This is transparency's Profile page. Use it to view transparency's comments, other users' replies
to these comments, and comments transparency has endorsed.
By eliminating partial payments or storing partial payments off to the side is creating another problem for borrowers when partial payments can be part of the solution and maybe even the determining factor in bringing the borrowers loan current by allowing additional time. If a checking account can have over “draft protection”. Then why can a property insurance policy not have the same system? “Bank auto draft protection” on the insurance policy. If the insurance company does not receive the monthly payment within a 5 day grace period after the due date bank auto pay kicks in, preventing a lapse in coverage and preventing the need for other policies that are largely based on fraud, racketeering and inflated fees that prevent borrower recovery. The bank can charge… more »
The “Periodic Statement” that you have placed up for review could solve almost every issue brought up here if “Transaction Activity” had to be inclusive of any and all account activity, directly or indirectly, addressing companies by name instead of general categories. The cure is literally that simple. The Transaction Activity” category is currently set up for generalities that enable bank fraud and deception, which is the problem. *******Tell me what issues listed in this column, could not easily be solved, in this one category, on your “Periodic Statement”? Look at the problems needing addressing here with this question: “no obligation to homeowner”, “”run around”, “accountability”, “weak rules”,… more »
Moderator, why is the CFPB concerned about giving the public too much information when almost all of the complaints are about not enough or wrong information? Not one person is complaining because they have “too much information”. The public is pulling their hair out because of lack of information, run around and lies. If all activity in a borrowers loan account is disclosed to the homeowner monthly, their would be no “unduly burdensome” phone calls to the servicer. Why is the CFPB complicating things further by separating what information only an attorney can get as opposed to what a borrower can get. A lot of borrowers represent themselves, then what? Why should only an irrelevant third party at a price have transparent information on your loan? What information… more »
Why don’t we use a simple, divided insurance formula, that solves all the force placed insurance problems. The home owner picks the best insurance policy prior to the closing when purchasing a home. The policy is divided by responsibility. The bank adds the portion for the structure to the monthly house payment, that includes wind if required and flood if in flood zone and any inside flooding. The home owner is responsible for personal injury, appliances and personal effects and has to send in the money directly. If the home owner quits making the payment it is irrelevant to the bank that is responsible for sending in the insurance on the structure if they want it protected their investment until foreclosure. It is considered part of the house payment and the bank is returned to arms… more »
The 4 letter original lender code followed by a dash then loan number needs to be on the closing documents. It is important that this combo can not be altered for the life of the loan. If I punch in on line for example BOFA-123756327 then I should be able to pull up a chain of title linked to property records, leins, taxes etc. We have had the technology for so long. The worst problem is that people can’t defend themselves in court with out a chain of title and banks are adding additional force placed insurance policies by altering the loan number on the policies so they are hard to trace. Make it simple, we have the technology. This way the banks will have to clean up their behavior because they will not have a choice.
A standard monthly statements for banks should be set up to allow bank investigators to go into the bank and run a report and identify most problems if the software is set up for maximum use. This asking the banks to tell us what they are doing wrong so they can be punished is not working. Letting the banks pick a friend to investigate them is also a bad option and is slowing our progress. This is causing the entire country to loose hope and faith. It is up to bank investigators to do the investigating and it needs to be easy and efficient using today’s technology if we are going to make any progress from this melt down. Please put all the problems on a flow chart and all the solutions on the chart. Get who ever wrote the software for ancestry.com or Ebay or US Customs that is amazing… more »
Their is only one simple solution to knowing all your options fast and at one easy to use location available to everybody. Using available computer technology to have someone write a program where you click on your state and answer a series of questions and all government programs are in the program along with all bank programs. You hit “enter” and it tells you all your options with phone numbers and links to on line forms to fill out to enter the program all in minutes. There should even be a make an offer section where the bank can offer the home owner money to walk away because it’s cost effective or where the home owner can ask to be entered into a short sale program or offer a Deed in Lieu agreement if they can remain in the home for 6 months for free for example. Or… more »
Where the note and mortgage are missing the bank should not be allowed to report to the Credit Bureau. The credit reporting agency should not be based on the hear say of a bankster. This is unethical and unfair. This would leave a lot of people with good credit where they can buy a new home again because of bank fraud and irresponsibility. Why is it a bank that admits they have no proof you owe them anything, with a lost note and mortgage, can leave a life wrecking statement that says you do owe them? And there is no place for the homeowner to report on the banks fraud, racketeering, pay to play, empty insurance shells set up for billing etc… so the bank can not loan money any more. In a fair society, this would be working both ways, the same. This has to change! Instead of 10 questions… more »
Moderator, the answer is both and they should be one in the same.:-) It is easier to trace a relative that dies a 100 years ago on ancestry.com then it is to trace a $500,00 current note and mortgage. (lack of linked cutting edge computer software is the difference). It is even easie to trace a $1.00 used item sold on Ebay after the sale then a current note and mortgage. I felt like pulling my hair out trying to put together a chain of title with my note and mortgage. If an investigator went into US customs they could pull up, on the computer, any container arriving in the USA, where it came from, where it went and what was in it. Because US customes has current standard technology and an amazing detailed code system that could be adapted for banking. If you want to see the extent of their… more »
