VA Circular 26-15-2 Reconveyance Disputes Process

On March 13, the U.S. Department of Veterans Affairs (VA) issued Circular 26-15-2, subtitled Reconveyance Disputes Process

Veterans Benefits Administration Circular 26-15-2
Department of Veterans Affairs
Washington, DC 20420

Reconveyance Disputes Process

1. Purpose.  The purpose of this Circular is to outline the process for a servicer to dispute a final reconveyance decision. This policy is effective March 13, 2015.

2. Background.  In certain instances, servicers may not agree with the reconveyance decision by the Department of Veterans Affairs (VA). This Circular provides guidance for servicers who wish to dispute a final reconveyance decision. A list of letters associated with the reconveyance process is attached in Exhibit A.

3. Reconveyance Dispute Process.  VA developed a reconveyance dispute process with Vendor Resource Management (VRM) to address servicer disagreements pertaining to the reconveyance of an asset. This process will require the servicer to complete and submit information regarding the dispute to VRM via email. See the requirements below involving the dispute process.

a. Disputes must be received directly from the servicer (not the foreclosure attorney).

b. The dispute should be emailed to the VRM Reconveyance Team at
title-va-reconveyance@vrmco.com.

c. The email submission must include the following:

(1) Email Subject Line: Reconveyance Dispute,
(2) Title Package Due Date,
(3) Copy of Pre-Reconveyance or Incomplete Letter,
(4) Copy of Final Reconveyance Letter,
(5) Proof of compliance in resolving any/all noted deficiencies by the due date in either the Pre-Reconveyance or Incomplete Letter, and
(6) the Reason for Dispute.

d. Reconveyance disputes must be submitted within 10-business days of receipt of the Final Reconveyance Letter.

e. VA through VRM will respond to disputes within 72 hours of receipt.

4. Rescission. This Circular is rescinded January 1, 2018.

By Direction of the Under Secretary for Benefits

Michael J. Frueh
Director, Loan Guaranty Service

Circular 26-15-2
Exhibit A

Description of Reconveyance Letters

Incomplete Title Package Letter – This letter is emailed to both the foreclosure attorney and servicer when a title package is received prior to the due date and is found to be incomplete (i.e. missing state-specific required documents). The letter will note the deficiencies and allow up to the original title package due date for additional documents to be submitted.

Pre-Reconveyance Letter (Expired Title Package) – This letter is emailed to both the foreclosure attorney and servicer when a title package has not been submitted by the due date. The letter will be sent 3 days after the due date has expired and allows for an additional 10-business days to submit the complete title package.

Pre-Reconveyance Letter (Incomplete Title Package) – This letter is emailed to both the foreclosure attorney and servicer when a title package is received on/after the due date and is found to be incomplete (i.e. missing state-specific required documents). The letter will note the deficiencies and allow for an additional 10-business days for submission of required documents.

Pre-Reconveyance Letter (Rejected Title Package) – This letter is emailed to both the foreclosure attorney and servicer when a title package has been rejected by the VA Regional Counsel (VARC). The letter will note the deficiencies and allow for an additional 10-business days for submission of corrective documents.

Final Reconveyance Letter – This letter is emailed to both the foreclosure attorney and servicer after the reconveyance has been approved and processed accordingly. If a quit-claim deed (QCD) is applicable (to vest back to the servicer), then the QCD will be sent along with the Final Reconveyance letter. If a QCD is not required, only the Final Reconveyance letter will be sent.

Please click here to view the online circular.

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.

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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