Introduction to Mortgage Servicing Examinations Training - March 2023

Escrow Account Maintenance

12 C.F.R. § 1024 – Real Estate Settlement Procedures Act

Does the servicer’s escrow account maintenance policy address: 1. Handling of shortage, deficiency, or surplus 2. Issuance of annual statements

 12 C.F.R. § 1024.17  12 C.F.R. § 1024.34

3. Issuance of short ‐ year statements 4. Issuance of statement upon servicing transfer 5. Content of statements 6. Timely payments/disbursements 7. Account cushion

CFPB RESPA Exam Procedures

8. Recoupment of advances 9. Refund of escrow balance

Force ‐ Placed Insurance

12 C.F.R. § 1024 – Real Estate Settlement Procedures Act

Does the servicer’s force ‐ placed insurance (FPI) policy address: 1. Basis for determining coverage is necessary 2. Notice requirements before implementing FPI coverage 3. Content and timing of notices 4. FPI policy renewal or replacement 5. Cancellation of FPI coverage Does the servicer have a foreclosure policy that addresses: 1. Timing and review of loss mitigation applications 2. Handling of loans in forbearance or repayment plan 3. Timing of foreclosure referral and initial notice of foreclosure Does the servicer’s loan boarding policy address: 1. Notice requirements for servicing transfers 2. Content and timing of notice 3. Handling of borrower payments during transfers

 12 C.F.R. § 1024.37

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Foreclosures

12 C.F.R. § 1024 – Real Estate Settlement Procedures Act

 12 C.F.R. § 1024.41

CFPB RESPA Exam Procedures

Loan Boarding

12 C.F.R. § 1024 – Real Estate Settlement Procedures Act

 12 C.F.R. § 1024.33

CFPB RESPA Exam Procedures

Loss Mitigation, Early Intervention,

12 C.F.R. § 1024 – Real Estate Settlement Procedures Act

Does the servicer’s loss mitigation, early intervention, and continuity of contact policy address: 1. Live contact with delinquent borrowers

 12 C.F.R. § 1024.39