On February 16th the Biden administration announced an extension of the COVID-19 forbearance and foreclosure protections for homeowners.  Read full details here… https://www.whitehouse.gov/briefing-room/statements-releases/2021/02/16/fact-sheet-biden-administration-announces-extension-of-covid-19-forbearance-and-foreclosure-protections-for-homeowners/

Notwithstanding this extension, the mortgage industry and the country continue to creep closer to a return to normalcy.  Now is the time to prepare your default and foreclosure shop for the coming uptick in claim volumes across all claim types.  Our experienced staff is well versed in all the government, GSE, and MI programs including Loss Mitigation, CWCOT, and conveyance.  Contact the experts at CRFS to learn how we can assist in prepping and QC-ing loan files for submission, supporting your team with increasing volumes, and delivering comprehensive Loss Analysis reporting.  E-mail us at sales@crfservices.com or call us at 585.589.8946.

CRFS Real World Case Study 2021-01

COVID-19 FNMA Deferment Claim Project

• Client:           Large non-bank mortgage servicer

• Challenge:   In May, 2020 Fannie Mae under the direction of the Federal Housing Finance Agency (FHFA) in partnership with Freddie Mac issued a new Lender Letter (LL-2020-07) that provided servicers with additional retention workout options for borrowers who were impacted by a hardship related to COVID-19. The goal of the program was to allow borrowers to return their mortgage to a current status after up to 12 months of missed payments. Our client was concerned it did not have enough fully trained staff to manage the large influx of claims that would need to be filed over several months as eligible borrowers entered the program. The project encompassed more than 1,000 monthly Fannie Mae COVID-19 claim submissions.

• Solution:       Within four weeks of commencing the project, CRFS was able to allocate staff for and deliver required training to the team tasked with managing the program. By the time the first referral file was delivered, CRFS had built-out its workforce such that it could handle up to 1,000 FNMA Deferment claims, more than tripling its claims processing capacity. At present, CRFS has further expanded its processing and QC operations to handle more than 1,500 monthly claims.

• Value Add:   CRFS was able to quickly allocate resources experienced with conventional claims to accommodate the client’s increasing claim volumes under a newly implemented GSE workout program, delivering an effective solution while also managing operational risk. Additionally, the staffing and operational solution put in place by CRFS controlled costs while maximizing the financial opportunity for our client.

Claims Recovery Financial Services, LLC (CRFS), the mortgage industry’s premier provider of claim filing and recovery services, was awarded the Orleans County (NY) Chamber of Commerce “Employer of the Year” for 2020 at a ceremony held today.

CRFS, which started out with one employee processing a few claims for one client, today employs almost 200 dedicated professionals and handles thousands of claims each month for over two dozen clients.

“The way that CRFS handled things this year…” was cited by the Orleans Chamber as a key factor in presenting the company with this honor. There are several things CRFS did during 2020 to not only preserve jobs and support clients in the face of the challenges and uncertainty brought on by the COVID-19 pandemic, but also invest in the company’s future growth. These include:

• Conversion to 100% remote workplace with deployment of workstations at the employee level and establishment of sophisticated IT infrastructure to support a remote desktop environment
• Development and rollout of new compensation plans and enhanced production reporting to more effectively measure and incent remote staff
• Strategic use of Federal PPP funds to help maintain employment levels during the initial Pandemic shutdown phase
• Implementation of a flex staffing model supported by NY State’s innovative WorkShare program that greatly reduced the need for a major corporate restructuring and helped preserve the level of active employees
• Renegotiation of leases at multiple office facilities to address the transformative requirements of the remote staffing model, featuring significant reductions in traditional office space and workstations and expansion of collaboration areas and employee engagement best practices
• Investment in IT Platforms and related hardware to enable remote based collaboration and communication including Office 365 and Microsoft Teams, Zoom, and GoTo Meeting
• Development of a national recruitment footprint and sophisticated recruiting and candidate evaluation models to support hiring of experienced remote staff
• Development and rollout of new product solutions, technology infrastructure, and workflow platforms including RPA that allow CRFS to better address the challenges and opportunities facing mortgage servicers during 2020 and beyond

Widely recognized as the industry leader in claims recovery, CRFS recovers, on average, an additional $2,500 per file for their clients. Clients turn to CRFS for expertise and outsourcing solutions in FHA, VA, FNMA, FHLMC, and USDA claims recovery, HUD Audit support, Loss Analysis review, consulting, and much more.

