OCC Releases Guide Other Real Estate Owned

On September 13, the Office of the Comptroller of the Currency (OCC) released Bulletin OCC 2013-20, announcing it had issued the “Other Real Estate Owned” booklet of the Comptroller’s Handbook.

Description: Comptroller’s Handbook Revisions and Rescissions

The Office of the Comptroller of the Currency (OCC) issued today the “Other Real Estate Owned” booklet of the Comptroller’s Handbook. This updated booklet replaces a similarly titled booklet issued in March 1990 (and examination procedures issued in April 1998). The updated booklet also replaces section 251, “Real Estate Owned and Repossessed Assets,” issued in December 2010 as part of the Office of Thrift Supervision (OTS) Examination Handbook for the examination of federal savings associations.

The OCC’s “Other Real Estate Owned” booklet provides updated guidance to examiners and bankers on the acquisition, reporting, management, and disposition of OREO. Major revisions address interagency appraisal and evaluation guidance; managing and renting foreclosed residential properties; third-party service providers; borrower redemption periods after foreclosure; and the exchange of participation interests in OREO.

The booklet discusses similarities and differences in the statutes and regulations unique to national banks and federal savings associations (FSA). Although policies governing OREO for national banks and FSAs are similar in many respects, some differences remain and are addressed in the booklet. In addition, areas governed by policy but not statute or regulation have been made uniform for national banks and FSAs in this booklet. For example, whereas section 251 described OREO hold or sell considerations that an FSA should address, the updated booklet directs FSAs to the general statutory and regulatory standard for national banks for OREO disposition. In another example, FSAs had been expected to use property acquired for future expansion within three years of acquisition or transfer the property to OREO, whereas national banks are expected to use such property within five years; FSAs now are allowed the five-year time frame.

With the issuance of this booklet, the following documents are rescinded:

  • TS Examination Handbook, section 251, “Real Estate Owned and Repossessed Assets” (December 2010)
  • OCC Bulletin 2011-49, “Foreclosed Properties: Guidance on Potential Issues With Foreclosed Residential Properties” (December 14, 2011)
  • OCC Bulletin 2011-10, “Other Real Estate Owned: Exchanging Other Real Estate Owned for Other Assets” (March 24, 2011)

For further information, contact Grant Wilson, Director for Commercial Credit Risk, Credit and Market Risk Division, at (202) 649-6432.

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

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To view the bulletin online, 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: 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