Presentation on theme: "National Mortgage Settlement and Chase RMBS Settlement Update NC Affordable Housing Conference OCTOBER 15, 2014 Josh Stein."— Presentation transcript:
National Mortgage Settlement and Chase RMBS Settlement Update NC Affordable Housing Conference OCTOBER 15, 2014 Josh Stein
National Mortgage Settlement 49 states, federal government and five largest mortgage servicers $25 billion o ~$5 billion in direct payments to states and consumers o ~$20 billion in consumer relief 304 servicing standards, or rules, and 29 metrics, or tests Monitor established to ensure servicer compliance with consumer relief and servicing standards
Consumer Relief All five banks received credit for consumer relief requirements in March The monitor credited $20.7 billion in total relief.
Consumer Relief by Servicer Consumer Relief LoansTotal Gross Dollar Relief Total Credited Relief Total Relief Obligations Bank of America317,028$27,344,833,073$9,610,418,492$8,574,200,000 Chase125,553$11,124,434,955$4,463,524,210$4,212,400,000 Citi58,822$3,515,708,965$1,792,967,705$1,789,000,000 ResCap7,434$554,086,749$257,411,785$200,000,000 Wells Fargo122,719$7,923,863,398$4,568,334,894$4,337,000,000 Total consumer relief 631,556$50,462,927,140$20,692,657,086$19,112,600,000 The Monitor’s Final Crediting report is at
Testing a Metric Step One: Bank implements servicing standards Step Two: Testing by Internal Review Group (IRG) Step Three: IRG submits Compliance Review Report to the Monitor Step Four: Retesting by Secondary Professional Firm (SPF), Primary Professional Firm (PPF) and Monitor Step Five: Monitor submits report on metrics to the D.C. District Court
Failing a Metric: What’s Next Bank implements Corrective Action Plan (CAP). If potential violation is widespread, bank compensates all borrowers experiencing material harm. Testing recommences by IRG and Monitor beginning the quarter after the CAP is completed by bank. If bank fails metric again in either of the next two quarters, Monitoring Committee and Monitor may file enforcement action, including: o A court order to stop specific behaviors o Up to $1 million civil penalty o Up to $5 million fine for failing particular metrics multiple times
Green Tree and Ocwen Green Tree Servicing and Ocwen acquired servicing rights and assets from ResCap Parties. ResCap reported eight failed metrics on their portion of the ResCap portfolio and is implementing corrective action plans. Ocwen fully implemented servicing standards for its portion of the ResCap portfolio and agreed to comply with NMS servicing standards in its entire portfolio. The Monitor will report on Ocwen’s compliance before the end of the year.
Executive Office Complaints
Additional Metrics The Monitor, Monitoring Committee and Servicers agreed to four additional metrics. Compliance testing by IRG began January 2014 to address issues related to: Single points of contact Billing statement inaccuracies Compliance testing by IRGs began April 2014 to address loan modification process issues related to: Missing documents Premature denials and appropriate time to provide additional documentation Proper communication of loan modification denials
Chase RMBS Settlement
Crediting Process Step One: Chase provides relief to borrowers Step Two: Chase Submits report to internal review group (HRG) Step Three: HRG tests Step Four: HRG asserts Chase’s crediting to monitor Step Five: Monitor and professional firm test Step Six: Monitor creates report on testing results Step Seven: Monitor publicly reports findings
Chase RMBS Consumer Relief HRG Assertion Chase’s HRG asserted that 46,404 borrowers received relief amounting to $7.6 billion
Chase RMBS Consumer Relief HRG Assertion Chase’s HRG claimed $868.6 million in relief credit