Servicing Report Frequently Asked Questions (6/12/2015)

Transcription

1 Servicing Report Frequently Asked Questions (6/12/2015) MI companies rely on our servicers data for a multitude of key business processes that enable us to effectively and efficiently transact with each other from correct UPB for billing purposes and internal/external reporting to ensuring the correct loan status and loss mitigation information. That is why Radian s Master Policy #RAF483 (for MI applications received on or after October 1, 2014) contains a provision for a monthly servicing report on both performing and delinquent insured loans, as do other MI companies. In 2014, a group of MI companies teamed together to create a consistent servicing report template and data definitions that servicers could use to make it easier for them to meet this reporting provision. The resulting template is called the Mortgage Insurance Loan Activity Report. The Mortgage Insurance Loan Activity Report (MILAR) provides two alternatives: MILAR 169: a full data set (169 data elements) MILAR 32: a minimum data subset (32 data elements) Radian is ready to accept either version of MILAR from any Servicer wishing to use this format while remaining open to work with Servicers who wish to meet this provision by some alternate reporting means. This document provides answers to several frequently asked questions (FAQ) about the Servicing Report Provision and MILAR templates and is broken into the following categories 1. Servicing Report Provision 2. Reporting using the MILAR Templates 3. Subservicer Data Elements 4. Loan Data Elements 5. Borrower Proceeding Data Elements For additional questions, please contact Radian s Customer Care team at: Telephone: 877.RADIAN1 or customercare@radian.biz

2 1. Servicing Report Provision 1.1. Where is this addressed in Radian s Master Policy (#RAF483)? 1.2. What reports will satisfy Radian s Servicing Report provision? Radian accepts two versions of the MILAR template: 1) the 169 field MILAR template, designed to replace the need for separate modification reporting once validated or 2) the 32 field MILAR template. Additionally, Radian is ready to partner with Servicers who would like to provide alternative reporting How often do I need to deliver the Servicing report? Radian requests that the servicing report be generated on a monthly basis and delivered to us by the 25 th day of the following month What should be the as of date for each Servicing report? The report should contain all loan information as of the last day of the prior month What is the preferred delivery format of the file? The preferred format is a text file that is pipe delimited ( ) to identify the start/end of each column. Radian also accepts this report in all versions of Excel. A commaseparated (CSV) file is not acceptable as many text values may have commas in the data Is there a preferred naming convention for the files? Radian s preferred naming convention is: File Naming Convention MILAR_<ReportingYear>_<ReportingMonth>_<ServicerShortName>_<ReportVersion>_<Maste rpolicynumber>.txt MILAR This is text that should be consistent on each monthly submissions <ReportingYear> 4 digit numeric to indicate year (e.g. 2015) <ReportingMonth> 2 digit numeric to indicate month (e.g. January would be 01 ) <ServicerShortName> Abbreviated name for Servicer, must be consistent on each monthly

3 submission <ReportVersion> <MasterPolicyNumber> Initial submission would always be 01 however if there is a need to regenerate the same report for a given month this number would be incremented Radian Master Policy Number (first 5 digits only) 1.7. What is the preferred delivery method? Radian offers two methods to submit the report: 1) SFTP (preferred) Contact Radian's Customer Care team for questions about the set-up for SFTP transmission at 877.RADIAN1 or , or customercare@radian.biz. 2) Secure the report to servicingreport@radian.biz Do I need Radian approval before ending legacy loan modification reports? Yes, Radian will work with our Servicers to provide guidance on when they can discontinue providing other existing loan modification reports. 2. Reporting using the MILAR templates 2.1. Why MILAR? The MILAR template satisfies the Servicing Report provision (section 5.1) in Radian s Master Policy #RAF483. This report will enable Radian to conduct portfolio reconciliations on a monthly basis, to ultimately ensure portfolio alignment with the Servicer What is the most current version of the MILAR Templates? The Mortgage Insurance Loan Activity Report (MILAR) Templates with definitions and instructions dated June While the structure of each template remains unchanged from the version released in August 2014, they have been revised to make them more informative Why two templates? The full 169 dataset version is intended to replace the need for separate modification reporting once the data being provided has been reviewed and validated by Radian while the 32 dataset version gives the servicer the option to continue reporting modification activity separately.

