What to Watch Out for with Your Mortgage Servicing Company

"Problems with payments head the list of consumer complaints about the companies that service home mortgages."

 

Mark Henricks

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Sep 6, 2016 10:02 AM EDT

ARTICLE LINK (CLICK HERE)

A Virginia borrower complained that after making a monthly mortgage payment via credit union electronic transfer the bank servicing the mortgage denied receiving payment despite two confirmation faxes from the credit union. In Texas, a borrower said a new servicer took over a loan, never sent a bill or responded to attempts to set up an account and make payments and then posted the home for foreclosure. 

These are two of 3,910 complaints about mortgages sent to the Consumer Financial Protection Bureau in July 2016. Mortgages represent the third-biggest category of complaints to the CFPB, behind debt collection and credit reporting. As of April 1, 2016, CFPB's online complaint system had handled nearly 860,000 complaints since it opened 2011, of which mortgages accounted for more than 223,000.

Mortgage complaints spiked during the last recession and housing downturn before falling to about their current level. Now they may be heading up again. During the first quarter of 2016, average monthly mortgage complaints were up 21% from the same period a year earlier, according to the CFPB.

Rocke Andrews, president of the Plano, Texas-based National Association of Mortgage Brokers, says during the downturn complaints tended to be about brokers but more recently concern servicers. One reason is that pricing pressure is causing servicer consolidation and efforts to reduce costs, he says.

"What you see now is there are probably five servicers that handle 75% of all servicing," Andrews says. "To make it profitable, you have to scale it up and do as much as you can automated. As a result, as a consumer, more than likely you're going to wind up with one of those automated systems when you call in for information."

Andrews says consumers with a problem can increase chances of a successful resolution by bypassing the automated systems -- often by pressing the "0" key -- and asking the human rep to speak with a supervisor. If that doesn't work, try hanging up and calling back, he suggests.

Complaints come in many varieties, but since 2011, most (51%) are "problems when you are unable to pay," according to the CFPB. Next is "making payments," cited by 31%. Complaints about applying, signing the agreement and receiving a credit offer are all single digit percentages.

Some problems are caused by borrowers confusing the servicer, which collects payments and disburses taxes and insurance, and the holder of the mortgage note. Borrowers may be upset that a servicer won't approve skipping a payment, when the borrower has to approve that, Andrews says.

Another common problem regards partial payments. Sometimes, such as during foreclosure proceedings, the amount owed may change after a payment is mailed and before it is received. The borrower may think payment has been made, when in fact it's been disallowed as a partial payment. New rules require servicers to tell borrowers upfront whether they will accept partial payments may help this problem, Andrews says.

While nearly a quarter of a million complaints to regulators sounds like a lot, Marina Walsh, a vice president with the Washington, D.C.-based Mortgage Bankers Association, notes that problems are typically handled before reaching the CFPB, and the complaint count is modest compared to the number of borrowers. "There are approximately 50 million outstanding mortgages in the U.S. and many more customer escalations or complaints are tracked and logged, then resolved directly by the mortgage servicer," Walsh says.

Walsh said dedicated phone numbers, customer service-friendly websites and better call center monitoring is helping to improve borrowers' experiences with servicers. "On the technology side, servicers have woken up and realized that they need to go digital especially for millennial borrowers," Walsh says. "This means revamping websites to provide more capabilities, offering seamless mobile options and generally moving toward a self-service and self-monitoring model preferred by some many borrowers, particularly Millenials."

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What to Watch Out for with Your Mortgage Servicing Company

"Problems with payments head the list of consumer complaints about the companies that service home mortgages."

 

Mark Henricks

 Follow

Sep 6, 2016 10:02 AM EDT

ARTICLE LINK (CLICK HERE)

A Virginia borrower complained that after making a monthly mortgage payment via credit union electronic transfer the bank servicing the mortgage denied receiving payment despite two confirmation faxes from the credit union. In Texas, a borrower said a new servicer took over a loan, never sent a bill or responded to attempts to set up an account and make payments and then posted the home for foreclosure. 