CRFS REAL WORLD CASE STUDY 2020-02

COVID-19 LOSS MITIGATION CLAIMS PROJECT

• Client:           Large bank mortgage servicer

• Challenge:   In April, 2020 HUD issued Mortgagee Letter ML 2020-06 that provided servicers with additional Loss Mitigation options for borrowers who had entered into forbearance as a result of financial distress caused by the Covid-19 pandemic. The client was concerned it did not have enough staff to manage the large influx of claims that would need to be filed over several months as borrowers exited their forbearance window. The project encompassed literally thousands of monthly FHA Loss Mitigation claim submissions under the COVID-19 National Emergency Standalone Partial Claim program.

• Solution:       Over a period of five weeks CRFS invested in technology upgrades including integration with the FHA Catalyst system and built-out its workforce to greatly expand its Loss Mitigation processing capacity. By the end of those five weeks CRFS had more than quadrupled its Loss Mitigation claims processing capacity, and partnered with the client to supplement their capacity by up to 4,000 monthly claim submissions. In total, CRFS expanded its processing and QC operations to handle more than 10,000 monthly Emergency Loss Mitigation claims.

• Value Add:   CRFS was able to quickly deploy experienced resources to accommodate the client’s surging claims volumes under a highly scrutinized government program, providing them with greatly reduced operational risk. Additionally, integration developed with HUD’s Catalyst system allowed for a more streamlined process that kept costs down while maximizing the financial reimbursement for our client.

CRFS is pleased to announce today that Audrey Cady has joined Claims Recovery Financial Services as their Accounting Manager.  In that role Audrey will be responsible for all the accounting and financial reporting activities of the company.  Audrey holds a Bachelor’s degree in Accounting from SUNY Geneseo, and has spent the past several years working in the New York City area where she held senior positions in the media and publishing, retail, and real estate industries.

 “Adding an experienced leader to our accounting team was a priority for us as we begin to wind down 2020 and plan for the growth we expect in 2021, so we’re delighted to be able to add a seasoned professional with the credentials and energy Audrey brings” said CRFS president Steve Mowers.

CRFS REAL WORLD CASE STUDY 2020-01

FHA CLAIMS REFUND PROJECT

• Client:          Large non-bank mortgage servicer

• Challenge:   The client was not confident it had available internal analytical resources to deliver a time sensitive project involving claim recovery refunds that needed to be identified, calculated and submitted to the FHA in advance of a pending HUD Claims Audit. The project encompassed 1,570 loans potentially requiring refunds on behalf of the investor totaling almost $2 million.

• Solution:      CRFS proposed deploying an experienced consultant to review each claim, determine the applicable refund, calculate any interest amount tied to the refund, and then process the refund – all within two weeks.

• Value Add:   CRFS completed the project 7 business days after the client sent the final inventory of loans. CRFS submitted an average of 224 refunds per day worth approximately $1,157 per refund over that 7-day period. As a result of the project, the client was able to mitigate risk exposure to the investor of $1.8 million at a cost equal to a tiny fraction of the exposure.

The FHA, USDA, VA and FHFA have all recently announced plans to officially extend their foreclosure moratorium programs through December 31st, 2020.  These actions will benefit millions of at-risk homeowners with mortgages insured or backed by these institutions.  Below are links to their respective websites and communications where you can get full details…

FHA

https://www.hud.gov/

ML 2020-27

VA

https://www.benefits.va.gov/homeloans/index.asp

Circular 26-20-30

USDA

https://www.rd.usda.gov/coronavirus

Bulletin 8/28/2020

FNMA and FHLMC

https://www.fhfa.gov/Media/PublicAffairs/Pages/FHFA-Extends-Foreclosure-and-REO-Eviction-Moratoriums.aspx

LL 2020-02

Bulletin 2020-34

Mortgagee Letter 2020-22 released in July introduced a full suite of COVID-19 Loss Mitigation options available to borrowers who are affected by the COVID-19 Presidentially Declared National Emergency. These options expand upon the COVID-19 Forbearance and COVID-19 Standalone Partial claim introduced in ML 2020-06. For additional details, visit the HUD website – https://www.hud.gov/sites/dfiles/OCHCO/documents/20-22hsgml.pdf

This mortgagee letter also introduces a new SFDMS code 053 – Combination Partial Claim/Modification Started (Non HAMP). This code is effective for the July 2020 reporting cycle. The mortgagee letter includes the SDFMS Default Reason code and Default Status code requirements for each of the loss mitigation options.