4 2.4. What information is provided on the Enumerations Tab of each template? The Enumerations Tab was added to the template to provide codes for certain data fields. This is where you will find the reporting codes for Service Bureaus (column AR in MILAR 169, not in MILAR 32), Reason for Delinquency (column CA in MILAR 169, not in MILAR 32), and Program (column CS in MILAR 169, column V in MILAR 32). Updates to enumerations will be notated at the top of the Template as Enumerations as of month year to alert you of any updates, e.g. new workout program codes What loans should be included in the report? The report should include the following: All active loans insured by Radian as of the report date (including both performing and delinquent loans), and Example: Servicer has 20,000 in-force Radian insured loans with primary-only coverage, 300 inforce Radian insured loans with pool-only coverage, and 100 in-force Radian insured loans with both primary and pool coverage at the end of the month of January. This Servicer report would report 20,400 rows of data for loans currently being serviced and insured by Radian in the report delivered in February that is based on data as of the end of January. All loans insured by Radian that were reported the previous month that are no longer being serviced, and Example: During the month of January the Servicer had a) 1,000 loans with Radian insurance were transferred to a new Servicer and b) 500 loans with Radian insurance paid in full during the month. In the report delivered to Radian in February reflecting January activity the report would include these 1,500 loans with the appropriate removal code. REO loans or any population that has an active policy with Radian and is not otherwise referenced above. Example: At the end of the month of January the Servicer had 100 REO loans that have Radian insurance. The loans are no longer active, but the property is in the Servicer s REO liquidation process and/or is in Radian s claim process. These 100 REO loans should be included in the report delivered to Radian in February based on data as of the end of January. Combined Example: Combining the above examples the Servicer should report 22,000 (20,400 currently serviced, 1,500 previously serviced and 100 active REO) total rows of data What should be reported when a loan has both primary and pool with Radian, should the loan be on the same row or different rows? If a loan has both primary and pool coverage with Radian, the information should be reported on one row and reported as one record for each loan. The row must contain the Primary Certificate Number (C), Contract ID (D) if applicable, and the Pool Certificate Number (E).

5 2.7. When should a loan be removed from the servicing report? Loans should be removed from the servicing report the month after any of the below activity has been reported in the "Removal/Status Code" field for the loan: Sold/Servicing Transferred Paid-in-Full (not REO) All claims have been paid or resolved for the referenced Radian certificates on a loan (i.e., if pool / primary, both need to be paid / resolved) The loan has been deemed a chargeoff or uncollectable MI Coverage has terminated for all Radian certificates on a loan 2.8. What if I am not able to report all data elements as specified in either MILAR template? Please contact Radian s Customer Care team at 877.RADIAN1 or , or customercare@radian.biz. 3. Subservicer MILAR Data Elements 3.1. When are we required to complete the Subservicer fields (AT through BA in the 169 field MILAR template)? These fields are only required if the Subservicer is not responsible for providing the monthly servicing report to Radian. In this case the Servicer would report the loan and complete the Subservicer fields to indicate that there is a Subservicer involved with the servicing activities for that loan. Please reference page 9 of Radian s Master Policy #RAF483 for detailed definitions of Servicer and Subservicer 4. Loan MILAR Data Elements 4.1. How do the various dates relate to each other for each of the workout types on an executed workout? Please see Exhibit 1at the end of this document 4.2. Do you have an example of how a loan with a modification that failed looks like on the report over time? Please see Exhibit 2 at the end of this document 4.3. Do I need to report the workout activity columns for a loan if the Status did not change from the prior month? Yes, while the workout information (columns CN through EN in MILAR 169, columns T through V in MILAR 32) may not change from what was previously reported, the columns should remain on the report with no values. The only exception to this is for Trial Modification Forbearance: the Borrower current on trial payment (Y/N) field (column EJ in MILAR 169, not in MILAR 32) which should be updated on a monthly basis.

6 4.4. How do I indicate that a loan does not have any workout activity or is performing? If there is no workout activity or the loan is performing, then workout information (columns CN through EN in MILAR 169, columns T through V in MILAR 32) should be blank except the Program Name (column CS in MILAR 169 and column V in MILAR 32) which should be Which columns need to be populated if more than one workout case exists on a loan? The file should reflect the most recent workout and only the columns that relate to the most recent workout should be completed. No data from previous workouts should be on the report What should be reported if the workout status changed more than once during the reporting period? In the event the workout status changed more than once during the reporting month, the most recent workout status should be reported. The template is designed to have only one line per unique primary and/or pool loan How do I identify the appropriate code for my workout program in field (CS) Program Name? Please refer to the enumeration tab in either MILAR template. This tab provides a list of workout programs and the associated code for the workout program name field. Please contact Radian s Customer Care team for questions regarding custom programs or programs that are not listed on the enumerations tab at 877.RADIAN1 or , or customercare@radian.biz I can t report the Status (CP) of a Trial Period Plan as a Closed workout, what should I do? Radian will accept either 2 (Approved) or 3 (Closed) as the Status for a Trial Period Plan. All other Types will require that the workout be closed for it to be recorded as such. 5. Borrower Proceedings MILAR Data Elements 5.1. What is the definition of borrower proceedings? Borrower Proceedings means any administrative, judicial or non-judicial action or proceeding brought or claim asserted by a Borrower that has affected, or has the potential to affect a Loan or the Borrower s, Servicer s, Beneficiary s or lender s rights or obligations under the Loan.

