LENDERS COMPLIANCE GROUP® is the country's first full-service mortgage risk management firms in the United States, devoted to offering a full suite of services in residential mortgage banking, respectively, to banks and nonbanks, independent mortgage professionals, and mortgage servicers. We also provide state-of-the-art mortgage quality control auditing and loan analytics.
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Wednesday, October 12, 2011
Plethora of Languid Foreclosure Prevention Programs
Thursday, September 23, 2010
Fannie: Introduces Second Lien Modifications
On August 13, 2009, the US Department of Treasury (Treasury) published Supplemental Directive 09-05, introducing the Second Lien Modification Program designed to work in tandem with the Home Affordable Modification Program (HAMP). The Supplemental Directive 09-05 was revised on March 26, 2010.
HAMP and the Second Lien Modification Program (which is named "2MP") are meant to create a "comprehensive solution to help borrowers achieve greater affordability by lowering payments on both first-lien and second-lien mortgage loans."
On September 21, 2010, Fannie issued Announcement SVC-2010-14, which introduces its Second Lien Modification Program and provides guidelines to Fannie servicers.
All Fannie Mae-approved servicers must participate in the program for all eligible Fannie Mae second-lien mortgage loans and must implement the 2MP program no later than January 1, 2011.
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Highlights
Modification Eligibility
- Borrowers in Bankruptcy
- Coordination with Other Making Home Affordable Programs
Modification Process
- Matching Second Liens to HAMP First Liens
- Reliance on First-Lien Data
- Standard Modification Steps
- Compliance with Applicable Laws
- Borrower Communication
- Trial Period Requirements
- Borrower Response
- Effective Date of 2MP Modification
- Reclassification or Removal of MBS Mortgage Loans Prior to Effective Date of Modification
- Borrower Notice
- 2MP Modification Documents
- Assignment to MERS
Use of Suspense Accounts and Application of Payments
- Monthly Statements
Reporting Requirements
- Reporting to Fannie Mae Through HSSN
- Reporting to Treasury
- Reporting to Credit Bureaus
Mortgage Insurers
- Mortgage Insurer Approval
- Reporting to Mortgage Insurers
Fees and Costs
- Servicing Fees
- Late Fees
- Administrative Costs
Incentive Compensation
- Servicer Incentive Compensation
- Borrower Incentive Compensation
- Re-default and Loss of Good Standing
Compliance
Record Retention
Transfers of Servicing
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Visit Library for Issuance
Fannie: Home Affordable Modification Program:
Introduction of Second Lien Modification Program
SVC-2010-14
September 21, 2010
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LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the country, specializing exclusively in mortgage compliance and offering a full suite of hands-on and automated services in residential mortgage banking.
Friday, July 23, 2010
HAMP: “Continues to Struggle”
Yesterday, we provided an outline of the continuing downward trend of the Home Affordable Modification Program (HAMP) program, as reported in the most recent June Report, issued on July 20, 2010.
On July 21, 2010, the Special Inspector General for the Troubled Asset Relief Program (SIGTARP), stated in its Quarterly Report to Congress (Report), that HAMP "continues to struggle to achieve its original stated objective to help millions of homeowners avoid foreclosure 'by reducing monthly payments to sustainable levels.'"
The Report states that the number of homeowners being helped through permanent modifications "remains anemic," with fewer than 400,000 ongoing permanent modifications and HAMP has not put an "appreciable dent" in foreclosure filings. Furthermore, according to the Report and as we also indicated in yesterday's compliance update, the number of trial and permanent modifications that have been canceled substantially "exceeds the number of homeowners helped through permanent modifications."
In a telling statement of fact, the Report unequivocally finds that the Treasury "clings to its prior statements that it plans to offer trial modifications to three to four million homeowners, a measure that the SIGTARP has previously shown to be essentially meaningless," and that its refusal to provide meaningful goals is a "fundamental failure of transparency and accountability."
Finally, the SIGTARP takes the position that the "American people are essentially being asked to shoulder an additional $50 billion of national debt without being told, more than 16 months after the program's announcement, how many people Treasury hopes to actually help stay in their homes as a result of these expenditures, how many people are intended to be helped through other subprograms, and how the program is performing against those expectations and goals."
Without clearly defined standards, opines the SIGTARP, positive comments about HAMP's success are "simply not credible," and leads to a growing "public suspicion" that HAMP is an "outright failure."
It should be noted that of the anticipated $75 billion dollar cost of the Making Home Affordable (MHA) program that commenced on February 18, 2009, $50 billion will be funded through TARP. HAMP is one of the MHA programs.
If you have any questions about this matter or would like assistance with mortgage compliance, please contact Jonathan Foxx, Managing Director or call 516-442-3456 x 100.
Highlights
As of June 30, 2010, a total of 753,275 mortgages are currently being modified, either permanently or on a trial basis. Of those, 389,198 were active permanent modifications and 364,077 were active trial modifications.
SIGTARP uses statements from the June reviews provided by HUD and Treasury to explain why the number of cancellations of mortgage modifications has increased, as decisions on aged trials are being reached, such as:
Office of the Special Inspector General
of the Troubled Asset Relief Program
Quarterly Report to Congress
July 21, 2010