CARES Act Forbearance Services

Financial Services

Financial Services | Forensic & Litigation Consulting

October 5, 2020

The CARES Act provides for various consumer relief, notably in mortgage forbearances and credit reporting. The fast-tracked legislation left open many practical implications, resulting in a multitude of logistical challenges to servicers in administering the forbearance programs and other consumer protections, such as credit reporting provisions.

With the FHFA’s Office of Inspector General already issuing a report raising the GSEs’ lack of oversight on servicers’ compliance with the CARES Act, the CFPB sending prioritized assessment requests to certain servicers and the House Financial Services Committee requesting information from 11 of the largest servicers, further regulatory scrutiny is inevitable.

FTI Consulting’s deep mortgage servicing expertise has provided us with specific insights into the challenges posed by loss mitigation and credit reporting to help navigate the potential risks to servicers, particularly in proactively identifying and addressing any potential issues that may result in future regulatory or reputational concerns and also informs our methodology for conducting these assessments.

Areas Requiring Special Consideration and Attention

  • Lack of Cohesive Guidance
  • Customer Call Quality
  • Lack of Documentation
  • Nuanced Credit Reporting Requirements

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