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56 better-informed financial decisions by engaging them at the right moments in their financial lives (i.e., moments when they are most receptive to seeking out and acting on assistance). To that end, the CFPB has established guidelines and standards that provide homeowners with targeted, meaningful, and accessible assistance and information. e CFPB framework for customer service requires mortgage servicers to organize their business so they can: » Allow homeowners to access correct information about their loan; » Respond promptly and correctly to problems; » Pass along complete, correct, and timely information when loan servicing is sold or transferred to another company; » Properly evaluate alternatives (i.e., loss mitigation options) for relief when homeowners encounter difficulties paying; and » Maintain records for at least one year after loan payoff. TECHNOLOGY Servicers generally utilize an interactive voice response (IVR) system to validate callers, forward calls to the right party, allow callers to leave recorded messages, permit callers to access self-help menus, gather usage statistics, identify periods of high call volumes in order to plan staffing for peak periods, and balance the use of phone lines. IVR information can be passed along to call agents through screen pop-ups, eliminating the need for homeowners to constantly repeat information. At the same time, this cue helps give customer service representatives (CSRs) preparatory time for upcoming calls. In addition, an automatic call distributor (ACD) may be utilized to target information gathered by the IVR to route calls to the correct personnel and departments, making it much easier for homeowners to get a more immediate level of service they require without being transferred from agent to agent. IVRs help enhance servicer productivity by assigning inbound customer service agents to incoming calls through the use of predefined instructions. For calls routed to a specific individual, the CSR is responsible for updating the underlying servicing system concerning the nature of the call. Underlying servicing systems are updated automatically with a description of the inquiry for homeowners utilizing self-help menus (i.e., balance inquiries, requests made for forms, etc.). For homeowners who are current, calls are generally routed and cued to the next available CSR. For homeowners who are either delinquent, in foreclosure, in bankruptcy, or pursuing available loss mitigation options, inbound calls will be routed to the appropriate department and SPOC. Federal and state regulatory guidelines do not exist requiring servicers to utilize IVRs and ACDs. As such, specific metrics and key performance indicators (KPIs) relating to this topic are not required. However, a key consumer finance regulatory theme relates to maintenance by servicers of a robust customer service function that is responsive and provides accurate and timely information to homeowners. erefore, proper and prompt routing by servicers of inbound homeowner calls to the appropriate individual/department is a critical goal. It is therefore reasonable to assume the utilization of technology is an appropriate enabler toward achieving this goal. METRICS Servicers should consistently capture and monitor customer service performance via critical metrics and KPIs, with performance reviewed opposite normal and usual industry practices. ese metrics/KPIs include, but may not be limited to: » Call Abandon Rate: Generally, abandon rates for inbound calls should not exceed 3 percent of all inbound calls that are received on a given day; » Homeowner Hold Time: Homeowners should not be placed on hold for more than 60 seconds; » Average Speed of Answer (ASA): Inbound homeowner calls should be answered within 30 seconds; » Average Talk Time: (i) For homeowners who are current and calling with general administrative matters, average talk time should generally not exceed one minute. (ii) For homeowners who are delinquent more than 30 days or for those homeowners who are calling to discuss specific loss mitigation or foreclosure protocols, average talk time will likely vary and therefore a specific standard may not be appropriate. (iii) For homeowners who are either current or who are delinquent, and also wishing to discuss an error or initiate a specific dispute, average talk time will likely vary, depending on the topic and issue raised and therefore a specific standard may also not be appropriate; and » One Call Resolution: For homeowners who are current and calling with general administrative matters For both current homeowners or for homeowners who are more than 30 days delinquent or for homeowners (regardless of default status) who are discussing an error or initiating a specific dispute, one-call resolution (while it should remain the goal of each servicer) may not be appropriate, reasonable, or practical; therefore, a specific standard may not be appropriate. Random call listening is also an excellent means of quality control in order to monitor performance of customer service personnel. ROUTINE HOMEOWNER INQUIRIES Specific CFPB regulatory guidelines and standards do not exist over the timing associated with the handling of routine homeowner questions, inquiries, and correspondence. Routine homeowner questions, inquiries, and correspondence may include, but are not limited to: » Balance inquiries; » Payment due dates; » Payoff balance requests; » Tax, insurance, and other escrow inquiries and questions; » Requests for forms and other documentation; » Servicer's mailing address, location(s), and other contact information; » Servicer's hours of operation; » Status of payments sent; » Inquiries and questions concerning monthly statements/coupon books received; » Non-receipt of monthly statements/coupon books; » Late fees and others service fees assessed; » Change of address; » NSF charges and related protocols; » Adjustable-rate mortgage (ARM) inquiries (i.e., rates, reset dates, etc.); » Privacy notices and other correspondence received from the servicer; » Modification and other inquiries regarding government programs; and » Changes in homeowner status (i.e., widowed, divorced, etc.). Servicers generally have specific personnel assigned to work with homeowners (sometimes called customer service expediters) to perform research and handle processes associated with these routine matters. As appropriate, expediters will refer items to the applicable internal servicing unit (i.e., collections, loss mitigation, bankruptcy, etc.). An expediter's job is to support and act as an extension of the CSR and perform necessary follow-up and research to answer routine homeowner questions and fulfill their requests. Any concerns, issues, problems, or errors associated with or arising from any routine homeowner questions, inquiries, and

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