Standards related to loss mitigation procedures, including dual tracking, are an area of much industry discussion for mortgage servicing companies.
Of the areas impacted by the CFPB mortgage servicing standards, loss mitigation procedures may have the highest inherent risk of non-compliance given the manual nature of these procedures. The loss mitigation procedure rules require servicers to evaluate borrowers’ applications for available loss mitigation options. The rules prescribe certain requirements servicers must meet prior to initiating any foreclosure actions.
In preparing for CFPB compliance, servicers should consider looking holistically at all governing rules to manage compliance.
Related reading about CFP mortgage servicing standards