This practice area helps clients in the assessment, design, and implementation of critical business functions. Leveraging Collingwood’s specialized risk management and operations expertise and highly skilled team of mortgage practitioners, the firm offers a full range of operational and technical professional services including: -Risk Management -Independent reviews of forward and reverse mortgage origination, servicing, quality control, and claims business operations -Litigation defense services, including False Claims Act subpoenas
The division supports the full range of clients’ government lending business activities, across the entire loan life cycle including origination, servicing, and claims for FHA, USDA, and VA. Staffed by the industry’s largest group of former HUD employees – including a former FHA Commissioner – the team brings a combined two hundred plus years of experience in government lending compliance and risk management.
- Operational risk assessment to determine the company’s vulnerability with regard to potential regulatory and/or compliance enforcement actions.
- Automated Neighborhood Watch analysis of corporate, branch office, national and FHA field office data and trending, as well as TPO analysis to effectively manage counterparty risk and identify potential areas of enforcement action.
- Readiness audits to identify compliance and risk management deficiencies and making recommendations for constructive corrective actions.
- Client support for appeals and responses to Mortgagee Review Board actions, Quality Assurance Division reviews, Office of Inspector General audits, Credit Watch or Direct Endorsement enforcement and Indemnification Requests.
- Preparation for FHA, USDA and VA compliance reviews.
- Review of Quality Control plans, processes and systems to help ensure compliance with FHA regulations.
- Sub-servicer monitoring and oversight as required by GNMA.
- Analysis of FHA and VA claims processing operations, potentially saving lenders significant dollars in claims recoveries.
- Compliance Training on FHA, VA origination, servicing and claims as well as GNMA.
- Litigation support in defense of False Claims Act and Qui Tam Cases
If you are an FHA lender or servicer, you are aware of the increase in FHA volume and the corresponding heightened level of enforcement. Of note, there has been a recent increase in inquiries around Policies and Procedures (P&P) for sub-servicer oversight and monitoring. This oversight is not only required by GNMA, but also falls under the Consumer Financial Protection Bureau (CFPB) policy regarding management of service providers to ensure compliance with federal law as well as the CFPB regulations. In addition, the dramatic increase in FHA origination that began in 2007 has resulted not only in a parallel surge of enforcement activity but also Credit Watch and Direct endorsement terminations and indemnification requests.
The Collingwood Group team knows first-hand the importance of understanding and interpreting the nuances of compliance changes within the FHA, VA, and USDA space. With expertise spanning all aspects of FHA financing programs and GNMA securitization activities, The Collingwood Group is uniquely qualified to help our clients manage and grow their businesses by being proactive in identifying areas of concern.
The costs of non-compliance have never been higher and our clients have experienced first-hand the benefit of working with an experienced partner in dealing with FHA and GNMA compliance issues.
Client experienced rapid growth in its FHA servicing operation over the course of 3 to 4 years, as a result of targeted acquisitions and transfers of non-performing loans into the servicing portfolio. Given the volume and proportion of non-performing loans on its books, the client wanted the perspective and insight of an independent review to evaluate operational effectiveness.
Client desired an industry-leading, best practice claims management function, staffed with talented professionals focused on reducing the severity of losses from claims curtailments. The goal was to establish claims processes that were highly efficient and scalable, and that offered real-time transparency into the effectiveness of the company’s servicing practices. Further, the company wanted to ensure that procedures could be adapted easily to meet changing business & investor demands.
Over 45 days, Collingwood’s team of highly experienced associates completed a “cradle-to-grave” deep-dive process evaluation of the claim filing and loss analysis processes, using our highly effective 4-step approach.
- Reviewed existing policy and procedures (P&Ps)
- Interviewed the client’s associates performing the tasks to determine gaps between current practice and documented P&Ps.
- Conducted a sample Claim File review to understand first-hand the client’s end product and, again, identify any gaps in practices.
- Evaluated the client’s Performance Management System
Made best practice recommendations, as the foundation for a highly efficient and effective long-term process. Deliverables included:
1. Narrative report of findings, describing in detail each high-level observation, as well as quantified financial exposure and potential recoveries;
2. Economically-focused Remediation Road Map;
3. Risk Control Process Assessments (RCPAs) for each business area, highlighting the identified gaps and best practice opportunities;
4. Detailed claim file review worksheets identifying issues and potential forms of remediation