Processing a Fannie Mae Principal Reduction Modification Job Aid

Investor Update
April 27, 2016

In conjunction with LL-2016-02: Fannie Mae Principal Reduction Modification, a new job aid, Processing a Fannie Mae Principal Reduction Modification, is available to assist servicers with the handling of the HSSN cases for each of the modified loans.

Source: Fannie Mae (full job aid)

MHA HAMP Reporting Update Updated Data Dictionaries Posted

Investor Update
April 28, 2016

In connection with the August 2016 release of the HAMP Reporting System, updated versions of the following Data Dictionaries were posted on HMPadmin.com:


Questions?
Email the HAMP Solution center or call 1-866-939-4469.

Source: MHA

MHA HAMP Reporting Update March 2016 UP Survey Now Available

Investor Update
April 15, 2016

The March 2016 UP survey is now available on HMPadmin.com (login required). Servicers that have executed a Servicer Participation Agreement (SPA) and that have cumulative UP activity must complete and upload their UP survey response to the HAMP® Reporting Tool (login required) by Friday, April 22, 2016.

SPA servicers that have any cumulative UP activity as of March 31, 2016 must submit an UP survey at this time.

For details on downloading and submitting the UP survey response, log in to HMPadmin.com, navigate to the HAMP Loan Reporting Tools & Documents area, and select the UP Survey tab.

Questions?
For more information, email the HAMP Solution Center or call 1-866-939-4469.

For questions specifically regarding the survey contents, email the HAMP Servicer Survey team.

Source: MHA

MHA HAMP Reporting Update HAMP Reporting Tool Post Release Message

Investor Update
March 28, 2016

Today, March 28, 2016, Fannie Mae, as Program Administrator for the Home Affordable Modification Program (HAMP), has implemented the following functionality to the HAMP Reporting Tool that supports:

  • Supplemental Directive 15-06 (SD 15-06) and Supplemental Directive 15-07 (SD 15-07) Making Home Affordable Program-Streamline HAMP Modification Process
  • Streamline HAMP Eligibility
  • Submission of Streamline HAMP Loan Setup Data
  • Streamline HAMP Additional Data Reporting Data
  • Streamline HAMP Official Monthly Reporting
  • Streamline HAMP Interactions With Other Modifications & Programs
  • Streamline HAMP Compensation
  • Streamline HAMP Servicing Transfers
  • Administrative Clarifications: Non-Approval Notices
  • Supplemental Directive 15-08 (SD 15-08) Making Home Affordable Program – Administrative Clarifications
  • HAMP Tier 2 Standard Modification Waterfall – Principal Forbearance Eligibility
  • New Servicing Transfer Reason Code for GSE Non-Performing Loan Sales
  • Interface File Changes

Servicers are encouraged to review updates related to this release from the program-specific sections on HMPadmin.com.

Questions?
For more information, email the HAMP Solution Center or call 1-866-939-4469.

Source: MHA

MHA HAMP Reporting Update August 2016 Release Communications Plan Posted

Investor Update
April 14, 2016

The communications plan for the August 2016 Release has been posted on the open and secure sections of HMPadmin.com. This plan provides a high-level overview of the upcoming release with key milestones identified.

Please review the August 2016 Release Communications Plan for more details. This plan can be found in the Release Notes tab under the Loan Reporting Documents section on HMPadmin.com.

Questions?
Email the HAMP Solution center or call 1-866-939-4469; to reach Black Knight Financial Services (BKFS), select option 1, then option 5.

Source: MHA

GAO-16-278: Nonbank Mortgage Servicers: Existing Regulatory Oversight Could Be Strengthened

Investor Update
April 11, 2016

What GAO Found

The share of home mortgages serviced by nonbanks increased from approximately 6.8 percent in 2012 to approximately 24.2 percent in 2015 (as measured by unpaid principal balance). However, banks continued to service the remainder (about 75.8 percent). Some market participants GAO interviewed said nonbank servicers’ growth increased the capacity for servicing delinquent loans, but they also noted challenges. For example, rapid growth of some nonbank servicers did not always coincide with their use of more advanced operating systems or effective internal controls to handle their larger portfolios—an issue identified by the Consumer Financial Protection Bureau (CFPB) and others.

