Profile: dennis frailey
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August 20, 2012 2:16 pm
Welcome to Regulation Room, dennis frailey, and thanks for your suggestions. What do you think of the proposed Notice of Servicing Transfer. You may also be interested in the proposed periodic statements .
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The problem with all of this is that the consumer doesn’t understand all of the parties involved in his or her loan and might need that information in the case of a financial crisis of some kind. In addition to the servicer of the loan there is the question of who actually owns the loan and, if the loan has been bundled into some sort of security, perhaps the borrower should know that as well. Lack of clear records in this regard was exposed as a major problem during the 2008 crisis. So it seems to me that whenever any change occurs in any of the above, the mortgagee should receive a clear, concise picture of the situation. For example, at time of loan:
- your loan is being sold to you by xxx (include all relevant contact info)
- your loan will be serviced by yyy. This is the organization… more »
- your loan will be owned by zzz. This is the organization to whom you actually owe the money. (include all relevant contact info).
and so on and so forth.
A similar form should be sent when there’s a change.
Suggestion: each mortgage loan should have a unique universal identifier so things can be tracked properly. I.e., when a loan is packaged and sold in a structured security, the paperwork would have the unique IDs of all loans included in the package. « less