Is Your Servicing Shop Ready for SPOC?

In its October edition, MortgageOrb published an article on loss mitigation, titled Is Your Servicing Shop Ready for SPOC?

Is Your Servicing Shop Ready for SPOC?
The CFPB’s single point of contact rule will be both a burden and a benefit for servicers.

Among the Consumer Financial Protection Bureau’s (CFPB) new mortgage rules going into effect this January is the single point of contact (SPOC) rule requiring servicers to have a dedicated agent or team of agents for each borrower who enters early-stage default. This dedicated agent or team is required to work with the borrower to avoid foreclosure by assisting with, if applicable, a loan modification or other alternative, such as a short sale, with an ultimate goal of mitigating loss for both the borrower and loan investor.

SPOC (i.e., the “continuity of contact” rule) is one of several CFPB rules that aim to fix the customer service problems that arose when servicers were blindsided with a flood of foreclosures in the aftermath of the financial crisis. Due to the sheer volume of delinquencies, many servicers became backlogged with requests for modifications, resulting in long delays, lost documents and a deluge of consumer complaints. In some cases, homeowners who otherwise might have qualified for a modification ended up in foreclosure. As a result, the U.S. mega banks were last year subject to the $25 billion National Mortgage Settlement, from which SPOC sprung.

So, how much of a burden has SPOC been on mortgage servicers so far? It depends on whom you ask. Small boutique firms that service, on average, under 5,000 loans at a time are exempt – and the mega banks that were subject to the mortgage settlement are already in compliance, as per their agreement with regulators. (Furthermore, the big banks have the luxury of ample budgets, advanced technology and their own internal compliance departments.)

That leaves the small- to mid-tier servicers, including subservicers, who are arguably the most burdened by SPOC, as they face costly implementation of new technology, processes and training. Many of these servicers have limited budgets, yet they have been cutting checks to technology vendors, training companies and consulting firms to help them get their systems, processes and people in compliance.

“The bigger servicers have had ample time to figure out how they’re going to deal with [SPOC],” explains Brian Moore, financial services industry practice director at contact center technology firm Varolii Corp. “That doesn’t mean it’s easy for them – it just means that they’ve had some experience.”

In fact, that experience is what helped the big banks inform the CFPB’s rulemaking.

“If you look at Regulation X (in the CFPB mortgage rules), the CFPB actually stopped short of requiring SPOC,” Moore adds. “They refer to it as ‘continuity of contact.’ The rule requires dedicated personnel to work with borrowers in loss mitigation – but without saying it has to be the same guy every single time.”

The ‘pod’ approach

Indeed, the CFPB states in its rules that it is up to each servicer to “decide whether to assign a single person or a team of personnel to respond to a delinquent consumer.” What’s more, this person can be “single-purpose or multi-purpose,” or in other words, doesn’t have to be dedicated solely to working on delinquencies. Moore says this softening of the initial rule was the result of industry stakeholders arguing that a single agent cannot realistically be available to borrowers 24/7.

The additional agents, along with the primary point of contact, make up what is called a “pod.” In effect, all agents in a pod qualify as a SPOC under the CFPB’s revised rules.

“Each member of that team is familiar with all the files that the team is handling,” Moore explains. “Usually they have a primary relationship manager who serves as the primary contact for each loan – but any member of the pod can back them up.”

The agents in a pod might be scheduled, for example, using a split-shift approach, where one agent works regular business hours while another works an evening shift. An additional agent might work during the off-hours; however, “the CFPB isn’t crazy enough to say ‘you have to have people available 24/7,’” Moore says.

“At the same time, you do have to let your at-risk borrowers know when the hours of communication are,” he says. “And it must be reasonable; for example, it can’t be from 2 to 3 p.m. only on Mondays.”

While the pod model provides some flexibility, it also presents challenges, including the need for systems that track borrower interactions and transactions among the different agents within a pod. To accomplish this, the borrower’s account, or profile, along with all related documentation, must be shareable among the agents within the pod. This requires integration between a servicer’s loan servicing platform, case management system and contact center system – and it is crucial, as servicers must be prepared to furnish documentation showing what happened throughout the entire lifecycle of a loan, should the CFPB conduct an audit.

A staffing conundrum

Another major concern for servicers is the impact SPOC will have on contact center staffing. Servicers will need to hire additional agents to handle SPOC interactions, as these delicate and complex calls require increased handle time. This, in turn, will have an impact on contact center operating budgets.

And what happens if a SPOC ends up quitting or getting fired – and then the replacement quits two months later, resulting in a customer complaint? Does a servicer risk CFPB enforcement action as a result of high employee turnover? According to Kelli Himebaugh, corporate vice president of technology provider Mortgage Builder Software, this is another one of servicers’ major concerns.

“The burden of proof will be on them to prove what may have occurred on a particular day when a SPOC was unavailable,” Himebaugh says. As a result, servicers are “going to have to start tracking things like time cards and sick hours – and I think that is what is making them nervous.”

