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Hi arron banner, and welcome to regulation room. Thank you for your comment reiterating the importance of consumer-servicer continuity of contact. What do you think about the time frames for servicers to establish continuity of contact? Is 5 business days for establishing contact enough time?
Thanks for your comment arron banner! It sounds like you think the sample form needs to include more information and group it differently. The Dodd-Frank Act requires specific information for the ARM disclosure forms, which is explained here: http://archive.regulationroom.org/mortgage-protection/agency-documents/tila-rule-text/#102620. How do those requirements match up with the information you think belongs on this form?
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Absolutely critical to construct this culture and structure of support for accurate and continual exchange of information with THE main affected party: at-risk owner. How can the Owner make intelligent use of time and energy to save the home without it? I would propose that the Owner have access to the full checklist of documents that he/she must satisfy for the completion of the process in question, and see the same documents that the service can see. Hearing someone tell you over the phone that they can’t find a document that you delivered over and over again is about the most frustrating and alienating and helpless shady experience I had while trying to short sale my home. My continual & repeated efforts where futile and inefficient.
Strongly support the concept of advanced notice on the “price shock”. It will not however save the consumer from a questionable prior financial decision (ARM, negative amortization). That is why presenting the critical information upfront, in a standard form single page 10-12point font that emphasizes the reality of the financial agreement they are being presented with, is the real practical force & effect of this rule secrion. E.g. “your mortgage will increase if you only pay x”
The sample form is a working draft I hope. Keep working towards streamline, and developing a matrix/table form that presents the information that the consumer cares about most.
PRIORITY INFORMATION, TABLE #1″how much& how soon & present balance & 1-2 scenarios for principle balance after next successful payment”
PRIORITY INFORMATION, TABLE #2 “rate benchmark, past/present/projected rates & cost differential for the monthly payment based on the current vs. projected rate”
PRIORITY #3: All the background and explanations…
@Moderator.
I must answer your Q with a Q. First, statement of fact: Establishing continuity is a front-end task which I believe is already recognized. If you are going to attempt to put a hard number to the window of time (X number of days) it takes to establish the contact, then I must ask:
Q1: what action/event do you expect should trigger the start of this window? (It seemed like a very messy process in my experience at the front end and there was no clear beginning to the conversation with the lein holder).
Q2: Context? What is the speed at which the owner must take action to save the home? Is it 30 business days? Then 5 business days to establish continuity of contact is a minimum. It is 60-90 days? In that case you might allow for up to 10-13business days.
Overall, without… more »
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