CRFS REAL WORLD CASE STUDY 2021-03

HUD CLAIMS AUDIT SERVICES

• Client:                  Several mid-sized mortgage servicers

• Challenge:           During 2021, several CRFS clients received notice from HUD regarding an upcoming claims audit for FHA loans. Since there is typically a lengthy gap between HUD audits, the process surrounding claim package preparation, audit research, and responding to findings is unfamiliar to many HUD mortgage servicers.  Our clients were concerned with the technical details around identifying, collecting and delivering the necessary documents as well as providing consistent, valid responses to HUD.

• Solution:              CRFS conducted kick-off calls with our clients to discuss the coordination of the claim package preparation and delivery process to HUD. As the HUD audit reviews proceeded, with CRFS’ support our clients were successful in resolving 60% of the preliminary pre-issuance findings before they ever appeared on HUD’s formal Initial Report. Moreover, leveraging our tremendous experience and understanding of HUD guidelines and the HUD Audit process, CRFS was able to contest (pending final resolution) nearly 65% of the findings that ultimately appeared on HUD’s Initial Report.

• Value Add:           CRFS is unique in its ability able to draw on almost 20 years of experience with HUD Audits to optimize the planning and execution phases. The result is consistent levels of success in  partnering with our clients to reduce risk, mitigate findings, and reduce financial losses.  CRFS frequently receives compliments from HUD audit staff on our claim packages for their consistency and organization, which makes their review process more efficient.  We are also able to identify and operationalize finding trends from HUD Audits that give our clients an added level of regulatory and compliance peace-of-mind.

In addition to being the Breakfast Sponsor (most important meal of the day!) for next week’s Five Star Conference and Expo in Dallas, CRFS will also be attending the MBA Annual Convention and Expo 2021 in San Diego from October 17-20.  The team is also looking forward to serving as the Technology Sponsor at the National Property Preservation Conference 2021 being held in Washington DC from November 7-9.

We’re all preparing to safely and responsibly network with our clients and partners at these important industry events.  If you’re also attending, please drop us a line to schedule time to meet and learn what CRFS is doing to help prepare our clients for the return to normal in 2022.

CRFS is pleased to announce the promotion of Audrey Cady from Accounting Manager to Corporate Controller.   Notes CRFS President Steve Mowers, “Audrey’s talent, experience and dedication have been apparent since she joined CRFS in 2020, so we’re delighted to be able to recognize her success with this opportunity.”

As Corporate Controller, Audrey is responsible for overseeing the company’s financial planning and accounting staff as well as developing and maintaining both internal and external financial reporting and metrics. Audrey possesses more than 10 years of progressive, results-driven management experience in all aspects of corporate accounting, financial analysis, and compliance. Prior to joining CRFS, Audrey spent most of her career in the New York City area in senior finance and accounting positions in the media, retail, and real estate industries.

Audrey holds a bachelor’s degree in Accounting from SUNY Geneseo.

CRFS is pleased to announce that it has promoted industry veteran and current Operations Manager Stacy Newell to Director of Operations.  In her new role Stacy has operational responsibility for all clients and claim types including FHA, VA, USDA, MI, GSE and Private Investor, and is a member of the company’s Executive Team.  “We couldn’t be more pleased to have someone of Stacy’s experience and integrity to promote into this critical role, and I have no doubt she’ll do a fantastic job” said CRFS Chief Operating Officer Sean Snook.

Stacy is a leader with extensive experience working with all organizational levels creating, promoting, and delivering operational excellence.  Stacy has been with CRFS since 2009, and throughout her time with the company she has assisted servicers of varying size and complexity manage their aged inventory by creating strategic walk down plans while minimizing overhead costs.  She has worked in the financial services industry for over 12 years and has held several key operational leadership roles over that time including Operations Manager, Client Relations Manager, and Manager of Auditing and Consulting.  The entire CRFS team wishes Stacy much success in her new role.

