A new presidential administration and a clarion call from the Consumer Financial Protection Bureau has transformed fair servicing from a seemingly remote risk into a front and center mandate.
After the 2008 financial crisis, regulators enhanced long-standing fair lending examination guidelines to incorporate the concept of fair servicing. They began to scrutinize potential discriminatory loss mitigation and foreclosure practices and threatened to hold mortgage servicers accountable if such impermissible practices were identified.
Mortgage servicers prepared for the scrutiny, conducted fair servicing risk assessments, and brought in the quants to analyze their servicing portfolio for risk of disparate treatment and disparate impact details ⇒
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