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63 approach to perfecting loan data files and pools will disrupt traditional servicing business models by elevating the user experience for lenders, investors, and borrowers." One of the biggest areas of concern for attorneys is the Personally Identifiable Information (PII) that is regularly contained in the documents which are attached to complaints, proofs of claims, judgments, and other documents. Redacting this information from documents is a time-consuming, tedious, monotonous, and imperfect process. Some of the technology provided to assist with the process is imperfect, allowing boxes to be moved unless a document has been appropriately flattened, or even reprinted and copied. Firms across the country have been engaged in projects to assist with painful after- the-fact fixes to cure the situation, including court hearings, notification of the consumer, and possible sanctions and financial penalties for the servicer and attorney. With Optical Character Recognition (OCR) and ML technology, however, the opportunity exists for document redaction, which is manual and imperfect, to be much more consistently correct and significantly less costly. AFTER THE MORATORIA LAPSE Given the moratoria which we are now operating under, the time is coming quickly when firms and servicers will be challenged in ways that will rival the financial crash of 2008. While we have done an amazing job providing forbearances to borrowers, with the moratorium in place it has been accomplished in a vacuum. We are basically just giving the borrower what they want. If they don't make a payment or return a document or a call, there is no consequence. When the moratoria end, any patience or extension regarding foreclosure timelines will cease to exist. We will be challenged to provide that same amazing customer service to borrowers while we are trying to meet investor timelines for foreclosure and bankruptcy, all while making sure that we do not "dual-track," that we have "standing," and that any new regulations are adhered to. Law firms will be likely starting a record number of foreclosures, ensuring that there are no errors, including no PII in the documents attached to complaints or claims. By way of illustration, consider two AI- powered technology providers that are getting significant traction during the foreclosure moratoria: Ocrulus on the origination side and Blackmarker on the default side. Ocrulus digitizes, classifies, and validates loan application data using sophisticated AI in every step of the process. ey're helping a number of firms save money and reduce cycle times in the process. Meanwhile, Blackmarker helps servicers reduce compliance risk by automatically redacting PII from foreclosure and bankruptcy filings. Vic Diloreto, CEO of Blackmarker, notes, "in collaboration with our clients, Blackmarker has measured accuracy of our redaction services and compared them to pre-automation processes, and we are seeing a significant increase in accuracy with an always on service, cloud deployed, that evolves as the technology does. Using state-of-the- art AI techniques, Blackmarker can shore up the errors, while scaling up or down to the fluctuations in foreclosure volumes and allowing firms to bring back staff where they can be more effective." WHERE WE'RE HEADED As during the beginning of the pandemic and how we adapted in previous crises, my expectation is that our industry will innovate and adapt to that "re-start" timeline. is will accelerate our innovation. Servicers and attorneys who adopt artificial intelligence to determine how to cut costs through automation, correct documents, and other problems prior to default will be measurably better in managing their portfolios in the future. When we look through and past our immediate issues it is exciting to think about where our industry could be in 5 or 10 years. Is it possible that attorneys and servicers can work together to eliminate the risk posed by PII on documents in the courts? Is it possible that servicers and service providers identify trends documents or other factors that identify potential loan losses and put resources to work to eliminate the factor prior to the loss occurring? When baseball analytics indicate that the infield should shift, or the designated hitter is implemented, there is a reaction. In baseball, there have been calls to require infielders to remain on their own side of the infield, or the universal implementation or outlawing of the designated hitter. Our industry is at least as complex. As AI is accepted and implemented, we need to think about the unintended loan servicing consequences of a "three infielders on one side of the diamond solution"; postponements resulting in interest curtailments, mistakenly ordering a lockout, FDCPA and TCPA violations, redlining, and other significant consumer impacts. We have many competing objectives. e winners will be our teams that understand and use the analytics and incredible horsepower provided by ML and AI, but they must also have the wisdom, diligence, and fortitude not to take shortcuts that offset the very gains provided by ML and AI. Michael F. Sullivan manages client relations and business development for the Codilis Family of Firms, serving the industry in Illinois, Indiana, Missouri, Texas, and Wisconsin. Sullivan has also served in several leadership roles in related entities: LCS Financial, Moss Codilis, Default Servicing Solutions, and Claims Recovery Financial Services providing services ranging from loss mitigation to bankruptcy to mortgage insurance claims. Prior to Codilis, Sullivan managed loss mitigation for Norwest Mortgage, foreclosure and bankruptcy for Prudential Home Mortgage, and REO at First Nationwide Bank and Community Federal Savings and Loan dating back to the Saving and Loan Crisis.