b'Mortgage Origination + ServicingIn 2020, Goodwin tracked mortgage origination andthe COVID-19 crisis. TheCFPB identified six areas servicing enforcement actions at the state and federalof noncompliance: levels resulting in total recoveries of approximatelyFailing to provide periodic statements to borrowers $174 million, an increase from the approximatelywho had closed-end mortgages and were in $99.6million recovered in 2019. Goodwin trackedbankruptcy;27publicly announced enforcement actions in 2020, more than doubling the 13 actions tracked in 2019.Imposing forced-place insurance policies and Federal agencies, predominantly the CFPB, DOJ, andrelated fees on borrowers without a reasonable HUD, were responsible for a majority of enforcementbasis to believe the borrower had failed to actions in the mortgage origination and servicingmaintain required insurance;space. State attorneys general, led by New York and Massachusetts, initiated only six publicly announcedFailing to cancel and refund forced-placed actions (including one action in coordination withinsurance charges within 15 days of receiving the CFPB).evidence of a consumers existing coverage;Providing consumers with options to repay escrow Key Trends account shortages and deficiencies that are not specifically enumerated in Regulation X;The CFPBs enforcement campaign targeting deceptive and misleading advertisements made toFailing to comply with servicing transfer obligations, military servicemembers and veterans, discussedincluding failures to exercise reasonable diligence, in more detail below, is largely responsible for theprovide an accurate effective date of transfer, and year-over-year increase in the number of enforcementproperly credit periodic payments as of the day of actions. These actions constituted over one-third of thereceipt; andmortgage-related enforcement actions that Goodwin tracked this year, but only yielded approximatelyFailing to provide notices to borrowers in $4.4 million in recovery for the Bureau. This isconnection with the transfer of loan ownership. representative of the Bureaus more lenient approachLast year, Goodwin reported on the Memorandum to civil money penalties under Director Kraninger.of Understanding (MOU) between HUD and the DOJ Over half of the $174 million in total recoveries isannouncing that HUDs administrative enforcement attributable to one joint federal-state settlement withmechanisms would be the primary mode for enforcing Nationstar Mortgage, LLC concerning certain allegedFalse Claims Act (FCA) claims. Goodwin predicted legacy servicing practices discovered in 2014 and 2015that, as a result of the MOU, lenders would see few regulatory examinations. And approximately $62 million(if any) new FCA actions based on alleged Federal of the $90 million attributed to the NationstarHousing Administration (FHA) guideline violations. settlements, discussed in more detail below, was forThatprediction proved largely true, except for one new past remediation that was voluntarily provided bylawsuit filed by the DOJ related to Nutter Home Loans Nationstar following those exams.origination of HECMs. This lawsuit likely stemmed from The CFPBs Summer 2020 edition ofan investigation launched before the MOU and should Supervisory Highlights detailed its most recentnot be taken to suggest the DOJ is launching new FCA findings from mortgage servicing examinationsinvestigations of FHA and VA lenders. The remaining conducted in the months immediately precedingactive FCA lawsuits concerning violations of FHA 14'