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56 When entering the realm of statistics, numbers definitely have the potential to weave plenty of misleading and false narratives. is is unfortunate since stories based on quantitative data tend to survive on their numerical authority alone, while sometimes hiding behind subtle deceptions based on the foundation of mathematical analysis. Such is the case with the Consumer Financial Protection Bureau (CFPB) Consumer Complaint Database. e database is filled to the brim with complaints about servicers, lenders, and financial service providers. Was a servicer late in dealing with a loan modification, unreceptive by phone, or flat out unhelpful or rude? e CFPB database of complaints is there to catch those grievances and report them to financial services industry and the world as informed data. But probe deeper, as some analysts did recently, and the numbers from the CFPB do not look as daunting or as thorough as they do at first glance. In fact, the industry discovered that simply analyzing data from the CFPB is not enough, especially since the database arrives with its own built-in bias—that bias being the very nature of the database itself. It collects complaints, not praises, and ignores the larger universe of loans serviced nationwide. To fill the void of well-rounded data, Black Knight Financial Services and the Five Star Institute jumped into the missing space and used data from the CFPB database and its own analytics to inform its latest white paper on CFPB complaints. e big takeaway from the report: servicers have improved tremendously. THE NUMBERS IN CONTEXT As servicers become preoccupied with fixing problems reported in the database, one significant development has slipped under the radar: the number of CFPB complaints plummeted by more than 50 percent for loan modifications, collections, and foreclosures during the two-year period stretching from 2013 through 2014, according to a recent white paper titled "Analysis and Study of CFPB Consumer Complaint Data Related to Mortgage Servicing Activities," produced by Black Knight Financial Services in conjunction with the Five Star Institute. I N D U S T R Y I N S I G H T / K E R R I P A N C H U K & B R I A N H O N E A Complaints to the CFPB may not be what they seem.

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