These are two of 3,910 complaints about mortgages sent to the Consumer Financial Protection Bureau in July 2016. Mortgages represent the third-biggest category of complaints to the CFPB, behind debt collection and credit reporting. As of April 1, 2016, CFPB's online complaint system had handled nearly 860,000 complaints since it opened 2011, of which mortgages accounted for more than 223,000.

Mortgage complaints spiked during the last recession and housing downturn before falling to about their current level. Now they may be heading up again. During the first quarter of 2016, average monthly mortgage complaints were up 21% from the same period a year earlier, according to the CFPB.

Rocke Andrews, president of the Plano, Texas-based National Association of Mortgage Brokers, says during the downturn complaints tended to be about brokers but more recently concern servicers. One reason is that pricing pressure is causing servicer consolidation and efforts to reduce costs, he says.

"What you see now is there are probably five servicers that handle 75% of all servicing," Andrews says. "To make it profitable, you have to scale it up and do as much as you can automated. As a result, as a consumer, more than likely you're going to wind up with one of those automated systems when you call in for information."

Andrews says consumers with a problem can increase chances of a successful resolution by bypassing the automated systems -- often by pressing the "0" key -- and asking the human rep to speak with a supervisor. If that doesn't work, try hanging up and calling back, he suggests.

Complaints come in many varieties, but since 2011, most (51%) are "problems when you are unable to pay," according to the CFPB. Next is "making payments," cited by 31%. Complaints about applying, signing the agreement and receiving a credit offer are all single digit percentages.

Some problems are caused by borrowers confusing the servicer, which collects payments and disburses taxes and insurance, and the holder of the mortgage note. Borrowers may be upset that a servicer won't approve skipping a payment, when the borrower has to approve that, Andrews says.

Another common problem regards partial payments. Sometimes, such as during foreclosure proceedings, the amount owed may change after a payment is mailed and before it is received. The borrower may think payment has been made, when in fact it's been disallowed as a partial payment. New rules require servicers to tell borrowers upfront whether they will accept partial payments may help this problem, Andrews says.

While nearly a quarter of a million complaints to regulators sounds like a lot, Marina Walsh, a vice president with the Washington, D.C.-based Mortgage Bankers Association, notes that problems are typically handled before reaching the CFPB, and the complaint count is modest compared to the number of borrowers. "There are approximately 50 million outstanding mortgages in the U.S. and many more customer escalations or complaints are tracked and logged, then resolved directly by the mortgage servicer," Walsh says.

Walsh said dedicated phone numbers, customer service-friendly websites and better call center monitoring is helping to improve borrowers' experiences with servicers. "On the technology side, servicers have woken up and realized that they need to go digital especially for millennial borrowers," Walsh says. "This means revamping websites to provide more capabilities, offering seamless mobile options and generally moving toward a self-service and self-monitoring model preferred by some many borrowers, particularly Millenials."

• . . . . . . . . . . . . . . . . .
• 
  
• Please contact us if you need help or resources as we are here and happy to help!
• 
  
• Respectfully,
• 
  
• Dana Shafman
• Managing Member
• END Consulting
• (888) 234-7006 Ext 101
• Dana@ConsultingEND.com
• 
  
• www.TheDailyComplaint.com

What to Watch Out for with Your Mortgage Servicing Company

"Problems with payments head the list of consumer complaints about the companies that service home mortgages."

 

Mark Henricks

 Follow

Sep 6, 2016 10:02 AM EDT

ARTICLE LINK (CLICK HERE)

A Virginia borrower complained that after making a monthly mortgage payment via credit union electronic transfer the bank servicing the mortgage denied receiving payment despite two confirmation faxes from the credit union. In Texas, a borrower said a new servicer took over a loan, never sent a bill or responded to attempts to set up an account and make payments and then posted the home for foreclosure. 

These are two of 3,910 complaints about mortgages sent to the Consumer Financial Protection Bureau in July 2016. Mortgages represent the third-biggest category of complaints to the CFPB, behind debt collection and credit reporting. As of April 1, 2016, CFPB's online complaint system had handled nearly 860,000 complaints since it opened 2011, of which mortgages accounted for more than 223,000.

