In the current mortgage landscape, ensuring the highest standards of loan quality is paramount not only during the origination process but also over the life of the loan. As the mortgage industry grapples with a changing market and regulatory complexities, we sat down with Amanda Phillips, Executive Vice President of Compliance at ACES Quality Management, to discuss how lenders can foster long-term success through a robust servicing QC process.
HousingWire: What were some of the challenges faced by lenders in 2023 and what is the outlook for 2024?
Amanda Phillips: 2023 was a year of trials and tribulations for financial institutions. Mortgage applications hit their lowest level since 1996 and lenders were faced with the compounding challenges of dwindling origination volume, soaring home prices, rising interest rates and inadequate housing inventory.
Thankfully, the tune of the housing industry has changed over the last few weeks. Analysts predict 2024 will bring a rise in mortgage origination volume and, potentially, several cuts to interest rates. While the challenge of low housing inventory persists across the country, I have a feeling loan officers will be busier. While the industry basks in the much-needed optimism for 2024, one thing is for certain, quality control (QC) and compliance are still important and worthy of lenders’ attention. An uptick in origination volume tends to bring an uptick in QC defects.
HW: Why is quality control (QC) so crucial for mortgage lenders and how can lenders maintain QC effectively?
AP: QC is crucial for lenders to ensure loan quality and mitigate risk. A well-rounded QC program can catch loan defects before regulators arrive for exam or investors send loans back for re-purchase. Operational capacity and the staggering cost to originate are challenges lenders will continue to face, leading many lenders to offset this hurdle by maintaining mortgage servicing rights (MSR). To maintain profitability through MSR, lenders also needa robust servicing QC program.
Maintaining QC begins with regularly assessing the integrity of both servicing portfolios and staff to ensure they adhere to all relevant servicing rules, guidelines and regulations. Fortunately, QC is a crucial area where lenders can see immediate returns from easy-to-implement audit and compliance technology. Lenders are advised to regularly review and update operational/compliance procedures and quality control frameworks, conduct self-assessments to test those updates, and, of course, remediate findings.
To mitigate and manage inherent servicing risks, your risk management team must identify your institution’s specific risk areas. From there, your internal audit team should ensure the proper processes and procedures are in place to address those risks. Subsequently, the QC team is responsible for verifying, from a transactional perspective, that your organization aligns its actions with its declarations and takes necessary measures regarding associated risks. Traditional methods, such as manual tracking and spreadsheets, make this process all the more prone to mistakes. This is why utilizing audit technology is so powerful; mistakes are significantly reduced and efficiencies gained through less manual entry needed from the QC team.
The CFPB’s priorities signal the importance of self-assessment and remediation. Dot your I’s and cross your T’s with a paper trail. Lenders should review their in-house practices to ensure they meet the standard and compare with the recommendations from regulators.
HW: What role does the Consumer Financial Protection Bureau (CFPB) play in the mortgage servicing landscape, especially concerning compliance with the CARES Act and servicing regulations?
AP: The CFPB continues to emphasize compliance with the CARES Act and other servicing regulations, particularly in areas like fair lending, fair servicing, and forbearance. Over the last several years, they have clearly stated the priorities of fair lending and achieving equitable and fair housing programs. The CFPB has actively stated that strictly relying on artificial intelligence (AI) and automated complex credit models will not be tolerated. If a borrower was denied, the lender needs to be able to accurately speak to and explain why and how the decision was made.
This is just another area of how implementing a robust QC process can help lenders avoid these regulatory pitfalls. With audit technology, lenders will have this process documented and ready to pull up in the event of a regulatory audit or discrepancy.
HW: What steps should servicers take to identify and manage inherent servicing risks?
AP: Servicers should identify specific risk areas, establish proper processes, and conduct audits against policies and procedures. An example of a process improvement could be a Call Monitoring program. Consumer telephone interactions are an essential aspect of servicing that is easy to overlook from a quality perspective. No matter how many controls are in place, the need for human interaction, especially as it relates to collections and loss mitigation efforts, can result in an increased risk of non-compliance. Lenders can leverage a robust Call Monitoring program to identify where improvements are needed to protect the organization from regulatory and reputational risk. ACES Quality Management has a pre-built, configurable Call Monitoring audit pack that enables servicers to establish an additional layer of protection quickly and seamlessly within your QC program.
As financial institutions navigate the intricate web of compliance requirements and market fluctuations, ACES not only enables adherence to regulatory standards but it elevates the entire loan quality paradigm. By fostering a culture of continuous improvement while equipping professionals with powerful data-driven insights, ACES becomes an invaluable ally in mitigating risks and enhancing operational efficiency.
The significance of robust quality control and management in the mortgage sector cannot be overstated. In an environment where precision and compliance are non-negotiable, ACES stands as a testament to innovation and adaptability. For more tactical ways to improve QC, download ACES’ free playbook: Three Lines of Defense for Maintaining Servicing Loan Quality.