Note: GAO measured the quantity of mortgages using the total unpaid principal balance of all home mortgage loans outstanding. GAO estimated the amount of mortgages serviced by banks as the sum of the unpaid principal balance of mortgages that banks report holding for investment, sale, or trading plus the unpaid principal balance of mortgages that banks report servicing for others. GAO estimated the amount of mortgages serviced by nonbank servicers as the difference between the total amount of mortgages outstanding and the amount serviced by banks.

Nonbank servicers are generally subject to oversight by federal and state regulators and monitoring by market participants, such as Fannie Mae and Freddie Mac (the enterprises). In particular, CFPB directly oversees nonbank servicers as part of its responsibility to help ensure compliance with federal laws governing mortgage lending and consumer financial protection. However, CFPB does not have a mechanism to develop a comprehensive list of nonbank servicers and, therefore, does not have a full record of entities under its purview. As a result, CFPB may not be able to comprehensively enforce compliance with consumer financial laws. In addition, the Federal Housing Finance Agency (FHFA) is the safety and soundness regulator of the enterprises. As such, it has indirect oversight of third parties that do business with the enterprises, including nonbanks that service loans on the enterprises’ behalf. However, in contrast to bank regulators, FHFA lacks statutory authority to examine these third parties to identify and address deficiencies that could affect the enterprises. GAO has previously determined that a regulatory system should ensure that similar risks and services are subject to consistent regulation and that a regulator should have sufficient authority to carry out its mission. Without such authority, FHFA may lack a supervisory tool to help it more effectively monitor third parties’ operations and the enterprises’ actions to manage any associated risks.

Why GAO Did This Study
 
As of June 2015, about a quarter of the $9.9 trillion in outstanding home mortgages in the United States were serviced by nonbank servicers—non-depository institutions that perform such activities as collecting borrowers’ monthly payments and modifying loan terms. After the 2007-2009 financial crisis, an increase in delinquent loans and other factors led some banks to exit the mortgage servicing business and created opportunities for increased participation by nonbank entities. GAO was asked to study the effects of the growth of nonbank servicers in the mortgage market. This report examines, among other things, recent trends in mortgage servicing and the oversight framework in which nonbank servicers operate. GAO analyzed mortgage industry data from January 2006 through June 2015; reviewed relevant laws and documents from regulatory and housing agencies and an industry group; conducted a literature review; and interviewed consumer groups, regulators and other agency officials, and market participants.
 
What GAO Recommends
 
Congress should consider granting FHFA authority to examine third parties that do business with the enterprises. In addition, CFPB should take steps to collect more data on the identity and number of nonbank servicers. FHFA agreed that there should be parity among financial institution regulators in oversight authority of regulated entities and third parties they do business with. CFPB agreed that more data could supplement existing information but noted that the current data limitation does not materially affect its work.
 
For more information, contact Lawrance L. Evans Jr., at (202) 512-8678 or evansl@gao.gov.

Source: GAO (GAO-16-278 full version)

Additional Resources:

GAO-16-278 Full Report [pdf]

National Mortgage News (FHFA Should Have Oversight of Nonbank Mortgage Servicers: GAO)

HousingWire (Elizabeth Warren Pushing CFPB for More Oversight of Nonbank Mortgage Servicers)

Freddie Mac: How to Avoid Mortgage Fraud

Investor Update
April 4, 2016

Expert offers tips on how to avoid getting conned

It’s spring time and that normally means homeowners are either searching for their perfect home, or are in the process of purchasing it. But according to Freddie Mac’s Financial Fraud Investigation Unit, it’s also a time for home shoppers to fall victim to real estate fraud.
 
In fact, Joan Ferenczy, vice president in the Freddie Mac fraud department, said in a blog post that, because people write checks and sign complex legal documents, it is so important to know how to protect from mortgage fraud.

Here are a 3 suggestions on how to avoid mortgage fraud, for the full story, visit her blog on Freddie Mac.
 
