GAO-15-670: Troubled Asset Relief Program: Treasury Could More Consistently Analyze Potential Benefits and Costs of Housing Program Changes

On July 6, the U.S. Government Accountability Office (GAO) released GAO-15-670, a report subtitled Troubled Asset Relief Program: Treasury Could More Consistently Analyze Potential Benefits and Costs of Housing Program Changes.

What GAO Found
 
Between February 2009 and May 2015, the U.S. Department of the Treasury (Treasury) disbursed approximately $16.3 billion of the $37.5 billion in Troubled Asset Relief Program (TARP) funds allocated to support housing programs. The number of new borrowers with permanent modifications added to the Home Affordable Modification Program (HAMP), the key component of these programs, began to decline in late 2013 but has stabilized at between 9,000 and 15,000 additions per month. Activity under HAMP Tier 1, the original modification for qualified borrowers seeking to reduce their mortgage payments to affordable levels (rates periodically reset), has gradually declined. HAMP Tier 2, a broader fixed rate modification announced in 2012, has gradually grown to account for the majority of new entrants. Since October 2014, Treasury has expanded incentives in order to draw new entrants into the programs and further assist existing participants.
 
In making program changes, Treasury took steps to assess their benefits and costs but did not fully meet all of the key elements of federal benefit-cost analysis guidance, and thus has limited assurance that the additional expenditures are an effective and efficient use of taxpayer dollars (see figure below). For example, it is unclear whether the recent changes, such as extending performance incentives to borrowers in the sixth year of their HAMP modification (estimated to cost $4-6 billion), will reduce redefaults. Treasury officials told GAO that borrower surveys confirmed that borrowers responded to performance incentives. But Treasury does not have the estimates needed to fully assess the effectiveness of this or other recent changes. Treasury officials said that program benefits and costs depended on unknown factors and macroeconomic trends and that program benefits were difficult to quantify. Office of Management and Budget guidance and GAO’s past work stress that analyzing benefits and costs can help decision makers choose among alternatives. Without full and comprehensive analyses, Treasury will be challenged to determine whether program changes are actually achieving desired goals and are an efficient use of taxpayer dollars.

Why GAO Did This Study
 
Treasury has allocated $37.5 billion in TARP funds to help struggling homeowners avoid potential foreclosure since 2009. The Emergency Economic Stabilization Act of 2008 includes a provision for GAO to report every 60 days on TARP activities. This 60-day report examines (1) the status of TARP-funded housing programs and (2) the extent to which Treasury’s analytic framework for considering recent program changes was consistent with federal guidance and best practices. To do this work, GAO analyzed borrower participation levels, reviewed program documentation, and interviewed Treasury officials.
 
What GAO Recommends
 
To bring greater rigor and efficiency to decisions about the use of federal funds, GAO recommends that Treasury develop and implement policies and procedures that establish a standard process to better ensure that TARP-funded housing program changes are based on benefit-cost analyses that meet key elements. Treasury agreed to consider applying GAO’s recommendation going forward.
 
For more information, contact Mathew Scire at (202) 512-8678 or sciremj@gao.gov.

Please click here to view the report highlights in their entirety.

Please click here to view the report [pdf] in its entirety.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Freddie Mac: Check Out Our Newly Updated Investor Reporting Web Page

On July 16, Freddie Mac released an update detailing changes made to its Investor Reporting Web Page.

Check Out Our Newly Updated Investor Reporting Web Page

We’ve updated our Freddie Mac Investor Reporting Web page with information, management tools and training that make it easier than ever for you to improve investor reporting accuracy and keep your Freddie Mac portfolio on track. 

We’ve also changed the name of the tab on our Servicing Web page from Investor Accounting to Investor Reporting to reflect our focus on the four R’s, which help you: 

  • Report principal and interest collection activity for each mortgage on a monthly basis.
  • Remit funds due to Freddie Mac.
  • Resolve reporting and remitting discrepancies.
  • Reconcile your Freddie Mac custodial accounts.