The new options include:

• COVID-19 Owner-Occupant Loan Modification
• COVID-19 Combination Partial Claim and Loan Modification
• COVID-19 FHA-HAMP Combination Loan Modification and Partial Claim with reduced documentation
• COVID-19 Non-Occupant Loan Modification
• COVID-19 Pre-Foreclosure sale (PFS)
• COVID-19 Deed-in-Lieu (DIL) of Foreclosure

Mortgagees must review the borrower for these options at the end of the COVID-19 Forbearance period. Borrowers who were current or less than 30 days past due as of March 1, 2020 are eligible for these options. All of the loss mitigation options are non-incentivized with the Partial Claim amounts being reimbursed by HUD through the claim submission process. The PFS and DIL claims are submitted using the standard process excluding the mortgagee incentive.

Don’t hesitate to contact us at sales@crfservices.com to discuss how CRFS can help your servicing organization manage these claims, as the projected volumes across the industry are expected to be significant.

Enhancements to FHA’s Claims Without Conveyance of Title (CWCOT) Procedures

The provisions of Mortgagee Letter 2020-21 may be used immediately, but must be used for all foreclosure sales associated with defaulted mortgages scheduled to occur on or after 90 days from the date of the ML (July 7, 2020). For additional details, visit the HUD website – https://www.hud.gov/sites/dfiles/OCHCO/documents/20-21hsgml.pdf

• The ML provides for a second appraisal upon vacancy for a property that had an exterior-only appraisal, where an interior appraisal could not be obtained;

• • This is permitted before foreclosure if any delay in obtaining the appraisal will not cause the foreclosure sale to be cancelled; or after foreclosure for the purpose of post-foreclosure sale efforts.

• Updates the policy and allowable fee structure regarding independent third-party providers that conduct foreclosure sales or Post Foreclosure Sales Efforts under CWCOT procedures;
  • Up to an amount equal to three percent of the Property’s sales price where the independent third-party provider markets the Property, but does not conduct the sale; or
  • Five percent of the Property’s sales price where the independent third-party provider markets the Property and conducts the sale

• Updates CAFMV discounts in FHA Connection and changing to tier based pricing factors.
  • The updated CAFMV discounts are available on FHA Connection and are effective with Foreclosure sales scheduled on or after August 1, 2020
  • The CAFMV adjustments will now be based on value bands and interior vs. exterior appraisals as opposed to the previous non-competitive vs. competitive model

• New automatic extensions have been introduced which could impact the conveyance timeframe and post foreclosure efforts,
  • Automatic extensions for the purpose of post-foreclosure sale efforts can be applied to the conveyance timeframe when all other foreclosure time fames have been met

• Allows Mortgagees to submit eviction costs and certain eligible property preservation expenses incurred during Post-Foreclosure sales opportunities;
  • HUD will reimburse for all reasonable preservation, protection and eviction expenses incurred prior to the expiration of any extensions to the deadlines for conveyance

HUD ML 2020-13

Extends the foreclosure and eviction moratorium through 6/30/2020. Vacant and abandoned properties are now excluded from the moratorium.

• The COVID-19 Forbearance must be reported as 06 – Formal Forbearance
  • If a different code was previously reported, mortgagees should stop immediately and begin reporting code 06
• Default Reason code 055 – Related to National Emergency Declaration is available May 1^st and must be used no later than the July 2020 reporting cycle

HUD ML 2020-14

Extends the exception to allow exterior only appraisals for origination and servicing through 6/30/2020

FHLMC Bulletin 2020-15 and FNMA LL 2020-07

• Introduces the COVID-19 Payment Deferral Option. This provides expanded eligibility then the previous Payment Deferral Option announced in March
• The loan must be current or less than 31 days delinquent as of 3/1/2020 and no more than 12 months past due as of the date of evaluation
• This can begin July 1, 2020
• Up to 12 months of payments can be deferred into a non interest bearing balance that becomes due at maturity, property transfer or refinance
• FHA, VA and RHS loans are ineligible
• A claim can be filed for expenses such as recordation fees, title costs and notary fees
• Incentive fee information will be provided at a later date

FHLMC Bulletin 2020-16 and FNMA LL 2020-02

• Extends the foreclosure moratorium through 6/30/2020 excluding vacant or abandoned properties

• Servicers must not complete property inspections when the borrower is experiencing a hardship related to COVID 19 or during the forbearance unless the loan was already delinquent or vacant and abandoned