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MortgagePoint » Your Trusted Source for Mortgage Banking and Servicing News 44 January 2024 F E A T U R E D o you ever get the feeling that someone is always moving the goal posts? That certainly seems to be the case when it comes to servicer call center commu- nications. Historically, regulators have determined compliance by reviewing the timing of borrower communications and the content of written correspondence. Now, banks and servicers are being placed in a position where the overall tone of a phone call with a borrower is being tested and judged, making examinations less objective by possibly introducing more subjectivity on the part of the examiner. While objective requirements con- tinue to be at the core of servicer reviews, servicers are now also evaluated on how well their call centers are "handling" the calls with borrowers, who are often distraught or confused or simply do not know the right questions to ask. In a growing number of instances, complaints are no longer at the center of discussion when talking about the quali- ty of a call. Instead, in a "damned-if-you- do, damned-if-you-don't" scenario, call center agents are being cited for both not asking the right questions and conversely for "leading" the borrower down a path. Let us take a "then vs. now" look at how an examiner might evaluate a call. Traditionally, the examiner focused on: If an outbound attempt was made … • Was the call placed between 8:00 a.m. and 9:00 p.m. in the borrower's physical time zone? • Were there any existing requests from the borrower regarding contact, and were they followed? • Was the frequency and pattern of the contact compliant? • Were the Federal and State Mini Miranda requirements adhered to? • Were the presumptions contained within the Debt Collection Rule violated? During the conversation, did the agent … • Refrain from obscene or profane language? • Refrain from the threat of the use of violence? • Was Right Party Contact achieved? Now, however, the overall tone and result of the call can also come into play with these additional questions … • Did the agent display empathy? • Did the agent follow the prescribed waterfall for loss mitigation activity? • Did the agent "lead" the borrower to a solution? • Was the agent courteous? • Was the borrower satisfied at the end of the call? So, what is a servicer supposed to do? Train. Test. Repeat. O bviously, the quality and efficiency of any function within a servicing operation depends on people, and peo- ple are fallible and predictably unpre- dictable. To help control this, servicers create training programs and develop scripts for agents, but no script is all encompassing and not every borrower situation is identical. Again, what is a servicer supposed to do? Going for- CALL CENTERS UNDER NEW SCRUTINY FOR 'SOFT SKILLS' Samantha Shanaberger of Clayton Servicing Oversight examines the policies and practices of servicer call centers, and how these centers must remain vigilant of changing rules and regulations. . B y S A M A N T H A S H A N A B E R G E R S A M A N T H A S H A N A B E R G E R serves as VP of Business Development for Clayton Servicing Oversight, a Covius Solution. Shanaberger is an industry veteran with nearly 20 years of experience in default servicing and subservicing-related activities, including foreclosure, bankruptcy, claims, property preservation, and REO activities. Throughout her career, Shanaberger has held executive positions at leading banks and servicers, including Bank of America and U.S. Bank, and has successfully helped various U.S. institutions navigate OCC Consent Orders, NMS, countless CFPB Examinations, and risk and compliance improvements.