What’s New
 
Every two months, we’ll update the Investor Reporting tab with a new information spotlight to help you better manage various aspects of investor reporting. The July/August spotlight is on avoiding common edits such as Edit Codes 600 and 700, with a reminder to answer common questions by accessing our Resolving Loan Level Edits Quick Reference Guide [pdf].
 
Bookmark this Web page and make our Investor Reporting tab your one-stop shop for policy updates, links to training and resources, and easy access to technology tools such as Service Loans applicationServicer Performance Profile, and Remedy ManagerSM.
 
Training
 
Please register for our free webinar training on August 11: Investor Accounting: Resolving Loan-Level Edits.
 
For More Information

  • Visit Freddie Mac’s Learning Center for additional information on our training programs and references tools.
  • Stay connected to Investor Reporting Web page updates and the latest Single-Family news. Sign up for the Single-Family Week in Review and receive a summary of the previous week’s Single-Family news and announcements every Monday morning.
  • Contact your Freddie Mac representative.

Please click here to view the update online.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

FHLMC Guide Bulletin 2015-11 Announces Borrower Solicitation and Effective Date Changes

On July 8, Freddie Mac released an update titled Guide Bulletin 2015-11 Announces Borrower Solicitation and Effective Date Changes.

Guide Bulletin 2015-11 Announces Borrower Solicitation and Effective Date Changes

In today’s Single-Family Seller/Servicer Guide (Guide) Bulletin 2015-11, we’re:

  • Updating Guide Exhibit 93 to incorporate the Freddie Mac MyCity Modification in the borrower evaluation hierarchy for loss mitigation alternatives; and
  • Extending the effective date for changes related to filing reimbursement claims on REO expenses announced in Guide Bulletin 2015-5 [pdf].
     
    Please read Guide Bulletin 2015-11 for full details on these updates.

Resources

For More Information

Please click here to view the online update.

Please click here to view Guide Bulletin 2015-11 [pdf].

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

FHLMC Guide Bulletin 2015-10 Supports TRID Rule

On June 30, Freddie Mac released an update titled Guide Bulletin 2015-10 Supports TRID Rule.

Guide Bulletin 2015-10 Supports TRID Rule

In today’s Single-Family Seller/Servicer Guide (Guide) Bulletin 2015-10, we’re announcing updates to Guide terminology regarding the new disclosure forms required by the Consumer Financial Protection Bureau (CFPB) under its final rule, TILA-RESPA Integrated Mortgage Disclosure (the “TRID Rule”), with respect to settlement-related disclosures.

To help you prepare for when the TRID Rule goes into effect, we’re making the following updates:

  • Settlement/Closing Disclosure Statement. We’re defining this new term in the Guide Glossary in response to the TRID Rule requirements with respect to the settlement-related disclosures. The new term includes, as applicable, both the HUD-1 Settlement Statement and the new Closing Disclosure.
  • Loan Prospector® will be updated by August 1, 2015, to reflect the new terminology.
  • Collection of signatures and additional forms. On and after the TRID Rule effective date, you will not be required to collect borrower signatures for disclosure forms or collect additional forms. This is in line with CFPB’s implementation of the rule. However, consistent with current industry practices, you may wish to consider collecting (or continue to collect) signatures and/or forms.

Future Updates

To further support the changes listed above and once the TRID Rule effective date is confirmed, we’ll announce other requirement updates in future Guide Bulletins and Single-Family communications related to:

  • Uniform Loan Delivery Dataset (ULDD) data point delivery instructions.
  • Requirements for the Truth-in-Lending Disclosure Statement.
  • Uniform Closing Dataset (UCD) delivery requirements.
  • Deletion of references to “signed/executed” from applicable Guide sections.

For More Information

Please click here to view the online update.

Please click here to view Guide Bulletin 2015-10 [pdf].

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

FHA Proposes Deadline for Lenders to File Claims

On July 6, the U.S. Department of Housing and Urban Development (HUD) issued a press release announcing the publishing of a proposed rule that would establish a maximum time period within which a Federal Housing Administration (FHA) approved mortgagee must file a claim for insurance benefits.

