Recently, the Consumer Financial Protection Bureau, Federal Reserve System, Federal Deposit Insurance Corp., National Credit Union Administration, and the Office of the Comptroller of the Currency issued joint guidance on mortgage servicing practices that affect active duty members of the military.
While the guidance focuses mainly on mortgage loan practices and procedures for Permanent Change of Station orders that servicers must follow for active duty military personnel, field service companies can play an important role in keeping their mortgage servicing clients in compliance with this new guidance and consumer laws.
National field service companies employ a large network of contractors throughout the country who inspect and maintain vacant and foreclosed properties under the guidance of servicers and investors. They physically visit the properties and can be utilized for borrower outreach purposes.
The field service company’s contractors can make face-to-face contact with a borrower to help determine if he or she is actively serving in the military. The contractor also can leave educational materials at the door or in the form of a door hanger at the property informing homeowners of their rights if a member of the military on active duty resides at the property. These materials may include the mortgage servicers contact information and other valuable information.
Field service companies and their contractor networks can assist servicers and investors in addressing the new interagency guidelines in several ways:
· Providing homeowners who notify servicers of PCS orders with accurate and understandable information about the availability of assistance for which they may qualify.
· Helping servicers identify homeowners who are active duty military personnel and providing them with relevant information in compliance with the Servicemembers Civil Relief Act.
· Providing accurate information about options to homeowners with PCS orders who are current on their loans and able to make the monthly payments
· Delivering communications in a timely manner from the servicer to homeowners who are active duty members of the military with PCS orders.