The Bureau of Consumer Financial Protection (CFPB) today issued its final rule to amend Regulation X to assist mortgage borrowers affected by the COVID-19 emergency. Effective August 31, 2021, the final rule establishes temporarily procedural safeguards to help ensure that borrowers have a meaningful opportunity to be reviewed for loss mitigation before the servicer can make the first notice or filing required for foreclosure on certain mortgages. In addition, the final rule would temporarily permit mortgage servicers to offer certain loan modifications made available to borrowers experiencing a COVID-19-related hardship based on the evaluation of an incomplete application. The Bureau has also finalized certain temporary amendments to the early intervention and reasonable diligence obligations that Regulation X imposes on mortgage servicers.

A summary of the rules follow, and the actual Final Rule can be viewed here…

https://www.consumerfinance.gov/rules-policy/final-rules/protections-for-borrowers-affected-by-covid-19-under-respa/

From August 31, 2021 through December 31, 2021, unless an exception applies, before referring certain 120-day delinquent accounts for foreclosure the servicer must make sure at least one of the temporary procedural safeguards has been met.

Procedural Safeguards. The three procedural safeguards are:

1.  The borrower was evaluated based on a complete loss mitigation application and existing foreclosure protection conditions are met. To meet this safeguard, the servicer must confirm that:

• The borrower submitted a complete loss mitigation application, and the servicer evaluated the application.
• The borrower remained delinquent since submission of the loss mitigation application.
• The foreclosure protection conditions in the existing Mortgage Servicing Rules discussed above, are met, such that a servicer is permitted by the Rules to make a foreclosure referral.

2.  The property is abandoned. To meet this safeguard, applicable state or local law must consider the property securing the mortgage abandoned when referred to foreclosure.

3.  The borrower is unresponsive to servicer outreach. To meet this safeguard, the servicer must not have received any communications from the borrower in the 90 days prior to the foreclosure referral and the servicer must confirm:

• It has complied with the early intervention live contact requirements in the Mortgage Servicing Rules during that 90-day period.
• It has provided the early intervention 45-day written notice required by the Mortgage Servicing Rules. The servicer must have sent the notice at least 10 but no more than 45 days before foreclosure referral
• It has complied with all loss mitigation notice requirements in the Mortgage Servicing Rules during that 90-day period, such as the notice of an incomplete loss mitigation application.
• The borrower’s forbearance program, if applicable, ended at least 30 days before foreclosure referral.

Exceptions. The temporary procedural safeguards are not required if:

• The foreclosure referral occurs (as permitted by applicable law) on or after January 1, 2022.
• The borrower was more than 120 days delinquent prior to March 1, 2020.
• The applicable statute of limitations will expire before January 1, 2022.

If the servicer has met the temporary procedural safeguards, or if the safeguards do not apply, the servicer may proceed with foreclosure referral, to the extent permitted by other law and the existing foreclosure protections in the Mortgage Servicing Rules. If the temporary procedural safeguards apply, a servicer is required to maintain records that evidence the servicer complied.

CRFS REAL WORLD CASE STUDY 2021-02

ACQUIRED PORTFOLIO CLAIM STATUS PROJECT

• Client:           Large non-bank mortgage servicer

• Challenge:   In late 2019 our client acquired a third-party mortgage servicer and encountered sizable challenges identifying the status of the defaulted loans portion of the portfolio and whether they were eligible for claim filing. Our client was concerned that their systems and due diligence process would not capture the full status of the loans and they did not want to miss any claim filing opportunities. The initial consulting project encompassed a claim status review of more than 800 FHA, VA and USDA loan files.

• Solution:       Over the course of 2020 and into 2021, as the client identified applicable loans they were referred as a package to CRFS for review and feedback. Leveraging its knowledge of the applicable agency and insurer regulations and claim systems, CRFS was able to determine individual loan status and claim eligibility. To meet the needs of the project, CRFS dedicated a team of knowledgeable and experienced consultants to complete the reviews. After each review, a package summary with loan level responses and recommended action items to be taken with relevant details was provided to the client.

