OCC Bulletin 2014-2: Comptroller’s Handbook Revisions and Rescissions

On February 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2014-2, subtitled Description: Comptroller’s Handbook Revisions and Rescissions.

Description: Comptroller’s Handbook Revisions and Rescissions

Summary

The Office of the Comptroller of the Currency (OCC) issued today the “Mortgage Banking” booklet of the Comptroller’s Handbook. This updated booklet replaces a similarly titled booklet issued in March 1996 (and examination procedures issued in March 1998). The updated “Mortgage Banking” booklet also replaces Section 750, “Mortgage Banking,” issued in November 2008 as part of the former Office of Thrift Supervision’s (OTS) Examination Handbook for the examination of federal savings associations (FSA).

Highlights

The OCC’s “Mortgage Banking” booklet

  • provides updated guidance to examiners and bankers on assessing the quantity of risk associated with mortgage banking and the quality of mortgage banking risk management.
  • includes wholesale changes to the functional areas of production, secondary marketing, servicing, and mortgage servicing rights to incorporate recent lessons learned and regulatory changes.
  • addresses recent amendments to Regulation X and Regulation Z issued by the Consumer Financial Protection Bureau (CFPB), as well as other statutory and regulatory changes, including those directed by the Dodd–Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd–Frank).

Note for Community Banks

The “Mortgage Banking” booklet applies to all banks engaged in mortgage banking activities.
 
Background

The OCC’s revised “Mortgage Banking” booklet is a comprehensive update that combines national bank and FSA guidance and examination procedures. The booklet provides an overview of Dodd–Frank’s mortgage-related provisions. Statutes and regulations governing FSAs also have been incorporated into the booklet.

Recently, the CFPB issued rules imposing new requirements related to mortgage servicing standards, loan origination compensation parameters, the Secure and Fair Enforcement for Mortgage Licensing (SAFE) Act of 2008, and ability-to-repay requirements, including conditions for residential mortgage loans to be considered “qualified mortgages.” The nature, general requirements, and core examination procedures are discussed in the appropriate sections. More comprehensive information regarding Regulation X and Regulation Z issues is available in other Comptroller’s Handbook booklets.

With the issuance of this booklet the OCC rescinds or replaces the following:

  • Replaces the OCC’s “Mortgage Banking” booklet issued in March 1996 (and examination procedures issued in March 1998).
  • Replaces Section 750, “Mortgage Banking,” issued in November 2008 as part of the former OTS Examination Handbook for the examination of FSAs.
  • Rescinds OCC Bulletin 2011-29, “Foreclosure Management: Supervisory Guidance” (June 30, 2011).

For further information, contact Joseph A. Smith IV, Credit and Market Risk Division, at (202) 649-6434.

John C. Lyons Jr.
Senior Deputy Comptroller and Chief National Bank Examiner

Related Link

 

Please click here to view the online bulletin.

 

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: www.safeguardproperties.com.

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CEO

Alan Jaffa

Alan Jaffa is the Chief Executive Officer for Safeguard Properties, 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® Award finalist in 2013.

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Esq., General Counsel and EVP

Linda Erkkila

Linda Erkkila is the General Counsel and Executive Vice President for Safeguard Properties, with oversight of legal, human resources, training, and compliance. Linda’s broad scope of oversight covers regulatory issues that impact Safeguard’s operations, risk mitigation, strategic planning, human resources and training initiatives, compliance, insurance, litigation and claims management, and counsel related to mergers, acquisition and joint ventures.

Linda assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. She has practiced law for 25 years and her experience, both as outside and in-house counsel, covers a wide range of corporate matters, including regulatory disclosure, corporate governance compliance, risk assessment, compensation and benefits, litigation management, and mergers and acquisitions.

Linda earned her JD at Cleveland-Marshall College of Law. She holds a degree in economics from Miami University and an MBA. Linda was previously named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.

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COO

Michael Greenbaum

Michael Greenbaum is the Chief Operating Officer of Safeguard Properties, where he has played a pivotal role since joining the company in July 2010. Initially brought on as Vice President of REO, Mike’s exceptional leadership and strategic vision quickly propelled him to Vice President of Operations in 2013, and ultimately to COO in 2015. Over his 14-year tenure at Safeguard, Mike has been instrumental in driving change and fostering innovation within the Property Preservation sector, consistently delivering excellence and becoming a trusted partner to clients and investors.

A distinguished graduate of the United States Military Academy at West Point, Mike earned a degree in Quantitative Economics. Following his graduation, he served in the U.S. Army’s Ordnance Branch, where he specialized in supply chain management. Before his tenure at Safeguard, Mike honed his expertise by managing global supply chains for 13 years, leveraging his military and civilian experience to lead with precision and efficacy.

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CFO

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard Properties. Joe is responsible for the Control, Quality Assurance, Business Development, Marketing, Accounting, and Information Security departments. At the core of his responsibilities is the drive to ensure that Safeguard’s focus remains rooted in Customer Service = Resolution. Through his executive leadership role, he actively supports SGPNOW.com, an on-demand service geared towards real estate and property management professionals as well as individual home owners in need of inspection and property preservation services. Joe is also an integral force behind Compliance Connections, a branch of Safeguard Properties that allows code enforcement professionals to report violations at properties that can then be addressed by the Safeguard vendor network. Compliance Connections also researches and shares vacant property ordinance information with Safeguard clients.

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.

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Business Development

Carrie Tackett

Business Development Safeguard Properties