Mortgage complaints spiked during the last recession and housing downturn before falling to about their current level. Now they may be heading up again. During the first quarter of 2016, average monthly mortgage complaints were up 21% from the same period a year earlier, according to the CFPB.

Rocke Andrews, president of the Plano, Texas-based National Association of Mortgage Brokers, says during the downturn complaints tended to be about brokers but more recently concern servicers. One reason is that pricing pressure is causing servicer consolidation and efforts to reduce costs, he says.

"What you see now is there are probably five servicers that handle 75% of all servicing," Andrews says. "To make it profitable, you have to scale it up and do as much as you can automated. As a result, as a consumer, more than likely you're going to wind up with one of those automated systems when you call in for information."

Andrews says consumers with a problem can increase chances of a successful resolution by bypassing the automated systems -- often by pressing the "0" key -- and asking the human rep to speak with a supervisor. If that doesn't work, try hanging up and calling back, he suggests.

Complaints come in many varieties, but since 2011, most (51%) are "problems when you are unable to pay," according to the CFPB. Next is "making payments," cited by 31%. Complaints about applying, signing the agreement and receiving a credit offer are all single digit percentages.

Some problems are caused by borrowers confusing the servicer, which collects payments and disburses taxes and insurance, and the holder of the mortgage note. Borrowers may be upset that a servicer won't approve skipping a payment, when the borrower has to approve that, Andrews says.

Another common problem regards partial payments. Sometimes, such as during foreclosure proceedings, the amount owed may change after a payment is mailed and before it is received. The borrower may think payment has been made, when in fact it's been disallowed as a partial payment. New rules require servicers to tell borrowers upfront whether they will accept partial payments may help this problem, Andrews says.

While nearly a quarter of a million complaints to regulators sounds like a lot, Marina Walsh, a vice president with the Washington, D.C.-based Mortgage Bankers Association, notes that problems are typically handled before reaching the CFPB, and the complaint count is modest compared to the number of borrowers. "There are approximately 50 million outstanding mortgages in the U.S. and many more customer escalations or complaints are tracked and logged, then resolved directly by the mortgage servicer," Walsh says.

Walsh said dedicated phone numbers, customer service-friendly websites and better call center monitoring is helping to improve borrowers' experiences with servicers. "On the technology side, servicers have woken up and realized that they need to go digital especially for millennial borrowers," Walsh says. "This means revamping websites to provide more capabilities, offering seamless mobile options and generally moving toward a self-service and self-monitoring model preferred by some many borrowers, particularly Millenials."

• . . . . . . . . . . . . . . . . .
• 
  
• Please contact us if you need help or resources as we are here and happy to help!
• 
  
• Respectfully,
• 
  
• Dana Shafman
• Managing Member
• END Consulting
• (888) 234-7006 Ext 101
• Dana@ConsultingEND.com
• 
  
• www.TheDailyComplaint.com

 Category:Press Release

Consumer Financial Protection Bureau Expands Foreclosure Protections

Updated Servicing Rule Provides Surviving Family Members and Other Homeowners with Same Protections as Original Borrowers

AUG 04, 2016 

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Washington, D.C. – The Consumer Financial Protection Bureau (CFPB) today finalized new measures to ensure that homeowners and struggling borrowers are treated fairly by mortgage servicers. The updated rule requires servicers to provide certain borrowers with foreclosure protections more than once over the life of the loan, clarifies borrower protections when the servicing of a loan is transferred, and provides important loan information to borrowers in bankruptcy. The changes also help ensure that surviving family members and others who inherit or receive property generally have the same protections under the CFPB’s mortgage servicing rules as the original borrower.

“The Consumer Bureau is committed to ensuring that homeowners and struggling borrowers are treated fairly by mortgage servicers and that no one is wrongly foreclosed upon,” said CFPB Director Richard Cordray. “These updates to the rule will give greater protections to mortgage borrowers, particularly surviving family members and other successors in interest, who often are especially vulnerable.”

Mortgage servicers are responsible for collecting payments from the mortgage borrower and forwarding those payments to the owner of the loan. They typically handle customer service, collections, loan modifications, and foreclosures. To address widespread mortgage servicing problems, the CFPB established common-sense rules for servicers that went into effect on January 10, 2014.

