Alert November 29, 2011

OCC Issues Status Report on Implementation of Foreclosure-Related Consent Orders

The OCC issued an interim status report summarizing the actions taken by12 national bank and federal savings bank servicers to comply with the April 13, 2011 consent orders issued by the OCC and the former OTS regarding foreclosure practices. The report identifies the consultants engaged by each servicer to conduct the independent foreclosure file reviews required by the orders, and discusses how the reviews will be conducted.  The report also discusses actions taken by the servicers to (1) change servicing processes and procedures; (2) improve oversight and management of third-party service providers, including MERS; (3) enhance management information systems; (4) assess and manage risks; and (5) set up compliance committees responsible for developing and implementing compliance programs, action plans, and policies and procedures.  The report states that the OCC expects the servicers to complete the implementation of new processes, policies, and enhanced controls during the first part of 2012.  Click here for the report.