Servicers Expected to Comply with Treasurys HAMP Update Registration
It may be just another example of how the Department of the Treasury keeps lenders and servicers on their tiptoes but complying or not with a recent technology access review means participating in the Troubled Asset Relief Program or not.
By Oct. 3, all servicers wishing to participate in any Making Home Affordable related program, including the Home Affordable Modification Program, Second Lien Modification Program, Treasury FHA-HAMP and Treasury FHA Second Lien Program must be registered.
It means all registration forms and trial balance summary information has already been sent to the
HAMP Solution Center since the information is used to establish program caps for each program for which a servicer is registering and complete the Servicer Participation Agreement. (The SPA must be signed and resubmitted to the HAMP Solution Center by Sept. 22.)
Treasury’s HAMP review requirement includes updates of access to the secure portions of HMPadmin.com, the NPV Transaction Portal and the HAMP Reporting Tool managed by Lender Processing Systems Inc. for Fannie Mae, on behalf of the Department of the Treasury.
Treasury recommends periodic reviews of entities that have access to HAMP technology “to ensure that it is commensurate with their job responsibilities.”
Regulatory compliance requirements demand “effective controls over who has access to sensitive corporate and customer information” to ensure changing business responsibilities that no longer justify data access over time are removed.
To remain in compliance servicers need to validate existing users and flag questionable access to the HAMP platform.
Servicers are expected to carefully review for inaccuracies information about the HAMP technology platform users. It has to include the first and last name of the user registered in the application's system of record, the user ID that allows users to log into the assigned application, phone numbers and e-mail addresses where to send communications such as security notifications, applications the user can access, and specific user authorization roles.
Also, access reviews sent to the HAMP Solution Center need to focus on whether the user still is employed by the servicer, changes in job responsibilities that may affect user access to the application, or their current role in case a user's access should be changed or disabled.