1. Mortgage application
 
First, never sign a mortgage application until you are certain the blanks are filled in correctly. Leaving blanks on a signed document makes it easy for a fraudster to change key information about you (think income and assets) or the amount you are borrowing, the interest rate you agree to pay, or even whether the interest rate is fixed for the life of the loan or will adjust. The best way to protect yourself from a loan you can’t afford is to make sure the loan application is complete and accurate before you sign it.
 
Encourage home shoppers to resist temptation to either exaggerate their income, length of employment or any other information someone says will help their loan approved. It is also important that they be in contact with their loan officer on any life changing events.
 
2. Meeting in person

Next, meet your loan officer in a secure location, like your home or their place of business. Don’t give your mortgage application in, say, a coffee shop or food court where a stranger with a cell phone could take a picture of your bank statement, tax returns, or income statements. This is an important tip for protecting yourself from identify theft.
 
3. False advertisement

Beware of ads promising to erase bad credit records and/or create new credit identities so people can get new credit cards or mortgage loans and start spending again. That’s an appealing pitch to someone eager to buy a home. But rebuilding credit takes time and patience, a good household budget, and paying your bills on time. People who fall prey to credit repair scams lose their upfront fees, don’t improve their credit, and sometimes run afoul of the law.

Source: HousingWire (full article)

Freddie Mac: 3 Red Flags + 4 Tips to Fight Affinity Fraud

Investor Update
April 28, 2016

Can you trust someone simply based on the fact you share a religion, neighborhood or other commonality?
 
Affinity fraudsters want you to think so. 
 
With affinity fraud, a scam artist preys upon members of identifiable groups, such as religious or ethnic communities, the elderly, or professional groups. The fraudsters who promote affinity scams frequently are – or pretend to be – members of the group.
 
In the past few months, the Freddie Mac Financial Fraud Investigation Unit (FFIU) has heard an increase in reports from Seller/Servicers related to suspected affinity fraud. That’s why we want to help you – and your borrowers – understand the psychology and sociology behind this type of fraud.
 
What Should You Know?

  • We tend to trust people like us. We assume they have the same values as we do. Any good salesperson can do this, but a salesperson within your own community increases the chance you’ll go along with it.
  • Affinity fraud cases are usually geographically-centric. We’re inclined to feel comfortable in our own neighborhoods. Sometimes the most egregious offenders are hiding in plain sight.
  • Proving that there’s affinity fraud is harder than with other types of fraud because participants are often less willing to admit to an “outsider” that fraud occurred. They’ll protect others within the group or may be too embarrassed to tell anyone.


Recent Affinity Fraud Examples

 
In one recent instance, a mortgage fraudster was sentenced to 30 to 99 years in prison and ordered to pay $400,000 in restitution for a “faith-based” mortgage assistance scam that was marketed through Christian networks and ministries.
 
Freddie Mac’s FFIU has also investigated reverse occupancy schemes that involve a common ethnicity and an investment scheme in which all the participants worked out at the same gym.
 
Three Red Flags

To help you detect, prevent and report affinity fraud as soon as possible, please look out for:

  • Overuse of gift funds. The amount given by the gift donor doesn’t feel reasonable.
  • Questionable income and employment.  All the borrowers are in similar lines of work.
  • Questionable occupancy. Borrowers qualify for an investment mortgage using rental income to offset a mortgage payment they wouldn’t otherwise qualify for and assets that don’t match their levels of income.  


Four Tips to Avoid Affinity Fraud

 
Follow these four tips for avoiding this scam – and share them with your organization and with your borrowers, too.

  • Do your research. Someone offers you a real estate opportunity. Check out the person’s background, as well as the investment itself, no matter how trustworthy the person who brings the investment opportunity to your attention seems to be. When doing business with someone you know, it’s wise to have an objective person review the transaction/documents before moving forward.
  • Don’t make assumptions. Beware of making any investment based solely on a recommendation from a member of an organization or group to which you belong. Not everyone like you is on the up and up.
  • There’s no free lunch. Be skeptical of any investment opportunity that promises risk-free returns or mortgage/default relief with fees. If it sounds too good to be true, it probably is.
  • Get it in writing. Avoid agreeing to anything you can’t get in writing and situations where you are told to keep the investment opportunity confidential or a secret. 


