|
New approaches are needed to prevent millions of
unnecessary foreclosures.
Without a substantial increase in loss mitigation
staffing and resources, we do not
believe that outreach
and unsupervised case-by-case loan work-outs, as used by
servicers now, will prevent
a significant number of unnecessary foreclosures. In our
first report, we renewed our
call for more systematic, long-term solutions to
efficiently deal with subprime loans
originated in recent years. While we support
industry-led efforts to implement
broader-based programs such as the ASF “fast track”
program and Project Lifeline’s
30-day breathing period, we still see a tremendous gap
between the need for loan work-outs and the options in
place today.
The State
Working Group believes more robust approaches to avoid
preventable foreclosures are
necessary. Servicers,
investors, and state officials have opportunities
to work
together on the following:
·
Developing a more
systematic loan work-out system to replace the
intensive
“hands-on” loss mitigation
approach. The continued
reliance on intensive individual interaction to identify
alternatives to foreclosure misses out on
opportunities to
implement solutions that can reach more homeowners
facing foreclosure. A more
systematic approach would benefit homeowners
and investors by reaching more
people with more streamlined solutions. Such
an approach would build on the
initial effort of the ASF Framework, but cover
many more loans.
·
Slowing down the
foreclosure process to allow for more
work-outs. Many
states have
passed or are considering legislation to slow down the
foreclosure process and to increase notice to
delinquent homeowners. Targeted efforts to slow down
subprime foreclosures may give homeowners and servicers
more time to find solutions to avoid
foreclosure.
In addition to these efforts, the State
Working Group recognizes that federal officials
have proposed or
are considering legislation, such as permitting
judicial modification of loans in
bankruptcy and expanding FHA refinancing of subprime
loans, that would mark a significant change to the
current mortgage servicing dynamics. While we do
not endorse any specific federal
approach, we support the development of
innovative approaches that recognize the
extent and scale of the foreclosure
crisis.
The Foreclosure
Fraud Alert Website http://www.foreclosurefraudalert.com/
The
Foreclosure Fraud Alert
Blog
http://www.foreclosurefraudalert.com/fraudblog
|