Clarifire Conversations

It is hard to imagine that we are approaching the three-month mark for working under COVID-19. Keeping up with industry change as we continue to grapple with pandemic disaster has kept us all on our toes, from the Coronavirus Aid, Relief, and Economic Security (CARES) Act to CFPB guidance to regular investor updates. Now more than ever, vendor partnership is an essential component to success. It's important to partner with an experienced, nimble innovator that can understand your unique needs, in addition to managing the ongoing maze of regulatory guidance.

Self-quarantine resulting from the Coronavirus (COVID-19) pandemic has propelled the industry into an entirely different mode of doing business.  With barely two months passed since the Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted, mortgage servicers have been thrown into a tailspin.  Experiencing what many businesses have in the face of COVID-19, mortgage servicers now have their entire staff (for the most part) working from home, and all customers sitting at home as well trying to make contact for relief services.  The exception is that not all businesses have customers receiving a pass to not make payments, while also having to foot the bill for nonpayment.  Plus, the regulatory bodies have each issued and continue to update “temporary flexibilities” that require understanding, implementation, and tracking. The cherry on top is that mortgage servicers are now expected to ensure their customers all transition to a secondary relief plan, either six months in or a full year later, that at this juncture, is loosely defined at best.

A record number of homeowners have taken advantage of COVID-19 related forbearance, pushing the percentage of mortgages in forbearance up to 7.54 as of April month-end. The real concern today is that the disposition of these loans at the end of forbearance is extremely unclear. Under the Coronavirus Aid, Relief, & Economic Security (CARES) Act, impacted homeowners who have federally backed mortgages can access up to 180 days of forbearance relief with the possibility to extend for an additional 180 days. The current industry concern is that details surrounding what happens when forbearance ends are extremely unclear, which may leave many financially stricken borrowers who took advantage of a COVID-19 forbearance in a precarious situation.

As servicers grapple with the numerous temporary “flexibilities” and “accommodations” that have been recently issued, accurately adhering to credit reporting requirements under COVID-19 may create long term issues for servicers, credit reporting agencies, and consumers. The credit protection offered under the Coronavirus Aid, Relief, and Economic Security Act (CARES) is fairly nuanced from an implementation perspective and will require significant attention to requirements, implementation, and reporting.

With skyrocketing unemployment, which will invariably lead to more delinquencies, consumers will have access to credit reporting relief under the Coronavirus Aid, Relief, and Economic Security Act (CARES) enacted on March 27, 2020. By modifying the Fair Credit Reporting Act (FCRA) and Regulation V, under Section 4021 of the CARES Act, protections have been put in place for consumers that need temporary “accommodations” due to the personal impact of COVID-19 on their livelihood.

As the world continues to struggle and change, the way we think of natural disasters evolves and changes along with it.  When you hear the term natural disaster, images from the aftermath of hurricanes, tornadoes, floods, fires, and earthquakes come to mind.  Over the last couple of months, we were introduced to a new kind of natural disaster, COVID-19.

Clarifire recently released its white paper on the current approach to customer-centric servicing and the corresponding key drivers as we head into a new decade. With ongoing fluctuation in business requirements and constrained resources expected to continue, informed and consistent communication with servicing customers is at the core of any successful servicing model.  Albeit difficult to deliver on, as technology budgets and profitability margins remain constricted, mortgage servicers need to make a sizable effort to embrace their customer base.  Whether looking to leverage cross-product penetration, increase retention, or simply endure the latest disaster obstacles, customer-centric servicing should be the focus.

Today’s customers demand far more than an automated process from their mortgage bank or servicer.  As servicers strive to improve overall efficiency through technology, many servicers may find themselves further behind the competition then they anticipated.  With targets set on process automation, data accessibility, artificial intelligence, and cybersecurity, efforts to innovate often fail to address the entire scope of digital, real time borrower engagement.  One of the most important areas of engagement, mobile access, is evolving at an exponential rate, especially with the developing deployment of 5G.  So, if mobile access has fallen to the bottom of your technology strategy, you may need to rethink your approach.

In today’s digital environment, the number of vendors delivering large platform-based systems remains high.  However, this approach is fast becoming dated as it slows down the ability of the servicer to evolve interoperability, impairs the capacity to integrate various systems, including access to data, and is typically costly and cumbersome to implement.

Disaster risk exposure relative to homeowner’s insurance has become a mounting concern for mortgage servicers as the number of natural disaster events remains high.  Servicers need workable strategies to protect mortgage collateral as they face an increasing number of disaster events toppling the $1 billion mark.  In this escalating disaster environment, mortgage servicers find themselves chasing insurance coverage options to help minimize their risk exposure.

Bank of America recently released the 2019 Fall Homebuyer Insights Report, which finds that homeowners value not only the financial equity that comes with homeownership but also the social and emotional benefits. Conveying several aspects of well-being that have been expanded with homeownership, including hobbies, interests, and family dynamics, information gathered from new homebuyers acknowledged that owning a home is considered an important element of one’s lifestyle. Affirmation of positive homeownership sentiments indicates that borrowers have moved beyond the financial crisis attitude whereby abandoning one’s home was considered an acceptable response to default. 