FHA PROPOSES DEADLINE FOR LENDERS TO FILE CLAIMS
New guidance establishes a clear timetable for claim payments

WASHINGTON – The Federal Housing Administration (FHA) is proposing to establish a maximum time period for lenders to file insurance claims and to revise its policy on reimbursement of eligible expenses and debenture interest when foreclosure and claim filing deadlines are missed.   Read FHA’s proposed rule.

Since the economic downturn in the housing market, many servicers delayed filing claims for insurance benefits, opting to wait and file large numbers of claims with FHA at the same time.  The costs associated with delayed claim filing and the large number of claims filed simultaneously strain FHA resources.

FHA’s proposal would require lenders to submit claims three months from the point at which they obtain marketable title to the property or successfully sell the property to a third party. This new deadline will ensure FHA can effectively manage and process timely claims.

FHA’s proposal would also eliminate the requirement that lenders/servicers forfeit reimbursement for eligible expenses and debenture interest after missing a foreclosure or claim filing deadline.  Lenders/servicers now will receive this reimbursement, subject to a deduction based on the number of days the foreclosure or claim filing deadline was past due.  This reimbursement calculation will allow lenders/servicers to recover amounts they normally would have lost while mitigating the cost to FHA associated with missed deadlines.

FHA’s proposed rule will be open for public comment for 60 days.

Please click here to view the press release online.

Please click here to view the Federal Housing Administration (FHA): Single Family Mortgage Insurance Maximum Time Period for Filing Insurance Claims, Curtailment of Interest and Disallowance of Operating Expenses Incurred Beyond Certain Established Timeframes (Docket No. FR-5742-P-01) proposed rule [pdf].

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Fannie Mae SVC-2015-10 Servicing Guide Updates

On July 8, Fannie Mae released Servicing Guide Announcement SVC-2015-10, subtitled Servicing Guide Updates.

Servicing Guide Announcement SVC-2015-10

Servicing Guide Updates

The Servicing Guide has been updated to include the following:

  • Updates to Post-Foreclosure Bankruptcy Filing Requirements
  • Updates to Requirements Related to MBS Reclassification
  • Updates to the Application of HAMP Incentives
  • Changes to Form 181
  • Miscellaneous Revisions
  • Reminder of July 7th Servicing Notice

Please click here to view the announcement in its entirety.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Fannie Mae Standard Modification Interest Rate Adjustment

On July 7, Fannie Mae issued Servicing Notice: Fannie Mae Standard Modification Interest Rate Adjustment.

Servicing Notice

Fannie Mae Standard Modification Interest Rate Adjustment

Fannie Mae is adjusting the Fannie Mae Standard Modification Interest Rate required for all Fannie Mae conventional mortgage loan modifications, excluding Fannie Mae HAMP Modifications. The servicer must implement the new interest rate indicated on the Fannie Mae Standard Modification Interest Rate Exhibit for any mortgage loan modification evaluation conducted on or after July 14, 2015.

NOTE: As a reminder, the interest rate used to determine the final modification terms must be the same fixed interest rate that was used when determining eligibility for the Trial Period Plan and calculating the Trial Period Plan payment.

Fannie Mae will continue to adjust the Fannie Mae Standard Modification Interest Rate for new mortgage loan modifications based on market conditions from time-to-time but will no longer issue a Servicing Notice with each Fannie Mae Standard Modification Interest Rate adjustment. Therefore, the servicer must access the Fannie Mae Standard Modification Interest Rate Exhibit on Fannie Mae’s website to ensure that the correct interest rate is utilized when evaluating a mortgage loan for a mortgage loan modification.

Please click here to view the notice online.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Fannie Mae: Servicer Expense Reimbursement Job Aid Updated

On July 15, Fannie Mae announced an update to the Servicer Expense Reimbursement Job Aid.  The job aid provides operational instructions based on servicing policies.