• Value Add:   CRFS was able to thoroughly and accurately review the loans and advise whether they would be eligible for claim submission to the applicable agency. This allowed the client to update their systems accordingly, thereby reducing the risk of missing a claim filing opportunity. On average, CRFS was able to provide a full summary and set of recommendations on each new loan package in two to three weeks, allowing our client to proceed quickly with all recovery opportunities.   From an ROI perspective, the cost of each loan level review was a fraction of the average claim opportunity.

CRFS is being featured as the Most Valuable Company in the May issue of DS News.  We’re delighted to be this month’s “MVC,” and are grateful to DS News for the opportunity to showcase the important work CRFS is completing for our clients as the industry continues to move closer to a more normal environment.  Now more than ever, CRFS is the valued partner mortgage servicers can rely on to support their default and foreclosure teams.

Check it out here…

CRFS Most Valuable Company Feature

CRFS is live and ready for action as a proud Exhibitor at this year’s MBA Spring Conference and Expo that opened today.  We’re looking forward to sharing with our clients and partners all the exciting news on the innovative products and services we’ll be rolling out over the course of 2021.  A few of these new services include:

• Default Portfolio Review Toolkit
• CRFS Flex Staffing
• Post-claim Quality Control Consulting
• HUD Audit Readiness Consulting
• Enhanced Loss Analysis Toolkit

If you’re attending the show, we look forward to engaging with you at our virtual booth.  If you’re not planning on attending, you can still check out the event page on our website that guests to our booth will be invited to visit.  Please have a look here…

https://www.crfservices.com/mba2021/

After you’ve taken a look don’t hesitate to reach out directly to learn why our expanded capabilities and unmatched expertise make CRFS a valued partner, now more than ever.

If you’re attending, have a great show and please take a moment to visit our virtual booth and say hello…

https://www.mba.org/conferences-and-education/event-mini-sites/spring-conference-and-expo

The CRFS team is pleased to announce that we will be an exhibitor at the upcoming MBA Spring Conference and Expo to be held virtually from April 20-22.  Offered via MBA LIVE, an interactive virtual conference experience, you will hear from an unparalleled lineup of speakers on the Main Stage, dive deep into your specialty area and explore others, chat live with peers across the entire residential real estate finance industry and meet with exhibitors in the virtual HUB.

At the CRFS booth you’ll be able to learn about the innovative products and services we’ll be rolling out over the course of 2021.  A few of these new services include:

• Post-moratorium, Pre-Claim Loan Portfolio Consulting
• Enhanced Loss Analysis Toolkit
• CRFS Flex Staffing
• Post-claim Quality Control Consulting
• HUD Audit Readiness Consulting

You’ll also be able to conduct live chats and schedule one-on-one meetings with CRFS staff and download custom collateral that provides detailed information on all our industry-leading products and services.

To learn more about the show and to register to attend, please  click here  .  We look forward to virtually “seeing you” in a few weeks!

CRFS announced today that it has hired industry veteran Ryan Lasal to take on the newly established role of Director of Innovation.  In that role, Lasal will be responsible for developing, facilitating and implementing new ideas and innovative strategies within CRFS’ business model that will position the company for success in the rapidly changing mortgage servicing default and foreclosure industry segment.  Says CRFS president Steve Mowers, “CRFS has to build on its nearly twenty years of proven success by successfully adapting to and managing for the changes we’re seeing in the business both now and down the road.  And bringing an experienced industry professional like Ryan on board will allow us to do that.”

Lasal has over 10 years of experience in the mortgage servicing industry, including 7 years previously with CRFS where he most recently held the roles of Process Improvement Manager, and Client Relations Manager. Ryan is a 2019 graduate of Roberts Wesleyan College with a Master’s of Strategic Leadership.  A believer that companies should always look to work smarter not harder, Ryan hopes to use this new role to help CRFS and its clients to do just that. As Ryan notes, “Utilizing its 19 years of industry-leading experience and knowledge, CRFS will look to become innovative and agile to continue to add value to our clients and fulfill their needs, both in the claims space and beyond.”

For more information on the new CRFS Office of Innovation, please contact Ryan at Ryan.Lasal@crfservices.com