DS News

DS News June 2021

DSNews delivers stories, ideas, links, companies, people, events, and videos impacting the mortgage default servicing industry.

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Page 76 of 99

75 should be prepared to properly recast the past due obligations to cure the default and return to current payment schedules with minimum intervention. is renders forbearance plans expiring in September with regular payment obligations resuming in October as ineligible for notice of filing and foreclosure as they will be less than 120 days delinquent under the existing rule until at least a month after the December 31, 2021, moratorium period. Complying with the intent of the moratorium should not be troubling for most servicers that have prepared for the exit—and experienced the Great Recession. e industry should also prepare for the indirect consequences of such a moratorium, including the fact the strength of the housing market today may suffer due to reduced property values and increasing deficiencies post-sale if distressed properties flood the market over the next 24-plus months. It may also introduce an increase of strategic defaults where the proposed regulations weaken the ability to enforce delinquency consequences. is population and credit risk is separate and apart from those exposed by unfair actions of servicers. Beyond the immediate priority to return existing notes to original terms, mortgage servicers should also prepare for an influx of other challenges surrounding borrowers in forbearance: Communication channels—e world went online due to COVID-19. Respond to borrower preferences for instant access and online tools to automate the ingestion of borrower information related to requests for assistance. Tracking and reporting—Review the pipeline to ensure completeness of population. Examiners will be asking who asked for help, who received help, and for reporting around those that subsequently defaulted or experienced consequences of default. Taxes and insurance—Negative escrow shortages and spreads will require scalable solutions as will the increase of force placed insurance and required advances for non- escrowed accounts. ere is still time to expand digital footprints and increase self-service features soundly and at scale. Reducing manual processes and increasing consumer transparency will curb compliance risks and improve customer satisfaction scores. Carissa Robb serves as President & COO of Constant AI, a digital loan servicing and loss mitigation provider. She most recently served as SVP and Head of U.S. Loan Servicing for TD Bank, responsible for servicing a $150 billion dollar portfolio of auto, consumer, residential, and commercial accounts. She joined TD Bank in 2009, overseeing collections channels and loss mitigation programs for distressed real estate, as well as servicing in executive roles responsible for audit remediation and governance and control frameworks for TD Bank's loan servicing and collections divisions. She can be reached at crobb@constant.ai or found on LinkedIn at linkedin.com/in/carissa-robb- a5a26615.

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