Recently the Treasury Department and the Department of Housing and Urban Development (HUD) published their long-awaited plans for housing finance reform. While the plans are most recognized for their proposed changes to government-sponsored enterprises (GSEs), they also introduce suggestions for amending Federal Housing Administration (FHA) programs and guidelines, including specific guidance on default servicing. 

Nearly half of mortgage servicers indicated that they felt the western region of the US was most likely to see an increase in distressed inventory for the latter half of the year. This was one of the key findings from Auction.com’s 2019 Disposition Summit Client Survey Report. 

The 2019 hurricane season is already off to a troubling start with Hurricane Dorian having caused an estimated $1.5 billion to $3 billion in insurance losses across the Caribbean. Even tropical storm Barry is estimated to have caused as much as $600 million in damage in the Southeast, including Alabama, Florida, and Mississippi. Last month, the National Oceanic and Atmosphere Administration (NOAA) updated its predictions for the current hurricane season, increasing expectations for an “above-normal” season.

New Jersey recently joined a handful of states seeking to increase regulation and oversight of nonbank mortgage servicers. The Mortgage Servicers Licensing Act went into effect just over a month ago and created new requirements for nonbank servicers doing business in the state.

As digital transformation evolves, agencies continue to migrate to the cloud to modernize operations, keep up with technological advances, and gain efficiencies.  Choosing the wrong vendor solution results in hidden costs and time delays.  Selecting the vendor that provides the most short-term gain balanced with long-term efficiencies is no small task.

In addition to federal regulations enforced by government agencies, including the Consumer Financial Protection Bureau (CFPB) and Office of the Comptroller of the Currency (OCC), mortgage servicers are subject to state regulations within the states they conduct business. And in the case of New York, those regulations can be as demanding, if not more so, than federal requirements. Even servicers that don’t operate in New York must keep a close eye on proposed changes to state requirements that have the potential to impact or increase today’s burden of compliance.

Although foreclosure rates are frequently touted to be at historic lows, servicers must still prepare for quarterly upticks and unexpected market changes that can quickly drive up foreclosures episodically. Increases in delinquency and foreclosure rates are in various quarterly reports, in numerous geographic pockets, and more frequently in areas where natural disasters occur.  Despite improved economic factors, the industry still needs to consider interest rate volatility, stagnating housing starts, latent home appreciation, and rising consumer debt.  Let’s not leave out talk of a forthcoming recession.  Last but not least, our industry has changed since we last saw serious delinquency risk, making awareness and readiness more important than ever.

The past decade has been a challenging one for mortgage servicers, with countless time and resources spent on high volumes of delinquencies, rigorous loss mitigation standards, and growing investor requirements. Looking ahead to the next ten years, stakeholders are asking if the old servicing model still makes sense for a transformed industry.

In May, we shared with you a sneak peek of what to expect at this year’s Ginnie Mae Summit.  With promises of an “in-depth, top-to-bottom perspective on Ginnie Mae’s business,” it certainly did not disappoint.  If you missed this exciting industry event, we’ve got you covered.  From government lending policy changes to Ginnie 2020, here’s what you need to know.

It appears that the Federal Housing Administration (FHA) will finally get the technology modernization it deserves.  This year Congress approved $20 million in funding for FHA’s technology infrastructure, coinciding with several initiatives to retool systems that are decades old. This funding acknowledgment will support significantly enhanced technological capabilities that will benefit the industry as a whole, as well as individual lenders and servicers.

The Consumer Financial Protection Bureau recently published its 18^th Edition of Supervisory Highlights, reviewing supervisory actions taken in the latter half of 2018.  The Supervisory Highlights outline four sectors that received significant supervisory attention.  Mortgage servicing once again made the list, alongside automobile loan servicing, deposits, and remittances. The findings related to mortgage servicing violations reiterate the need for up-to-date policies and procedures, as well as mechanisms to ensure adherence.

It has been a difficult year for many rural American families, particularly those that farm. From unprecedented flooding, tornadoes, and tariffs, the “perfect storm” of challenges could have a historical impact on areas of need. During this time, many farmers and homeowners are likely to turn to the United States Department of Agriculture (USDA) and its Rural Housing Service (RHS) for support. Mortgage servicers have a big part to play in preparing and managing an influx of homeowners seeking disaster relief and loss mitigation options.

New research suggests a growing number of service members are opting for Department of Veterans Affairs (VA) mortgage programs over other alternatives. The Consumer Financial Protection Bureau’s (CFPB) Quarterly Consumer Credit Trends report for the first quarter of 2019 dug into first-time service member home buying trends.  The results should remind mortgage servicers of the need to stay on top of VA-specific policy requirements, especially the VA’s expanding disaster relief loss mitigation requirements.

The Consumer Financial Protection Bureau (CFPB) recently published an assessment of the significant mortgage servicing regulatory overhaul that went into effect in January 2014. To assist borrowers in avoiding foreclosure, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) required the consumer watchdog to expand the scope of regulatory and supervisory oversight of mortgage servicing under the Real Estate Settlement Procedures Act (RESPA). The legislation also required the CFPB to conduct an assessment of major rulemakings within five years of the effective date – bringing us to 2019.