Moderator I can show you documents where the account number has been changed on things like over lapping force placed insurance policies for example. When loans change hands to generate expenses you see this. I am saying your “periodic statement” should have the same originating lender code followed by the account number that was assigned at closing on every statement. The lender code is important, in case the loan transfers to a bank that already has the same number. There should be a government place to “report an error” if your account number has been altered or changed. As you seem genuinely interested in this project I would like to send you my case and you will see that there are so many issues that need fixing relating to the big picture. Why fix a few things… more »
Moderator, Steve Smith made a great point that is related to insurance and is another example of the narrow scope of the questions, that you have to work with. Your success level with this program will be based on embracing the issues that are relevant and important that are being ignored, like the point Steve made. Ultimately, the consumer pays for PMI. If PMI is required, then the home owner should be able to shop for the best rate. If PMI is mandatory then it should be listed and broken down on the statement that we are discussing. Banks need to be removed from insurance where it appears they commit massive fraud so banks will return to focusing on loaning money. The home owner should shop for the PMI best rate to protect their loan because ultimately they are paying for it. The homeowner… more »
Moderator, maybe the government could buy one less military plane and fund this program. The American people are not afraid that Iran or Russia are going to bomb their homes. The American people are afraid of the banks that are already here, that collapsed the economy and are taking advantage of them now, by inflating the fees and then stealing their homes with fake document by hiring a slimy attorney. They are living with fear and anxiety because their chain of title has been destroyed with MERS and the banks are killing their homes values and stable neighborhoods are turning into rental neighborhoods with run down homes deserted with expensive insurance on them to fix them up but it is not being used, just billed. This system would be a lot cheaper than a plane and would save a lot more… more »
To maintain clear information that will prevent people from being “overwhelmed” with fraud would require the bank to give the home owner a choice of servicers at closing. Just like when you buy a computer you pick your service provider. For a servicer to change 4 times in a year, to create multiple annual forceplaced insurance policies, is abuse! Your servicing should not be traded like a stock because, well it’s stupid, leads to fraud and leads to people being “overwhelmed” for no reason. When you buy a car you decide who is going to send you your monthly bill. The banks have proven they are way too irresponsible to make this decision for homeowners. So I ask, why after 4 years, are banks still allowed to do this?
It is important that if a house has gone into foreclosure that the payoff information remains the responsibility of the lender not the attorney taking care of the foreclosure. This is very important because I got a payoff from both the servicer and the attorney to see what would happen, in Florida. There was close to a $10,000.00 difference in payoff statements. The attorney overstated the payoff in almost every category that he gave to the closing agent. I have proof. The servicer still needs to provide service and be held accountable for the accuracy. The FBI has determined that Florida is one of the worst states for mortgage fraud and with over 90,000 attorneys in Florida the Florida bar revokes very close to “0″ licenses. So, leaving an attorney responsible for payoffs is a risk that is not necessary to take and I don’t think it should be allowed.
The Periodic Statement is great and you can see that a lot of thought went into this process. However , there is 1 very big problem that will have devastating consequences if not fixed. Under “Transaction Activity” there needs to be three categories. 1) “Charges” 2) “Payments received” 3) “Payments paid out”. This statement still allows banks to generate bogus bills under generic categories like “property inspection fee”. (HUGE PROBLEM) General entries like this allow banks to bill homeowners, without even telling the homeowner who they are obligated to pay, knowing the homeowner has no way to verify the bill and even worse senerio was any service ever provided or just a bill. Any time the bank charges your account for something,… more »
Warning a borrower about force placed insurance is irrelevant to addressing the problem, symptom or solution. After reading your link to 2024.37 force placed insurance (c)2viii I realized that the only solution that is being offered for all the force placed insurance issues is that the banks have to tell the borrower that they are about to place a force placed hazard insurance policy on them that “cost significantly more”. In other words, if you can’t make your property insurance payment, our solution is to increase the price of the insurance. Why am I the only person that sees this as totally stupid? Providing a borrower a written statement that you are going to take advantage of them is not the solution but part of the problem. Trust me, after watching 4 years of abuse,… more »
Why are you leaving it up to the servicer to determine if the information being requested is “unreasonable”? The CFPB is not listening to the “ordinary” people because this is the problem now, not the solution. The banks are probably being asked the same 20 or 30 questions over and over about loans. Please ask Versability for a list of the questions, in relation to a loan, that people ask that are currently not covered on the sample monthly statement that could easlily fit on the statement. Varsability that is emailing you, is trying everything to address transparency issues and has the answers you are looking for. Why don’t we separate reasonable questions from unreasonable questions. Ask Versability, how many of the questions could be answered on the monthly… more »
Here is another force placed insurance problem that is not being addressed with the current force placed insurance solution. The current solution, which is a “warning” to the borrower that will some how prevent force placed insurance. Because the homeowner can not make their property insurance payment, because of lack of funds, the bank is going to highly inflate the insurance, is some how the current solution. (This makes the problem worse and is not a solution but another problem.) I have linked the following problem because I’m surprised this problem is not all over the web. I would guess this ladies problem was probably created because the banks collapsed the market after running the market up with artificial demand leaving her upside down.