The CFPB issued proposed amendments to those rules in November 2014, and the final rule issued today adopts many of the proposed provisions. However, the Bureau made a number of changes in the final rule after considering comments received from the public.

The rule issued today establishes new protections for consumers, including:

• Requiring servicers to provide certain borrowers with foreclosure protections more than once over the life of the loan: Under the CFPB’s existing rules, a mortgage servicer must give borrowers certain foreclosure protections, including the right to be evaluated under the CFPB’s requirements for options to avoid foreclosure, only once during the life of the loan. Today’s final rule will require that servicers give those protections again for borrowers who have brought their loans current at any time since submitting the prior complete loss mitigation application. This change will be particularly helpful for borrowers who obtain a permanent loan modification and later suffer an unrelated hardship – such as the loss of a job or the death of a family member – that could otherwise cause them to face foreclosure.
• Expanding consumer protections to surviving family members and other homeowners: If a borrower dies, existing CFPB rules require that servicers have policies and procedures in place to promptly identify and communicate with family members, heirs, or other parties, known as “successors in interest,” who have a legal interest in the home. Today’s final rule establishes a broad definition of successor in interest that generally includes persons who receive property upon the death of a relative or joint tenant; as a result of a divorce or legal separation; through certain trusts; or from a spouse or parent. The final rule ensures that those confirmed as successors in interest will generally receive the same protections under the CFPB’s mortgage servicing rules as the original borrower. 
• Providing more information to borrowers in bankruptcy: Under the CFPB’s existing mortgage rules, servicers do not have to provide periodic statements or early intervention loss mitigation information to borrowers in bankruptcy. Today’s final rule generally requires, subject to certain exemptions, that servicers provide those borrowers periodic statements with specific information tailored for bankruptcy, as well as a modified written early intervention notice to let those borrowers know about loss mitigation options. Servicers also currently do not have to provide early intervention loss mitigation information to borrowers who have told the servicer to stop contacting them under the Fair Debt Collection Practices Act. Today’s final rule generally requires servicers to provide modified written early intervention notices to let those borrowers also know about loss mitigation options.
• Requiring servicers to notify borrowers when loss mitigation applications are complete: Whether a borrower is entitled to key foreclosure protections depends in part on the date a borrower completes a loss mitigation application. If consumers do not know the status of their application, they cannot know the status of those foreclosure protections. Today’s final rule requires servicers to notify borrowers promptly and in writing that the application is complete, so that borrowers know the status of the application and have more information about their protections.
• Protecting struggling borrowers during servicing transfers: When mortgages are transferred from one servicer to another, borrowers who had applied to the prior servicer for loss mitigation may not know where they stand with the new servicer. Today’s final rule clarifies that generally the new servicer must comply with the loss mitigation requirements within the same timeframes that applied to the transferor servicer, but provides limited extensions to these timeframes under certain circumstances. If a borrower submits an application shortly before transfer, the new servicer must send an acknowledgment notice within 10 business days of the transfer date. If the borrower’s application was complete prior to transfer, the new servicer must evaluate it within 30 days of the transfer date. If the new servicer needs more information to evaluate the application, the borrower would retain some foreclosure protections in the meantime. If the borrower submits an appeal, the new servicer has 30 days to make a determination on the appeal.
• Clarifying servicers’ obligations to avoid dual-tracking and prevent wrongful foreclosures: The CFPB’s existing rules prohibit servicers from taking certain actions in foreclosure once they receive a complete loss mitigation application from a borrower more than 37 days prior to a scheduled sale. However, in some cases, borrowers are not receiving this protection, and servicers’ foreclosure counsel may not be taking adequate steps to delay foreclosure proceedings or sales. The CFPB’s new rule clarifies that, if a servicer has already made the first foreclosure notice or filing and receives a timely complete application, servicers and their foreclosure counsel must not move for a foreclosure judgment or order of sale, or conduct a foreclosure sale, even if a third party conducts the sale proceedings, unless the borrower’s loss mitigation application is properly denied, withdrawn, or the borrower fails to perform on a loss mitigation agreement. The clarifications will aid servicers in complying with, and assist courts in applying, the dual-tracking prohibitions in foreclosure proceedings to prevent wrongful foreclosures.
• Clarifying when a borrower becomes delinquent: Several of the consumer protections under the CFPB’s existing rules depend upon how long a consumer has been delinquent on a mortgage. Today’s final rule clarifies that delinquency, for purposes of the servicing rules, begins on the date a borrower’s periodic payment becomes due and unpaid. When a borrower misses a periodic payment but later makes it up, if the servicer applies that payment to the oldest outstanding periodic payment, the date the borrower’s delinquency began advances. The final rule also allows servicers the discretion, under certain circumstances, to consider a borrower as having made a timely payment even if the borrower’s payment falls short of a full periodic payment. The increased clarity will help ensure borrowers are treated uniformly and fairly.

