Comments on: For All Borrowers: Periodic Statements

By: transparency

transparency — Tue, 02 Oct 2012 00:33:13 +0000

Problem: Every place where there is not transparency in lending there is fraud.
Solution: All account activity directly and indirectly in your account has to be on the monthly statement addressing companies by name not category.
Problem: “depending on circumstances”
Solution: No, ALL circumstances

By: Moderator

Moderator — Wed, 26 Sep 2012 18:49:50 +0000

loanswithjorge, The purpose of Regulation Room is to provide an environment in which people can learn about important proposed government regulations and discuss them in ways that help the agency make a better final decisions. Everyone who comments on the site is expected to remain civil and respectful. Please see the Terms & Conditions you agreed to when you registered.

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 18:34:25 +0000

Because of your lack of education on the ACTS that now govern and control how YOU/YOUR ORGANIZATION works with consumers, let it be a “DEMO” of what happens with you make exceptions.

Based on the SAFE ACT…I will say, maybe a long shot…but, you are NOT a LICENSED MLO, maybe just registered…and if an executive of the bank, you did not even submit a background check or credit report.

What makes you so worthy to comment?

By: Moderator

Moderator — Wed, 26 Sep 2012 18:29:51 +0000

Thank you for your comment, amyrozycki. It sounds like you think that consumers generally should be entitled to periodic statements, but that small servicers should be able to solicit their clients for waivers. What do others think of this proposal?

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 18:25:43 +0000

Exceptions are simply loop holes for the opportunity to take advantage of the unsuspecting/uneducated…this is absolutly out in left field.

As mentioned in comments below…in short, equality is vital…big or small…mom and pop vs chains…the rules need to be the same.

In response to another comment…the minute you feel your company is overwhelmed, CREATE A JOB (there are plenty of people that need jobs)…it would be a great time and opportunity to grow your business and take your business to the next level…get out of your comfort zone. You might sit and say, “this is alot for little old me with only 1000 files”, but rest assured that the company with hundreds of thousands of files is saying, “holy cow, this is going to cost me… more »

…millions”…you are just at a different level.

Equally the same for everyone, big or small. « less

By: amyrozycki

amyrozycki — Wed, 26 Sep 2012 18:15:01 +0000

This issue really should be a part of the fair lending/ consumer protection practices… Consumers should have access to their information whenever they need it. Ultimately it should be up to clients if they want to receive periodic statements in the mail; would rather have them emailed; or want neither, but are able to request a statement when it is needed. There are plenty of primative inexpensive software programs available to small businesses. Small servicers should not be exempt from sending periodic statements if the client requests them, but should be allowed to solicit their clients for waivers or alternatives to save money.

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 17:56:59 +0000

As mentioned, Coupon Books should be for borrowers who request them “AND” should be a solution for when other payment options are exhausted or unavailable.

It is important to address the needs of ALL clients with ALL options. Though a coupon book is an old method, “it works” for those individuals.

If a coupon book is provided, quarterly statements could be implemented to compensate for monthly statements…quarterly reports are done by almost every company and is a great time to execute.

To close…I am positive this data (mortgage balance, escrows, payments, etc) is already “electronic” within the company. This electronic option is NOT an option or solution, it is how data is maintained and should/will always be an available method to all… more »

…accounts regardless of secondary options…we all know that it is the fastest and the cheapest.

The rules should not be made to favor one option over another, electronic data must ALWAYS be available to account holders regardless of how they make thier payments. « less

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 17:04:07 +0000

WHEN…is surely tough when crediting an account when payments are inconsistant and completely understand the complexity of the matter when providing up to date information to the client in a timely manner (before the next payment).

As I feel there is NO one answer that conforms to ALL needs…I feel what is important is creating an incentive that encourages MOST people to act, ultimatelty streamlining most of whatever process.

In the past, consumers where offered discounts on the mtg interest (.25%) if you signed up for electronic payments. Though this may/may not be an option now, the idea is to add options, not take away…as they say in the service business, different strokes for different folks. And that should be up to company and/or its affiliates. Surely a tough situation… more »

…for both ends.

HOW…like mentioned by “versability, August 12, 2012 4:54 pm” the OPTION to be paperless is up to the client (mortgagor not the mortgagee).

I would add though, it is to often that computers become UNRELIABLE therefore making paperless accounting very risky. I know that saving trees is extremely important, but buyer beware with anything electronic. In todays age, an area that works along side with an electronic system is identity theft and viruses.

It is just as improtant, should you decide to go paperless, make sure you print a RECEIPT…because the burden of proof is on the consumer, not the organization! « less

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 16:18:08 +0000

In response to Info…it should be the standard practice to all businesses…the better informed your client is (whatever… payments, fees, penalties, etc), the better your relationship or the better chances of you (a business) getting paid.

As described in the FRAUD ACT 2006…

Fraud by failing to disclose information.

A person is in breach of this section if he—
(a)dishonestly fails to disclose to another person information which he is under a legal duty to disclose, and .
(b)intends, by failing to disclose the information— .
(i)to make a gain for himself or another, or .
(ii)to cause loss to another or to expose another to a risk of loss.

Simply said, it is considered FRAUD to not provide “INFO”. If your collecting payments for the next… more »

…30 years (or whatever term), info associated with the account it is surely part of the business obligation.

To close, if at any point, your client (mortgagor) is at risk of NOT making payments, it surely becomes your DUTY to protect the contract by offering solutions…or in this case “Info”. « less

By: loanswithjorge

loanswithjorge — Wed, 26 Sep 2012 15:57:50 +0000

“Periodic Statements”… unless you want to get paid “Peridocially” you should send consumers (your clients) “MONTHLY STATEMENTS”…therefore collecting your payment every time you send a statement. We are talking about MORTGAGES, if not the largest, surely one of the largest investments consumers will make and we see how connected it is to our global economy, as soon as the little guy is NOT making payments, the world practically collapses. It is vital, to not only mortgages, but to any business…you should always maintain a connection with your clients to ensure your relationship is one of good standing that will continue for many years to come.

As to the ITEMIZATION, I find it surprising that NOT all servicers provide this detail of consumers… more »

…accounts. If the servicer does not know about the itemization and current standing of the consumers account, well then they need to apply some sort of system that allows them to maintain these records…asking the consumer to pay for it, is just ridiculous.

This is similar as to asking a local community, to pay for the construction, permits, taxes, infastructure and other costs to open a McDonalds on the corner. Yes, I might like thier burgers, Yes it might be convenient right down the street, but how is it my responsibility to cover the costs of being able to get my business?

When the government required fast foods to contain a nutrition label, I didnt get a call from McDonalds saying, since you eat here, we need to charge you X so that I can continue to accept your business.

The burden of being compliant is always on the one providing the services/products in exchange for profits. « less