CFPB issues blog post on COVID-19 mortgage servicing communication strategies

Ballard Spahr LLP

Ballard Spahr LLP

On April 5, 2021, the CFPB issued a blog post suggesting various communication strategies for mortgage servicers, to handle increased volume associated with the COVID-19 national emergency.  Noting the CFPB’s recent Compliance Bulletin 2021-02 and Mortgage Servicing Notice of Proposed Rulemaking, the post encourages mortgage servicers to use all available tools to reach affected borrowers.

In addition to traditional techniques of mailing letters and calling borrowers, the CFPB suggests using data science to understand borrower contact preferences.  Regarding communication strategies, the blog notes the following non-traditional techniques used by some servicers:

  • Use of multi-media channels to meet customer preferences, including combinations of text, personalized emails, or mail, as permitted under applicable law;
  • Identifying borrower contact preferences;
  • Development and use of self-service web-based tools and customer portals to assist borrowers with the loss mitigation process;
  • Use of tailored communications, including videos and emails, to explain specific options to individual consumers, depending on the owner of the loan (e.g., FHA, VA, Fannie Mae, or Freddie Mac).
  • Sending certain important communications to borrowers by FedEx, UPS, or other weighted mail options, to help encourage borrowers to open mail that they may otherwise discard as a routine communication.
  • Providing information in multiple languages to better assist Limited English Proficient borrowers.

The blog post also encourages servicers to refer borrowers to the CFPB’s Interagency Housing Portal, which explains forbearance programs and other available options.  The portal also has resources available in multiple languages.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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