On November 10th, the regulatory agencies released a joint statement on supervisory and enforcement practices related to mortgage servicing in light of COVID-19.
Back in April 2020, a joint statement was issued to communicate that the agencies did not intend to take supervisory or enforcement action for delays in sending out notices or taking other required actions related to early intervention or loss mitigation, as long as good faith efforts were being made to be in compliance. This “flexibility” will no longer apply and servicers should fully comply with the timing and other requirements.
Regardless of whether you’re a small or large mortgage servicer, you will want to make sure your servicing practices are on-point. The nation’s largest subservicer of residential mortgages, Cenlar, was recently the subject of a cease and desist order for inadequate internal controls and risk management. Two areas where Cenlar apparently fell short were root cause analysis and appropriate resolution. These two items are essential to any successful review or audit program.
If you need a refresher on the mortgage servicing requirements, our Mortgage Servicing webinar is available now OnDemand.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!