The document outlines a vision and goals for a servicing oversight role to support adherence to uniform national mortgage servicing standards. It discusses analyzing a servicer's capabilities in areas like compliance, policies/procedures, IT controls, staffing, and oversight of third party providers. Today's situation involves ensuring contractual agreements outline obligations and remedies, and receiving monthly reporting packages. Opportunities include monitoring governance, staffing, and quality control processes. The recommended approach includes relationship management, monthly report receipt/review, business intelligence dashboards, loan level loss analysis, and access to servicer systems.
2. Vision Statement
The Servicing Oversight role is an essential
function to support the adherence to the
uniform national mortgage-servicing and
loss mitigation standards that would apply
to all servicers. A comprehensive
Servicing Oversight process protects the
interests of the servicer of record, the
investor, the insurers, the regulators and
the borrowers.
3. Goal and Objectives
Servicing Oversight should analyze and monitor the servicer’s
capabilities in the following focus areas:
Credit Loss, Risk and Fraud Management
Compliance and Regulatory Requirements
Policies, Procedure and Process Controls
Centralization of Corporate Data and IT Data Controls
Organization Structure, Staffing and Training
Management of third party service providers
Quality Control, internal self assessment and external audits
Loss Mitigation Procedures and Workflow Maintenance
Financial Accounting and Cash Control
Investor Reporting
Critical Documentation Management
Business Continuity Plan
4. Today’s Situation
Servicing Oversight plays an important role in insuring the
implementation of clearly defined governing rules for industry
standard prudent Mortgage Servicing, Loss Mitigation and Investor
Reporting
Contractual Agreements should outline applicable Obligations,
Fees, Costs, Benefits, Breach Events, Representations, Warranties
and Remedies
• Servicing and Subservicing
• Custodial/Collateral
• Vendor Management
• Trustees
Monthly Remittance and Investor Reporting Package including
income fees and costs, credit loss, loss mitigation workouts and
delinquency data and Management Dashboard Summary Reports
5. How Do We Get Here?
Servicing Oversight analyzes and monitors the Servicer, Third
Party and Vendor Activities to insure the appropriate controls are
maintained. Some of these include:
• Taxes and Insurance
• Outsourced Servicing Functions
• Payment Processing
• Escrow and Cash Control
• Collections
• Legal Document Custodians
• MERS
• Credit Bureaus
• Legal firms
• Loss Mitigation
• Liquidations
• Flood, Force Placed Hazard and Mortgage Insurers
6. Opportunities
Servicing Oversight monitors Servicing, Collections and Loss
Mitigation Governance
• Industry Comparative Data for Trending default Statistical
Analysis
• Dual Tracking of borrower workouts occurring simultaneously
• Borrower Communication Procedures including solicitations
• Quality Control and Due Diligence Processes
Staffing
• Capacity Modeling
• Workload Management
• File to Representative ratio
• Training Programs
7. Recommended Servicing
Oversight Approach
Relationship Management - Dedicated Servicing Oversight Point of
Contact
Monthly Remittance Package Receipt and Review Schedule
Business Intelligence Dashboard & Management Summary Reports
Loan level Loss Analysis with applicable Remedy and Recourse
Plan
Access to Servicer Workflow Management System (SharePoint;
CRM platforms)
Contingency Plan for Ongoing Regulatory Changes
Reasonable access to Books/Records
Fraud and Risk Management Plan