Himebaugh says some technology vendors are now offering systems that provide all the agents within a pod a “single point of contact screen.” This enables a borrower’s profile, including recent interactions and related documents, to be readily accessed and shared among the agents in the pod. “This way they all have access to the same info,” she says, adding that most systems track “which agent took which actions” and allow for complete transparency.

To view the article in its entirety, please click here.


About Safeguard 
Safeguard Properties is the largest mortgage field services company in the U.S. Founded in 1990 by Robert Klein and based in Valley View, Ohio, the company inspects and maintains defaulted and foreclosed properties for mortgage servicers, lenders,  and other financial institutions. Safeguard employs approximately 1,700 people, in addition to a network of thousands of contractors nationally. Website:



Alan Jaffa

Alan Jaffa is the chief executive officer for Safeguard, steering the company as the mortgage field services industry leader. He also serves on the board of advisors for SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Alan joined Safeguard in 1995, learning the business from the ground up. He was promoted to chief operating officer in 2002, and was named CEO in May 2010. His hands-on experience has given him unique insights as a leader to innovate, improve and strengthen Safeguard’s processes to assure that the company adheres to the highest standards of quality and customer service.

Under Alan’s leadership, Safeguard has grown significantly with strategies that have included new and expanded services, technology investments that deliver higher quality and greater efficiency to clients, and strategic acquisitions. He takes a team approach to process improvement, involving staff at all levels of the organization to address issues, brainstorm solutions, and identify new and better ways to serve clients.

In 2008, Alan was recognized by Crain’s Cleveland Business in its annual “40-Under-40” profile of young leaders. He also was named a NEO Ernst & Young Entrepreneur of the Year® finalist in 2013.


Chief Operating Officer

Michael Greenbaum

Michael Greenbaum is the chief operating officer for Safeguard. Mike has been instrumental in aligning operations to become more efficient, effective, and compliant with our ever-changing industry requirements. Mike has a proven track record of excellence, partnership and collaboration at Safeguard. Under Mike’s leadership, all operational departments of Safeguard have reviewed, updated and enhanced their business processes to maximize efficiency and improve quality control.

Mike joined Safeguard in July 2010 as vice president of REO and has continued to take on additional duties and responsibilities within the organization, including the role of vice president of operations in 2013 and then COO in 2015.

Mike built his business career in supply-chain management, operations, finance and marketing. He has held senior management and executive positions with Erico, a manufacturing company in Solon, Ohio; Accel, Inc., a packaging company in Lewis Center, Ohio; and McMaster-Carr, an industrial supply company in Aurora, Ohio.

Before entering the business world, Mike served in the U.S. Army, Ordinance Branch, and specialized in supply chain management. He is a distinguished graduate of West Point (U.S. Military Academy), where he majored in quantitative economics.



George Mehok

George Mehok is the chief information officer for Safeguard. He is responsible for all strategic technology decisions, new systems deployments and data center operations supporting a national network of more than 10,000 mobile workers.

George has more than 20 years of leadership experience dedicated to high-growth companies in the mobile telecommunications and financial services industries, spanning startups to global industry leaders.

George played a senior role in the formation of Verizon Wireless, leading the IT product development and strategic planning team. He led the integration planning for the Verizon merger including: GTE, Vodafone-AirTouch, Bell Atlantic Mobile and PrimeCo.

As chief information officer at Revol Wireless, a VC-backed CDMA wireless communications network operator, George’s team implemented an integrated technology infrastructure and award-winning business intelligence platform.

George holds a bachelor’s degree in political science and economics from Eastern Michigan University and an M.B.A. from The Ohio State University. He is a board member of Akron University’s School of Business Center for Information Technology, in addition to an advisory board member for OHTec.

In 2013, George won the Crain’s Cleveland Business CIO of the Year award for his team’s work in completing a major acquisition and technology transformation at Safeguard. In 2015, George’s team was recognized by InformationWeek’s annual Elite 100 ranking of the most innovative U.S.-based users of business technology. The mobile inspection technology developed at Safeguard was selected as InformationWeek’s “One of the top 20 ideas to steal in 2015”.


General Counsel and Executive Vice President

Linda Erkkila, Esq.

Linda Erkkila is the general counsel and executive vice president for Safeguard, with oversight responsibilities for the legal, human resources, training, compliance and audit departments. Linda’s broad scope of oversight covers regulatory issues that impact Safeguard’s operations, pro-active risk mitigation, enterprise strategic planning, human capital and training initiatives, compliance and audit services, litigation and claims management, and counsel related to mergers, acquisition and joint ventures.

Linda’s oversight of the legal department along with multiple compliance and human capital focused departments assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. Her practice spans almost 20 years, and Linda’s experience, both as outside and in-house counsel, covers a wide range of corporate matters, including regulatory disclosure, corporate governance compliance, risk assessment, executive compensation, litigation management, and merger and acquisition activity. Her experience at a former Fortune 500 financial institution during the subprime crisis helped develop Linda’s pro-active approach to change management during periods of heightened regulatory scrutiny.

