Version 7 Questions

Questions about MCR V7.

1. How do we define a loan “in forbearance” for MCR reporting?

Loans in an active forbearance plan are considered “in forbearance.”

2. What does “resumed contractual payment” mean in the forbearance sections of the MCR?

“Contractual payment” includes loans for which there is an expectation of contractual payment, regardless of whether or not those payments are received from the borrower. This also includes loans that are paid off during the period.

3. How should we classify loans that exit forbearance and resume contractual payments initially, but then, within the same reporting period, transition into loss mitigation or foreclosure?

Report the initial disposition of the loan when it exits forbearance in the relevant forbearance section(s), then report the loan as a normal loan you are servicing after it exits forbearance.

4. Now that HELOCs have their own line item in RMLA Section II, should I change how I report them on RMLA Section I?

No, the standard guidance for reporting HELOCs in the AC300 series of RMLA Section I (Loan Purpose) is to report them in AC310 (Home Improvement) unless the purpose of the loan fits better into the other categories.