This lady’s house… more »
http://www.ask.com/answers/214056661/here-is-my-problem-i-have-policy-for-59-000-on-my-home-insurance-will-not-insure-for-any-more-than-that?qsrc=14106#jaques_frm « less
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
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.
Hi Transparency. The CFPB’s proposed rule contains requirements for the “Content and layout of the periodic statement,” and require the statement to provide several pieces of information including: the amount due, an explanation of the amount due, a breakdown of past payments, transaction activity since the last statement, and the bank’s contact information (the full list can be seen in the proposed rule.) It sounds like you are suggesting that the statement require billing and contact information for third party service providers, and that the layout should be similar to credit card statements. Do you believe that adding a “who” and “when” to the CFPB’s sample statement would address most of your concerns? What do other users think… more »
Hi transparency. Thank you for your comment!
The CFPB wants periodic reports provided by creditors, assignees, or servicers to balance the need to provide useful information against the risk of overloading consumers with too much information. If a consumer wants additional information about their mortgage loan, the CFPB would require servicers to respond to consumers’ written and oral requests within a specified amount of time. Because expanding the way consumers can ask for information encourages use of the new disclosure system by attorneys, rather than ordinary people, the CFPB would allow servicers not to respond to certain types of information requests. Do you think the CFPB has struck the appropriate balance? Do you have an example of the kind of indirect transaction activity that… more »
You also mentioned that advanced software and technology is available to servicers that would simplify the disclosure process. What do you think of the proposed exception servicers would have that would allow them not to respond to “unduly burdensome” information requests? « less
Hi transparency. CFPB is proposing a standard Periodic Statement to be given to borrowers. Are you suggesting a standard monthly statement or software that bank regulators could use when investigating banks?
If a nationwide database, like what you propose, can’t be put into place, what kind of information or access do you think will be missing from the CFPB proposals? CFPB’s proposals include requiring that borrowers receive periodic statements about the status of their mortgage accounts, ensuring they have the right to tell their servicer, and get a prompt response, when they make an information request or report an error, and requiring servicers to provide borrowers in trouble… more »
transparency, we hope you will continue to comment and give feedback on CFPB’s proposals. It sounds like you’re concerned that CFPB’s proposal doesn’t do enough to ensure continuity of record keeping among the various banks and servicers a borrower might have to deal with over the life of their loan. While a national database is not proposed in this rule, CFPB envisions that standard periodic statements will keep information consistent across banks and give borrowers the information they need.
If you go to the issue posts about periodic statements, requesting… more »
Because we are neutral, we can’t take a stance on the rule or other banking issues. The way we hope to make change is by providing a space for commenters like you to participate effectively in the rulemaking process and have your voice heard. For more about how Regulation Room works, please visit this page. « less
Hi transparency. If I understand you correctly, you are making two proposals. First, on insurance, you think an insurance company should be selected at closing to provide hazard insurance. The insurer cannot adjust the rate it charges more than once every 12 months, and must provide 60 days’ notice before changing its rate, giving the borrower time to find a lower-cost insurer. If the homeowner fails to make the required insurance payments, the bank should become responsible for them and simply foreclose on the homeowner without charging the borrower for insurance. Second, servicing cannot be transferred once foreclosure proceedings begin. Is that a correct summary?
Hi transparency, and thanks for your participation. If I understand you correctly, servicers and banks would need to provide information to the website you’re describing, so that consumers could access it. Who would bear the cost of maintaining the website?
Hi transparency, We are sorry if you feel you are not being heard or that our questions are too narrow. We should explain that the Regulation Room moderators are neutral, we don’t take a position on the proposed rules. Our job is to help every person contribute their viewpoints in way that will be useful to the agency when they finalize the proposed rules. During the discussion, we may point users to additional information about the rules, pose questions designed to prompt fuller or more detailed discussion, and facilitate discussion between users with different views. Our questions may appear narrow, because we only focus on issues the agency is addressing in these rulemakings. You can learn more about effective commenting and our project.
Hi Transparency. CFPB has not proposed a “new disclosure system” for attorneys that would give attorneys privileged access to mortgage information. Instead, it wants to make information more accessible to borrowers and feels that servicers will be able to devote more resources to providing borrowers with specific information about their mortgage accounts if servicers are not overwhelmed by the types of burdensome information requests that are more likely to come from attorneys and are better suited for the discovery phase of litigation.
Please also remember that 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 better final decisions. Moderators are here to facilitate discussion on CFPB’s proposed rules and do not take sides on the issues.