Linda previously served as vice president and attorney for National City Corporation, as securities and corporate governance counsel for Agilysys Inc., and as an associate at Thompson Hine LLP. She earned her JD at Cleveland-Marshall College of Law. Linda holds a degree in economics from Miami University and an MBA. In 2017, Linda was named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.


Chief Financial Officer

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard. Joe is responsible for the Control, Quality Assurance, Business Development, Accounting & Information Security departments, and is a Managing Director of SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Joe has been in a wide variety of roles in finance, supply chain management, information systems development, and sales and marketing. His career includes senior positions with McMaster-Carr Supply Company, Newell/Rubbermaid, and Procter and Gamble.

Joe has an MBA from The Weatherhead School of Management at Case Western Reserve University, is a Certified Management Accountant (CMA), and holds a bachelor’s degree from The Ohio State University’s Honors Accounting program.


AVP, Operations

Jennifer Jozity

Jennifer Jozity is the assistant vice president of operations, overseeing inspections, REO and property preservation for Safeguard. Jen ensures quality work is performed in the field and internally, to meet and exceed our clients’ expectations. Jen has demonstrated the ability to deliver consistent results in order audit and order management.  She will build upon these strengths in order to deliver this level of excellence in both REO and property preservation operations.

Jen joined Safeguard in 1997 and was promoted to director of inspections operations in 2009 and assistant vice president of inspections operations in 2012.

She graduated from Cleveland State University with a degree in business.


AVP, Finance

Jennifer Anspach

Jennifer Anspach is the assistant vice president of finance for Safeguard. She is responsible for the company’s national workforce of approximately 1,000 employees. She manages recruitment strategies, employee relations, training, personnel policies, retention, payroll and benefits programs. Additionally, Jennifer has oversight of the accounts receivable and loss functions formerly within the accounting department.

Jennifer joined the company in April 2009 as a manager of accounting and finance and a year later was promoted to director. She was named AVP of human capital in 2014. Prior to joining Safeguard, she held several management positions at OfficeMax and InkStop in both operations and finance.

Jennifer is a graduate of Youngstown State University. She was named a Crain’s Cleveland Business Archer Award finalist for HR Executive of the Year in 2017.


AVP, Application Architecture

Rick Moran

Rick Moran is the assistant vice president of application architecture for Safeguard. Rick is responsible for evolving the Safeguard IT systems. He leads the design of Safeguard’s enterprise application architecture. This includes Safeguard’s real-time integration with other systems, vendors and clients; the future upgrade roadmap for systems; and standards designed to meet availability, security, performance and goals.

Rick has been with Safeguard since 2011. During that time, he has led the system upgrades necessary to support Safeguard’s growth. In addition, Rick’s team has designed and implemented several innovative systems.

Prior to joining Safeguard, Rick was director of enterprise architecture at Revol Wireless, a privately held CDMA Wireless provider in Ohio and Indiana, and operated his own consulting firm providing services to the manufacturing, telecommunications, and energy sectors.


AVP, Technology Infrastructure and Cloud Services

Steve Machovina

Steve Machovina is the assistant vice president of technology infrastructure and cloud services for Safeguard. He is responsible for the overall management and design of Safeguard’s hybrid cloud infrastructure. He manages all technology engineering staff who support data centers, telecommunications, network, servers, storage, service monitoring, and disaster recovery.

Steve joined Safeguard in November 2013 as director of information technology operations.

Prior to joining Safeguard, Steve was vice president of information technology at Revol Wireless, a privately held wireless provider in Ohio and Indiana. He also held management positions with Northcoast PCS and Corecomm Communications, and spent nine years as a Coast Guard officer and pilot.

Steve holds a BBA in management information systems from Kent State University in Ohio and an MBA from Wayne State University in Michigan.


AVP, Business Development

Tim Rath

Tim Rath is the AVP of business development for Safeguard. He is responsible for developing innovative growth strategies for Safeguard and developing and overseeing potential partnerships, mergers and acquisitions.

Tim joined Safeguard in 2011 as project director and has filled numerous roles within Vendor Management, most recently serving as director of vendor management, a role he assumed in 2011.

Prior to Safeguard, Tim worked as director of supply chain at PartsSource Inc. in Aurora, Ohio, a provider of medical replacement parts, procurement solutions and healthcare supply chain management technology services. He also has held sales positions with Rexel, ComDoc, and Pier Associates, all based in Ohio.

Tim holds a degree in marketing and sales from The University of Akron in Akron, Ohio. He also earned his FAA Certified Commercial UAS (Drone) Pilot license in 2017.


Assistant Vice president of Application Development

Steve Goberish

Steve Goberish, is the assistant vice president of application development for Safeguard. He is responsible for the maintenance and evolution of Safeguard’s vendor systems ensuring high-availability, security and scalability while advancing the vendor products’ capabilities and enhancing the vendor experience.

Prior to joining Safeguard, Steve was a senior technical architect and development manager at First American Title Insurance, a publicly held title insurance provider based in southern California, in addition to managing and developing applications in multiple sectors from insurance to VOIP.

Steve has a bachelor’s degree from Kent State University in Ohio.