Today’s final rule makes additional changes to the CFPB’s mortgage servicing rules. These changes include providing flexibility for servicers to comply with certain force-placed insurance and periodic statement disclosure requirements. The changes also clarify several requirements regarding early intervention, loss mitigation, information requests, and prompt crediting of payments, as well as the small servicer exemption. Further, the changes exempt servicers from providing periodic statements under certain circumstances when the servicer has charged off the mortgage. Finally, concurrently with the final rule, the CFPB is issuing an interpretive rule under the Fair Debt Collection Practices Act relating to servicers’ compliance with certain mortgage servicing provisions as amended by the final rule.

Most of the provisions of the final rule will take effect 12 months after publication in the Federal Register. The provisions relating to successors in interest and the provisions relating to periodic statements for borrowers in bankruptcy will take effect 18 months after publication in the Federal Register.

View final rule

View interpretive final rule

###
The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives. For more information, visit www.consumerfinance.gov.

Topics:

• •FAIR DEBT COLLECTION PRACTICES ACT
 
• •MORTGAGE SERVICING
 
• •DEBT COLLECTION
• •REGULATION
 
• •FORECLOSURE
 
• •RULEMAKING
 
• •MORTGAGES

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CFPB Issues PMI Cancellation and Termination Guidance Bulletin

Author: Xhevrije West in Daily Dose, Government, Headlines, News

August 4, 2015

ARTICLE LINK (CLICK HERE)

In an effort to bring mortgage servicers into compliance with the Homeowners Protection Act, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on Tuesday providing guidance to servicers regarding the cancellation and termination of private mortgage insurance (PMI).

According to the CFPB, private mortgage insurance provides protection to the lender if the borrower stops making payments on the loan. Private mortgage insurance is usually required by lender if the borrower's down payment is less than 20 percent of the sales price or appraised value of the home and are added to the borrower's monthly mortgage payment.

Congress passed the Homeowners Protection Act of 1998 to provide borrowers with cancellation and termination rights with their private mortgage insurance policy, the CFPB says. The law requires automatic termination of private mortgage insurance once the mortgage balance is reaches 78 percent of the original value of the property, among other criteria.

Private mortgage insurance is a huge cost to consumers, but the Homeowners Protection Act provides specific cancellation and termination rights to protect consumers from unnecessary costs. The CFPB advises that if a servicer does not cancel a borrower’s private mortgage insurance in a timely manner, it can lead to the borrower paying significant amounts of money on unnecessary premiums.

“Consumers should not be billed for unnecessary private mortgage insurance,” said Richard Cordray, CFPB director. “We will continue to supervise mortgage servicers to ensure they are treating borrowers fairly, and today’s guidance should help servicers come into compliance with the Homeowners Protection Act.”

The CFPB noted that this bulletin does not advise of any new responsibilities or requirements, but summarizes existing requirements under the law.

In addition to reaching the 78 percent loan-to-value (LTV) threshold, the borrower must meet certain other requirements for borrower-requested private mortgage insurance cancellation:

• The borrower must have a good payment history.
• The borrower must be current on the loan.
• The borrower must satisfy any requirement of the holder of the mortgage for certification that the borrower’s equity in the property is not subject to a subordinate lien.
• The borrower must satisfy any requirement of the holder of the mortgage for evidence (of a type established in advance and made known to the borrower by the servicer) that the value of the property has not declined below the original value.

