Servicing

Questions about reporting servicing on the mortgage call report.

Q. Is my company required to report interim servicing?

No. Interim servicing information under 90 days or collection of three payments or less is not reported on the MCR.

Q.If my company owns the servicing rights in states where we are not currently required to be licensed through NMLS, should we create state-specific RMLAs in those states to report the servicing activity so all reports balance, or do we report the additional volume under the "Loans Serviced - Nationwide Totals" section?

Your company has two options: You can report the servicing activity in the nationwide totals section to reflect the additional servicing volume in those states where you are not required to hold a license through NMLS, but because this won't match up with the state specific servicing figures in the RMLAs, you will be required to acknowledge a completeness check warning and input a note for the regulators. The second option is to create new RMLAs for those states that you are not licensed in, input the servicing data for those respective states, and submit the filing. This approach will ensure that the nationwide servicing totals match the state specific servicing data, therefore there will be no completeness check warning to acknowledge.

Q. My company owns the servicing rights to all our loans but uses a subservicer to complete the servicing function. We have indicated in S540 Subservicing by Others, that all our serviced loans are subserviced by others. Do we need to report these serviced loans in S600-S1050 as well?

Yes. Your company should report serviced loans in S600-S1050 for loans that you have the servicing rights to. You need to report on all the loans you are responsible for servicing even if you have contracted with another company (subservicer) to complete that function.

Q. For some loans serviced, no pool numbers are assigned, but we receive an error message if pool number is left blank in Section III – Loans Serviced. How should complete these fields if no pool number is assigned to satisfy the Completeness Check error message?

Systematically filers are required to input a pool number, owner name, the UPB($) and Loan Count (#) in Section III – Loans Serviced if servicing information is provided. If no pool numbers were assigned, filers should use their own in-house pool numbers and retain proper work papers to provide the examiners during an examination.

Q. Are we required to report each individual pool, or should they be limited to investor type and provided in the aggregate?

Due to the large amount of data/pools that are being reported in some cases, pools should be limited to investor type and provided in the aggregate. Retaining work papers is important so that pools can be reviewed adequately during an examination.

Q. As a subservicer, when entering Owner Name and NMLS ID # under S530 (Subservicing for Others), do we input the owner of the loan or the owner of the mortgage servicing rights?

Report the owner of the mortgage servicing rights.