For More Information

  • Read the Single-Family mortgage fraud mitigation best practices document [pdf] and mortgage screening checklist [pdf].
  • Visit the Freddie Mac fraud prevention web page and share our updated resources with appropriate members within your organization.
  • Refer to Single-Family Seller/Servicer Guide Chapters 3100 and 3200 for our complete requirements on fraud prevention, detection and reporting.
  • Contact us immediately if you suspect fraud related to any loans we’re working on together. Call (800) 4FRAUD8 or email Mortgage Fraud Reporting.

Source: Freddie Mac

FHLMC Guide Bulletin 2016-07: Freddie Mac Principal Reduction Modification

Investor Update
April 14, 2016

In Single-Family Seller/Servicer Guide (Guide) Bulletin 2016-07, we’re announcing the Freddie Mac Principal Reduction Modification. We’ve developed this temporary offering with Fannie Mae and at the direction of the Federal Housing Finance Agency (FHFA).
 
Review Guide Bulletin 2016-07 for the eligibility requirements and modification terms. We are publishing requirements and terms only in the Guide Bulletin (not in the Guide), since this is a temporary offering.
 
Principal Reduction Modification Highlights

  • This modification is aimed at helping assist seriously delinquent, underwater borrowers at risk of foreclosure, mainly in neighborhoods hit hardest by the housing crisis.
  • It leverages the Freddie Mac Streamlined Modification (Streamlined Modification) structure. The evaluation criteria, Trial Period Plan, processing and reporting are the same as the Streamlined Modification. Some key differences include:
  • Evaluation Criteria – the mortgage must
  • Have a UPB less than or equal to $250,000, before capitalizing eligible arrearages.
  • Have a post-modification mark-to-market loan-to-value (MTMLTV) ratio greater than 115%.
  • Not have been for an investment property at origination.
  • Solicitation Letter. Solicit eligible borrowers by sending the Principal Reduction Modification Solicitation Letter provided in Attachment A of Guide Bulletin 2016-07.
  • Submission Through Workout Prospector®. Once the borrower successfully completes the Trial Period Plan and executes the modification agreement, you enter the terms of the modification and data for all required fields using the Workout Prospector Court-Mandated Modification/Litigation exception path.
  • Principal Reduction. This is achieved by calculating the forbearance amount as you would with a streamlined modification; that amount is later forgiven. Eligible borrowers in active Trial Period Plans (as defined in the Guide Bulletin) for Home Affordable Modification Program (HAMP®), Freddie Mac Standard Modification or Streamlined Modification or Freddie Mac MyCity Modification, may also have their forbearance amount forgiven following settlement of the modification.


What Servicers Need to Do

 
Evaluate the starting population provided in the list on our Servicer Performance Profile website of reports using the eligibility criteria provided in Guide Bulletin 2016-07 by October 1, 2016. Servicers may implement prior to October 1, 2016, if they are ready to do so.
 
An initial borrower solicitation must be sent no later than October 15, 2016, and all subsequent solicitation letters must be sent by December 31, 2016.
 
Be ready to discuss alternative workout solutions with borrowers who don’t end up qualifying for the Principal Reduction Modification, including modifications with principal forbearance.
 
Training and Resources
 
Take advantage of training opportunities on our Learning Center. A reference guide and tutorial on the Principal Reduction Modification will be available by April 30, 2016.
 
For More Information

Source: Freddie Mac

FHFA: Statement on Authorized Enterprise Servicers Reliance on Legal Standards in Homeowner Association Foreclosure Proceedings (release date 4/29/2016)

Investor Update
April 29, 2016

[See attached PDF]
 
Attachments: PDF of August 28, 2015 Statement

Contacts:
?Media: Stefanie Johnson (202) 649-3030 / Corinne Russell (202) 649-3032  Consumers: Consumer Communications or (202) 649-3811

Source: FHFA

Additional Resource:
DS News (FHFA Vows to Keep Fighting HOA Super-Priority Liens)

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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