Many financial institutions service some loans held in its portfolio and some may sell loans outright or sell the rights to service certain loans separately from any ownership transfers. In light of mortgage reform, the rules regarding servicing are complex and an increased regulatory scrutiny is evident. Servicers must comply with various laws to the extent that the law applies to the particular servicer and its activities which could include servicing transfers and loan ownership transfers; escrow disclosures, maintenance of escrow accounts and insurance products; payment processing, account maintenance, consumer inquiries, complaints, and error resolution procedures; default servicing, collections, loss mitigation, and foreclosure processes.
The loan servicing review will focus solely on consumer compliance disclosure and monitoring required after loan closing and will include a review of the Bank’s compliance management system as it relates to loan servicing. Specialized training will be provided on-site to applicable personnel and will focus primarily on any deficiencies noted during the review.
Generally the review will include the following areas as applicable
The loan servicing review will focus solely on consumer compliance disclosure and monitoring required after loan closing and will include a review of the Bank’s compliance management system as it relates to loan servicing. Specialized training will be provided on-site to applicable personnel and will focus primarily on any deficiencies noted during the review.
Generally the review will include the following areas as applicable
- Forced Placed Flood Insurance and Hazard Insurance
- Servicing and ownership transfer notices
- Open-end Credit Statements including HELOCs, credit cards, and LOCs
- Servicemember notice requirements, rate reductions, and servicing practices
- Late Notices – Home ownership counseling
- Credit card servicing rules
- Payoff requests and proper crediting of loan payments
- Escrow account analysis
- PMI requirements
- Advertising
- Loss Mitigation Procedures
- ARM payment change notices
- Error Resolution
- Internal Debt Collection Practices