The Office of the Comptroller of the Currency said Friday it is requiring comprehensive data from nine large national banks engaged in mortgage servicing. The OCC stated that these nine comprise the “overwhelming majority” of national banks servicing mortgage loans.
The OCC indicated the data would supplement HOPE NOW alliance efforts, a cooperative enterprise between investors, lenders and counselors intended to help distressed homeowners. The data request covers all mortgages, rathen than being limited to subprime.
Comptroller John C. Dugan stated the data was being collected “to assure that we have a detailed picture of the activities of national bank servicers and the performance of loans serviced by them.”
The press release states in part:
With record numbers of foreclosures, the data is expected to give the OCC and other regulators a more complete view of the market, which will aid in the agency’s supervisory work as well as help in preventing unnecessary foreclosures. Metrics developed from the data on subprime lending will be available to state agencies through the HOPE NOW alliance, and should provide a robust and comprehensive overview of subprime mortgage lending.
While the HOPE NOW alliance is collecting data on subprime mortgages, the OCC is seeking a broader data set that includes information on all mortgages. The OCC is also planning to collect data on home equity loans as well, later this year.
The OCC has had an effort underway for some time now to develop data that would provide key metrics on the mortgage lending industry, and share the agency’s proposed metrics, data definitions and reporting schedules with HOPE NOW. HOPE NOW has revised and expanded its subprime mortgage metrics to be more consistent with the enhanced metrics to be used by the OCC, and the OCC has made some revisions to its metrics and definitions so they would be compatible with the HOPE NOW data set.
As a result, national banks can satisfy the OCC reporting requirements either by sending mortgage data directly to the OCC, or the OCC will accept mortgage data prepared on behalf of national banks from the HOPE NOW alliance data aggregator.
A copy of the letter the OCC sent to these nine national banks is available here.
As previously mentioned on this site, Mortgage Law Blog has concerns regarding multiple, duplicative regulations burdening lenders and servicers. The currently sharp spike in foreclosures exacerbates this concern today, as servicers need to focus their time and limited resources assisting homeowners rather than responding to redundant requests for information about foreclosures.
Mortgage Law Blog is glad to see the OCC is cognizant of the burden of data production on national banks. Other regulators will hopefully take a similar approach. A number of states have implemented or proposed foreclosure data production laws and regulations.
A single uniform approach would greatly serve the public interest. The OCC has indicated it would share the information with the states. Assuming the states are willing, this approach is imminently sensible.