Profile: amyrozycki
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Hi amyrozycki. Welcome to Regulation Room, and thank you for your comment! It sounds like you have first-hand experience working with borrowers, which is helpful. CFPB’s proposal would require servicers to designate a customer service representative, or team of representatives, who troubled borrowers can contact for assistance. Are you suggesting that CFPB should require servicers to channel all communications to distressed borrowers through the designated contact? Do you think that it would be feasible to expect servicers to make such an accommodation? If the designated contact has access to all communications made to troubled borrowers, would that address your concern about borrowers receiving conflicting or confusing information from multiple departments?
Hi amyrozycki. Thank you for your reply. Are you concerned that providing direct access to underwriters might overwhelm servicers and therefore further delays in resolving mortgage modification requests? Do you have any suggestions for how servicers might accommodate the borrower’s interest in both receiving information directly from departments within a lender and having all communications channeled through a single point of contact?
Thanks for your response, amyrozycki. Would lenders be concerned that, by flagging open items, an underwriter might compromise the independence of the review process, even if inadvertently? How would the underwriter be comfortable, for example, that a borrower isn’t checking a box to get approval when, in fact, the original application was more accurate? As an alternative, would it make sense for housing counselors to review materials for accuracy and completeness (i.e., check the box, if appropriate) before submission?
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?
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A single point of contact needs to be as described; and needs to be cross-trained to provide real and accurate answers. If an answer is not available, the SPOC needs to follow up with the client in a reasonable time to provide an answer to their questions. Often times clients are assigned to a SPOC that is unable to assist them, and does not have accurate updates. Another problem is that often times even though a SPOC exists, other account reps from various departments at the same servicer (or affiliated attorney) continue to contact or send letters to the client which confuses them as to which documents have been received, what needs to be provided, and what the status is. For example, a client was approved for a trial mod but after signing and returning her documents, she received a notice… more »
Thank you for your response… Yes, I think it is feasible to expect servicers to make the accommodation of having a SPOC for ALL outbound and inbound communications with clients and housing counselors, AND that they are able to answer questions (or find the answer and follow up), and have direct contact with underwriters (in order to eliminate rejections based on correctable errors or missing information). It would be ideal if housing counselors were able to have direct communication with underwriters and eliminate the third person in between which would also be more cost effective due to a reduction in communication problems, time, and the amount of re-dos because of inaccurate rejection issues.
I am concerned about underwriters being overwhelmed by calls from clients and understand how difficult it is to constantly be interrupted while trying to review detailed information… however; the reps also interrupt the underwriters to find out information for clients and counselors so it wastes time adding a 3rd person to the mix when the information at hand is critical to the decision making process. I don’t think the average turn around time for evaluation decisions is accurate. Because of the barrier in communication, many clients are being denied due to forgetting to fill something in or check a box when the underwriter could simply call and say, “can you check the box and fax it back in to me, or can you explain… or send me xyz document?” so they are able… more »
Thank you.
RE:
Moderator
September 21, 2012 12:53 pm
“Hi amyrozycki. Thank you for your reply. Are you concerned that providing direct access to underwriters might overwhelm servicers and therefore further delays in resolving mortgage modification requests? Do you have any suggestions for how servicers might accommodate the borrower’s interest in both receiving information directly from departments within a lender and having all communications channeled through a single point of contact?”
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Moderator: Thank you for your response… I understand the lender/servicer’s fears that the integrity or independence of a review may be compromised by the coaching of clients by their underwriters; however, that is not what I was implying, and I doubt it would be an issue as the underwriters are working for the servicers, not the clients; so underwriters would have no incentive to coach clients. What I was implying was for underwriters to follow up and ask questions or confirm obvious small mistakes that are made before simply denying a modification. Yes, in a perfect world housing counselors would catch all errors, but aside from the fact that we are also human and miss things from time to time ourselves, and that every servicer has slightly different requirements; often times clients… more »
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.