Loss Mitigation: A Hot Topic Gets Hotter
ABA Bank Compliance Magazine
The 2016 Final Rule amended Regulation X's loss mitigation procedures, imposing additional obligations that may be entirely new to mortgage servicers. For example, in the short-term forbearance and repayment context (where there previously was little guidance and structure), servicers are required to send a written notice confirming the terms of any short-term plan that is offered to a borrower. Servicers also now have specific procedures to follow in the area of loss mitigation if and when 1) all required loss mitigation documentation and information in a borrower's control has been received, but 2) information needed from a third party is missing.
The complete article first appeared in the January/February Issue of the ABA Bank Compliance magazine.