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Board Report: 2014-SR-B-015 September 30, 2014

Opportunities Exist to Enhance the Boardís Oversight of Future Complex Enforcement Actions

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Appendix B: Results of the Servicersí Slotting and the Payment Amounts

No.a Category description Stage of foreclosure 11 servicersb Goldman Sachs and Morgan Stanley Total borrowers
Borrowers who requested a review All other borrowers Number of borrowers Payment amount
Number of borrowers Payment amount Number of borrowers Payment amount
1a Servicer foreclosed on borrower eligible for SCRA protectionc Rescinded 8 $15,000 108 $15,000 14 $15,000 1,261
Completed 123 $125,000 959 $125,000 49 $125,000
1b Servicer charged servicemembers interest rates that exceed SCRA section 527 limits In process 33 >=$300 317 >=$300 101 >=$300 525
Completed 11 >=$300 63 >=$300 0 >=$300
2 Servicer initiated or completed foreclosure on borrower who was not in defaultc In process 46 $5,000 543 $5,000 55 $5,000 747
Rescinded 8 $15,000 29 $15,000 10 $15,000
Completed 8 $125,000 45 $125,000 3 $125,000
3 Servicer initiated or completed foreclosure on borrower who was protected by federal bankruptcy law In process 2,401 $7,500 19,860 $3,750 1,069 $4,650 29,531
Rescinded 28 $7,500 160 $3,750 67 $4,650
Completed 763 $62,500 5,075 $31,250 108 $38,750
6 Servicer completed foreclosure on borrower who was meeting all requirements of documented forbearance plan Rescinded 50 $6,000 185 $3,000 45 $3,900 1,174
Completed 162 $24,000 684 $12,000 48 $15,600
4 Servicer failed to convert borrower to permanent modification after three successful payments under a written trialperiod plan In process 461 $6,000 2,436 $3,000 312 $3,900 4,482
Rescinded 31 $6,000 91 $3,000 44 $3,900
Completed 239 $50,000 718 $25,000 150 $32,500
5 Servicer completed foreclosure on borrower who was performing all requirements of the written trial-period plan Rescinded 29 $6,000 126 $3,000 77 $3,900 1,209
Completed 163 $50,000 477 $25,000 337 $32,500
10 Modification request approved In process 118,177 $500 746,894 $300 62,927 $300 1,191,516
Rescinded 2,617 $500 9,229 $300 869 $300
Completed 39,368 $500 195,448 $300 15,987 $300
7 Modification request deniedd In process 62,557 $2000 432,595 $1,000 41,912 $1,300 942,116
Rescinded 1,539 $2000 6,007 $1,000 1,016 $1,300
Completed 60,251 $6000 309,597 $3,000 26,642 $3,900
8 Modification request received but no underwriting decision made In process 21,153 $800 200,596 $400 13,090 $520 449,266
Rescinded 709 $800 3,757 $400 324 $520
Completed 27,152 $800 168,479 $400 14,006 $520
9 Servicer did not engage with borrower in a loan modification or other loss mitigation action In process 16,679 $600 312,881 $300 5,825 $300 918,392
Rescinded 350 $600 4,549 $300 96 $300
Completed 36,564 $600 531,912 $300 9,536 $300
11 All other loans In process 21,459 $500 334,630 $300 13,780 $300 633,435
Rescinded 450 $500 4,161 $300 304 $300
Completed 24,959 $500 218,737 $300 14,955 $300
Total borrowers   438,548   3,511,348   223,758   4,173,654

 

Source: OIG analysis of Board and OCC documents.

a The categories listed are not in numerical order. For the slotting, borrowers were to flow down through the waterfall in the sequential order that the categories appear in this table.

bThe 11 servicers were Aurora, Bank of America, Citibank, HSBC, JPMorgan Chase, MetLife Bank, PNC, Sovereign, SunTrust, U.S. Bank, and Wells Fargo. This chart includes borrowers whose mortgage was serviced by Board- and OCC-supervised servicers.

cThe amount received by borrowers in these categories may be different because of offsets resulting from other settlements.

dAccording to Board staff, the Board and the OCC decided that all borrowers denied a modification would be slotted into one category. Thus, the Board and the OCC combined subcategories (7a and 7b) that had been listed separately in a draft of the IFR waterfall.