike in mortgage delinquencies is one of the more predictable industry trends; however, this September’s figures, which were published a few weeks ago, may have caught some servicers by surprise, and could indicate a hefty ramp up in loss mitigation efforts is on the horizon.
Is hurricane season over? Not if you’re a loan servicer. Given the skyrocketing amount of devastation caused by hurricanes, wildfires, flooding and other natural disasters, loan servicers are faced with developing a complete process for relief that begins when disaster strikes. Historically, disaster relief was an infrequent and isolated issue, allowing servicers to manage assistance on a manual, ad hoc or one-off basis. In today’s environment, the volume of natural disasters, the geographic breadth, and extent of recent changes to investor requirements, make this approach a risky venture.
What does it mean to be disaster ready? As a servicer you’re already juggling a variety of change initiatives at any given time, with unreasonably thin margins and minimal resources. Beyond basic system enhancements to your loan servicing system…
The end of this year’s hurricane season is less than two months away; however, with hurricane Florence barely in our rearview, are your operational processes in check to meet disaster relief requirements? If not, they should be.
Last year’s federal aid for natural disasters was nearly tenfold that of the previous year. Hurricanes Harvey, Irma and Maria alone are said to have affected approximately eight percent of the population in the U.S. The Federal Emergency Management Agency (FEMA), who provides assistance in the event of all natural disasters, reported that more than 25 million people were impacted by hurricanes, flooding, or wildfire in 2017, and close to five million households applied for FEMA’s Individual Assistance program requesting direct support.
One can only begin to imagine how many homeowners have contacted their mortgage servicer for information and participation in relief programs. Although the servicers' phones start to ring as soon as there’s a Presidential Disaster Declaration, the real test of readiness occurs when borrowers are unable to make payments and need to understand their options for financial assistance.
While nearly all government-backed mortgage guarantors provide a wide range of disaster relief programs, perhaps none are quite as unique and diverse in their offering as the Small Business Administration (SBA). Most mortgage lenders and servicers have been working hard to stay abreast of updated disaster relief requirements for Fannie Mae, Freddie Mac, the Federal Housing Administration (FHA), the Department of Veterans Affairs (VA) and the US Department of Agriculture (USDA), but not as many are aware of the extensive options available to SBA customers, not to mention that the SBA administers their programs directly.
Two years ago, the Bureau of Consumer Financial Protection (BCFP) finalized an expansion of successors in interest (SII) protections as part of a larger package of new mortgage servicing rules. While the majority of the final rule required implementation last year, the successors in interest provisions only took effect a few months ago. The BCFP completely re-envisioned the coverage of SII and it is imperative mortgage servicers understand their extended compliance responsibilities in order to avoid having costly errors uncovered in regulatory supervision.
Just last week, Freddie Mac issued a press release advising mortgage servicers to prepare to assist borrowers whose homes or places of employment were impacted by Hurricane Florence. Likewise, they directed homeowners to pursue disaster relief once out of harm’s way. Freddie Mac said, “We strongly encourage homeowners … to call their mortgage servicer … to learn about available relief options,” adding, “we stand ready to ensure that mortgage relief is made available.”
As Hurricane Florence tests the preparedness of state and local governments up and down the East Coast, Fannie Mae servicers must similarly ask themselves if they are prepared for revamped disaster relief requirements this hurricane season and beyond. Fannie Mae’s disaster assistance requirements span more than a dozen chapters of the Seller/Servicer Guide.
From loan origination to loan payoff, there are multiple paths that a loan can take throughout its lifecycle. The best performing loans will follow a clear, straight path with no hiccups along the way. All payments are made on time. This path is the easy street for loans, and the servicers servicing them.
When a disaster strikes, the United States Department of Agriculture (USDA) is ready to respond to the needs of American farmers with a vast toolbox of disaster assistance programs, from emergency loans to crop insurance. In the mix of a wide range of programs, it can be difficult for servicers of Rural Development (RD) mortgages to see where they fit into the ‘farm safety net.’
When it comes to disaster response, the Departments of Veterans Affairs (VA) is one of the more responsive federal agencies. Servicers of VA loans should be prepared to closely monitor the needs of distressed homeowners in disaster-stricken areas and provide timely and flexible relief.
Three of the top five costliest hurricanes on record occurred last year, according to the National Oceanic and Atmospheric Administration (NOAA), resulting in an estimated $306.2 billion worth of property damage. That shatters the previous record of $214.8 billion worth of damages in 20051. In a world of billion-dollar weather events, mortgage servicers face the challenge of managing hundreds of thousands of hazard insurance claims, repairs, foreclosure moratoriums and relief programs. The Federal Housing Administration (FHA) is particularly vigilant in managing its portfolio and exposure to loss, and expects servicers to stay on top of fluctuating timelines, priorities and policies that apply to recovery areas.
You’ve heard the saying, “the more things change, the more they stay the same”. The mortgage industry has definitely seen its fair share of changes in the last decade, brought in part by the financial crisis of 2008. While the landscape may have changed, the pain points that servicers experience remain essentially the same today.
Lenders prefer that foreclosure be the last resort when it comes to recovering the remaining balance of a home loan. Many offer forbearance plans as an alternative to foreclosure to help keep borrowers in their homes. These forbearance plans provide servicers a temporary solution to keep borrowers out of foreclosure when they are experiencing a short-term financial hardship.
Last month, the United States Department of Agriculture (USDA) Rural Housing rolled out extensive amendments to its Technical Handbook for the Single Family Housing Guaranteed Loan Program (HB-1-3555). These updates were particularly concentrated in Chapter 18, Servicing Non-Performing Loans - Accounts with Repayment Problems, which serves as the primary guidance for USDA default servicing.
Today’s technology news is filled with references to artificial intelligence (AI)—the latest in Robotics Process Automation (RPA)—but what does this mean for your organization? How difficult is it to access the opportunity and how quickly can your organization realize benefits? What do you need to know?
The regulatory landscape for mortgage bankers continues to touch every phase of the mortgage lifecycle. Whether it’s the prospect of ongoing regulatory implementation or the assimilation of change from deregulation, servicers need to be prepared to continue managing through transformation as discussed in our recent blog on deregulation.
New technology is fun and exciting! Making the transition from manual to automated processes can be an energizing endeavor for any organization. The opportunities available are endless, which can also make the move a bit intimidating. It doesn’t have to be! It’s all in the planning.
Adopting process automation technology is more than just plug and play. It eliminates costly, time consuming tasks so careful thought and planning needs to go into your approach and implementation to achieve the best results. Rome wasn’t built in a day and neither will your automation be. Here are 4 phases of planning to help ease your transition from manual to automated processes.
We love automated workflow! Although, we may be a little biased. It’s been our business for over a decade. We are firm believers that technology is meant to work for you. If it isn’t, then what good is it really? If you are still looking for a few good reasons why you should embrace automation, here are 10 we hope will win you over.
The servicing industry has significantly transformed itself since the onset of the financial crisis. Beginning with the tsunami of delinquencies, servicers scrambled to combat the lack of loss mitigation options, fought against the inability to rapidly scale processes and creatively band-aided antiquated technology. Those that have survived the past decade have done so with a pioneering spirit, perseverance and sophisticated workflow.
Natural disasters have an impact that extends beyond the rising waters, the scorched structures, and the scattered debris. When lives are changed and jobs lost, the impact can be felt for weeks, months, and even years after. As the impacts continue to set in from the wildfires in California and hurricanes Harvey, Maria, and Irma, delinquencies are expected to rise as homeowners repair and rebuild. Are you ready to help them on their road to recovery?