Servicer Expense Reimbursement Job Aid Updated

The Servicer Expense Reimbursement Job Aid has been updated and posted to the business portal. This job aid provides operational instructions based on servicing policies. Servicers are expected to review and comply with the information outlined in the job aid. Also, the servicer must always refer to Fannie Mae Servicing Guide F-1-06, Expense Reimbursement, to determine how to obtain reimbursement from Fannie Mae and to determine what is eligible for reimbursement. Specific updates to the job aid include:

  • New Jersey Vacancy Property Inspections for Expedited Foreclosure Actions: A one-time reimbursement in excess of the allowable property inspection fees will be allowed for a vacancy property inspection in the State of New Jersey provided the inspection was conducted for purposes of the expedited foreclosure process for vacant or abandoned properties and provided certain requirements are met on the expense reimbursement claim.
  • Property Insurance Reimbursement Requirements: Effective Oct. 1, 2015, servicers must provide supporting documentation for all property (hazard) and flood insurance expense reimbursement claims.
  • Non-Recoverable Advances
  • Fannie Mae does not reimburse servicers for recoverable advances that a servicer fails to collect.
  • Servicers submitting requests for reimbursement of non-recoverable advances must include a comment on the claim stating that the expense was determined to be legally non-recoverable.
  • Property Preservation Expenses: Effective Sep. 1, 2015, claims submitted for property preservation expenses, such as property inspections, cleaning, landscaping, and maintenance, should follow the requirements as outlined in the Expense Reimbursement Job Aid. After this date, expenses that are not itemized with a completed date may be rejected.
  • Taxes: Servicers must submit supporting documentation (taxing authority or third party vendor invoice) for all tax reimbursements.

Reminder: All claims submitted more than 30 days after the disposition event date will be denied for late filing.

Please click here to view the Servicer Expense Reimbursment Job Aid [pdf].

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Fannie Mae: Learn About Future Changes to Investor Reporting

On June 26, Fannie Mae released an update announcing the addition of several items to the Future Changes to Investor Reporting website.

Future Changes to Investor Reporting

Fannie Mae is changing investor reporting requirements, which affect all loans and servicers, in addition to eliminating the Single-Family MBS “call-in” requirement. Servicers must implement these policy changes when reporting borrower activity that occurs on and after February 1, 2017. These are welcome steps toward industry-standard best practices that will save servicers time and effort.
 
Fannie Mae is aligning the investor reporting due dates for Scheduled/Scheduled (S/S), Scheduled/Actual (S/A), and Actual/Actual (A/A) remittance type mortgage loans and will require the servicer to report removal transactions (payoffs, repurchases and foreclosures) by the first business day after the servicer processes the transactions in its system. These changes apply to all servicers servicing Fannie Mae loans.

These changes are welcome steps toward industry-standard best practices. Today, Fannie Mae requires that servicers report (e.g., “call-in”) monthly pool balances for Single-Family MBS SWAPs in addition to providing monthly loan activity data reports. Eliminating the Single-Family MBS call-in requirement will simplify policies and procedures and provide many key benefits for servicers.

Please click here for a link to the Future Changes to Investor Reporting website.

About Safeguard 
Safeguard Properties is the mortgage field services industry leader, preserving vacant and foreclosed properties across the U.S., Puerto Rico, Virgin Islands and Guam. Founded in 1990 by Robert Klein and headquartered in Cleveland, Ohio, Safeguard provides the highest quality service to our clients by leveraging innovative technologies and proactively developing industry best practices and quality control procedures. Consistent with Safeguard’s values and mission, we are an active supporter of hundreds of charitable efforts across the country. Annually, Safeguard gives back to communities in partnership with our employees, vendors and clients. We also are dedicated to working with community leaders and officials to eliminate blight and stabilize neighborhoods. Safeguard is dedicated to preserving today and protecting tomorrow.  Website: www.safeguardproperties.com.

Fannie Mae File Transfer Portal Version 4.0 Release Notes Now Available

Investor Update
July 29, 2015

The File Transfer Portal (FTP) application helps to move data quickly between external entities and Fannie Mae applications. This release includes many technical improvements that will make the application more robust and efficient but should be relatively transparent to users. (The details of the technical tickets are not included in this document but can be supplied to anyone interested in them.)

Fannie Mae will implement FTP Release 4.0 over the weekend of August 8, 2015.

Please click here to view the release notes in their entirety.