Click here to view the CFPB's Private Mortgage Insurance Advisory Bulletin. 

Click here to view the CFPB's Summer 2015 Supervisory Highlights. 

. . . . . . . . . . . . . . . . .

Please contact us if you need help or resources as we are here and happy to help!

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Why Default Servicing Processes Haven't Improved Since the Crisis

BY KARL FALK

AUG 4, 2015 12:32pm ET

ARTICLE LINK (CLICK HERE)

After years of historically high levels of distressed and default mortgages, servicers are still over-reliant on human mediation and interaction when there should be no subjectivity in the process.

Despite recent headlines indicating a normalized environment, significant residual issues persist that undermine the default servicing industry's potential for true healthiness. For example, the truly abysmal rate of borrower participation in traditional default servicing processes is a trend that continues to confound servicers and compromise their compliance strategies.

What the origination side has learned, and what servicing needs to understand, is that throwing bodies at a problem does not solve the problem, and changing internal processes is not the smoking gun, either. The servicing industry should adopt greater automation to more efficiently clear out its backlog of defaults and better manage spikes in the future.

What's needed is a fundamental shift in servicers' relationships with customers that modifies communication to speak the "language" of borrowers in a healthier way.

This begs two questions: "Is the default servicing process any better than it was in 2007?" And, "Have we learned from the faults of our past?"

Every lender/servicer has documented guidelines regarding foreclosure alternative qualifications, which are based on a set of calculations. Excise the always fallible, often-biased human element from default servicing calculations and get right to the facts.

Mediation, in states requiring judicial review of foreclosure, is redundant and a drag on the process. Self-service makes a non-mediated default resolution possible.

In automating as much as possible, servicers can devote their human capital to outliers or exceptions, and process finalization, instead of managing the entire process start to finish.

Mortgage delinquency rates increased a scant 1.46% from March to April, but the national mortgage delinquency rate is down 15% from one year ago. In addition, though non-foreclosure solutions outpaced foreclosures in Q1 2015, overall loan modifications, short sales, deed in lieu transactions, foreclosure starts and foreclosure sales, as well as serious loan delinquencies, continue to decline.

What these numbers don't address is the enormous backlog of defaults that have yet to be resolved. According to Federal Deposit Insurance Corp. data, banks have $57.9 billion residential loans in the process of foreclosure, representing 48% of all nonperforming loans.

Defaults are absolutely trending downward, but this cyclical industry guarantees that everything comes around again. Being better prepared for them helps ensure the waves don't knock you down.

Self-service options would enable borrowers to participate in a process that isn't really designed around the average consumer's level of understanding. The prevailing thought on how to fix the default industry and increase distressed borrower engagement is to change the documentation so that borrowers can better understand them, but the problem isn't with the documents. It's with the process itself.

Take tax preparation software, for example. Tax documents are difficult for even financially educated consumers to understand, and yet, every year, millions of consumers prepare and file their own taxes using tax preparation software. If the documents weren't filled out correctly, the software companies would be out of business.

These companies succeed not by changing the documents to make them easier to understand or by changing the tax laws, but by changing the process by which consumers calculate their tax responsibility. Document fulfillment is simply a byproduct of making the process easier.

Default servicing via a self-service platform can work much the same way. On average, borrowers are not well versed in the particulars of foreclosure alternatives.

Although borrowers are not loss mitigation experts, they are experts on their current situation. Borrowers can tell if you if they want to stay in their home, if they have income, what their current monthly expenses are. With self-service technology allowing borrowers to direct their own loan workout process, default servicers can capture data at the point of entry and use the information to drive the rest of the process, rather than requiring paperwork up front before an assessment is even made.

There is something fundamentally wrong with the way the default servicing process operates today, and it will not fix itself. If we have learned anything from the foreclosure crisis, it is that the default servicing process must be managed better, and servicers need to reimagine how this process works to avoid becoming buried by volume and ill-will during spikes in defaults.

Karl Falk is CEO and co-founder of ShortSave.

. . . . . . . . . . . . . . . . .

Please contact us if you need help or resources as we are here and happy to help!

Respectfully,

Dana Shafman

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