One of the metrics, which “effectively created new servicing standards pertaining to the loan modification process and thereby imposed additional, measurable obligations on servicers,” he notes, “does not per se satisfy the additional metrics criteria” that is part of the settlement.
“However, the obligations imposed on servicers as a result of such additional metric are substantially similar to and flow from the obligations imposed upon servicers by the existing servicing standards under Exhibit A to each of the consent judgments filed in the settlement,” according to Smith. This new metric is designed to measure the loan modification process.
Others new metrics aim to measure loan modification denial notice disclosure, single point of contact implementation, and effectiveness and billing statement accuracy.
