Comments for Home Mortgage Consumer Protection

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Moderator

Moderator — Thu, 04 Oct 2012 20:00:12 +0000

Hi Versability1 – We think this is pretty clear in the summary, see the last sentence in section 6 – “S/he argued that the law should categorically prohibit charging REO insurance against the borrower’s escrow.”

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Moderator

Moderator — Thu, 04 Oct 2012 19:17:56 +0000

Thanks, versability1. The current draft makes this point about insurance trackers, but we will add lenders to the final version.

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Brian Penny

Brian Penny — Thu, 04 Oct 2012 17:52:56 +0000

Just to clarify, REO insurance should NEVER be charged to the borrower. The problem isn’t the cost of REO, it’s that it’s even being charged to the consumer in the first place. REO insurance NEVER covers the borrower. It is intended to cover the structure after foreclosure.

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Brian Penny

Brian Penny — Thu, 04 Oct 2012 17:52:48 +0000

Ignore that…meant to post it above…

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Brian Penny

Brian Penny — Thu, 04 Oct 2012 17:40:37 +0000

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Brian Penny

Brian Penny — Thu, 04 Oct 2012 17:39:16 +0000

Borrowers need not only to be able to update their information online, but they need to be able to do it proactively on the loan servicer’s website. When we just say “online” the banks state they can do it online, but it’s at Assurant & QBE’s websites. Nobody would know to go to those until they’re told they don’t have the required insurance, and again, they’re only updating that information directly to the Insurance Tracker/Force-Placed Insurer. They have no way of directly providing the information to the Loan Servicer. People won’t go to a website they don’t trust to update their personal information (if you’d like to see an example, go to ihaveinsurance.com) and it also leads to confusion when a Loan Servicer’s… more »

…mortgage and auto portfolios are tracked by 2 different Insurance Trackers. How would a consumer know to go to 2 different websites to upload information for their home & auto loans, especially when neither website is the website for the company they trust to hold their loan (i.e Bank of America, Wells Fargo, Chase). If the regulations don’t accommodate real world situations that real consumers face, then they are worthless. « less

Comment on For Borrowers in Trouble: “Force-Placed” Insurance by Brian Penny

Brian Penny — Thu, 04 Oct 2012 17:05:50 +0000

I think it’s important to emphasize that an insurance tracker should not be allowed to act as both the loan servicer and the force-placed insurer in the event of a claim. The insurer/mortgager relationship should be an adversarial relationship. If 1 lawyer can’t represent opposing clients in a case, then 1 company shouldn’t be allowed to be your only point of contact for both sides of an insurance matter. Currently the Insurance Tracker acts as both.

Comment on For Borrowers in Trouble: Options for Avoiding Foreclosure by Moderator

Moderator — Thu, 04 Oct 2012 16:43:51 +0000

Hi Sue806 – We tried to include your comments on the issue post in sections 2 & 5 (Need for Enforcement). Do you think the summary is missing anything or is unclear?

Comment on For Borrowers in Trouble: Options for Avoiding Foreclosure by sue806

sue806 — Thu, 04 Oct 2012 04:22:14 +0000

The new industry wide practice is to offer modifications as an incentive to negative equity homeowners to remain negative equity homeowners because the INVESTOR loses a guarantee portion of their money with a foreclosure sale. There are numberous laws on the books addressing this issue, the most basic and simple one is- all similiarly situated parties, the homeowners with the same loan to value are legally entitled to the same reimbursement, incentive, modification that others( over 6 milion) received.
Unless there is a national modification program like the Unitedinprosperity.org program removing the fox from the hen house, no additional rules or laws will work simply because they will be voluntary without enforement.

Comment on For All Borrowers: Asking For, and Getting, Information by transparency

transparency — Tue, 02 Oct 2012 01:39:25 +0000

Problem: “The servicer would not have to respond to requests that come more than 1 year after the loan is paid off.
Solution: No time limit to expose mortgage abuse. We have not solved the problems in 4 years so how could one year be a fair time line? (Common sense)

Problem: Allowing servicers to charge for information on your account.
Solution: All monthly account activity directly and indirectly needs to be transparent on the monthly loan statement, this is not an alicart restaurant.