7 5.2. Which columns need to be populated if more than one borrower proceedings case exists on a loan? The file should reflect the most recent borrower proceeding case and only the columns that relate to the most recent case should be completed. No data from previous borrower proceeding cases should be on the report What should be reported if the borrower proceedings status changed more than once during the reporting period? In the event the borrower proceedings status changed more than once during the reporting month, the most recent borrower proceeding status should be reported. The template is designed to have only one line per unique primary and/or pool loan. Exhibit 1: Examples of how various dates relate to each other for each of the workout types on an executed workout: Type Standard Forbearance (4month forbearance) Payment Plan (6 mo. payment Major data elements (based on MILAR 169) Definition Example Status (CP): Closed 3 Approved Date Date on which the 10/01/2011 forbearance was approved by all parties Close Date (CW): Date on which all 10/15/2011 the forbearance have been signed, executed and/or recorded in order to finalize, or make the subject workout official Effective Date (CX): 1st skipped or partial 11/01/2011 payment due date under the plan Plan Start Date (EM): First payment due date 11/01/2011 under the forbearance plan Plan End Date (EN): The last installment due 02/01/2012 date under the forbearance plan Status (CP): Closed 3 Approved Date Date on which the payment plan was approved by all parties 09/01/2011

8 Major data elements Definition Example Type (based on MILAR 169) plan) Close Date (CW): Date on which all 09/15/2011 the payment plan have been signed, executed and/or recorded in order to finalize, or make the subject workout official Effective Date (CX): First payment due date 10/01/2011 under the payment plan Plan Start Date (EM): First payment due date 10/01/2011 under the payment plan Plan End Date (EN): The last installment due date under the payment plan 04/01/2012 Status (CP): Closed 3 Approved Date Date on which the trial 09/01/2011 plan was approved by all parties Trial Modification Forbearance (3 mo. trial) Loan Modification Close Date (CW): Date on which all 09/15/2011 the trial plan have been signed, executed and/or recorded in order to finalize, or make the subject workout official Effective Date (CX): 1st payment of trial 10/01/2011 period Trial Period Begin Date (EG): Date on which the 10/01/2011 modification trial period began Trial Period End Date (EI): Last installment due date under the modification trial period 12/01/2011 Status (CP): Closed 3 Approved Date Date on which the permanent loan modification was approved by all parties 12/05/2011

9 Type Preforeclosure Sale Deed-in-Lieu Major data elements (based on MILAR 169) Close Date (CW): Effective Date (CX): Definition Date on which all the permanent loan modification have been signed, executed and/or recorded in order to finalize, or make the subject workout official 1st payment date of the newly modified loan (could be a future date). This would also be the date in which any change in the mortgage insurance coverage under the terms of the modification would go into effect. Example 12/15/ /01/2012 Status (CP): Closed 3 Approved Date Date on which the preforeclosure 08/31/2011 sale was approved by all parties Effective Date (CX): Date the real estate sale 10/23/2011 closed Close Date (CW): Date on which all the pre-foreclosure have been signed, executed and/or recorded in order to finalize, or make the subject workout official 10/23/2011 Pre-foreclosure Sale Closing Date (DE): Date of pre-foreclosure sale (i.e. Close of Escrow) 10/23/2011 Status (CP): Closed 3 Approved Date Date on which the deedin-lieu 09/20/2011 was approved by all parties Close Date (CW): Date on which all 10/23/2011

10 Type Major data elements (based on MILAR 169) Effective Date (CX): Date Voluntary Conveyance Accepted (DF): Definition the deed-in-lieu have been signed, executed and/or recorded in order to finalize, or make the subject workout official Date on which the borrower executes the Deed Date on which the Servicer accepted title to the subject property. Example 10/23/ /23/2011 Exhibit 2: Example of how a loan with a modification that failed looks like on the report over time: MILAR Field Data as of Month Modification Activity Example Column in MILAR 169 Removal Code Status Date of Submission Status Date Review Start Date Approval Date Denied Date Failed Date Close Date Effective Date M CP CN CQ CR CT CU CV CW CX Jan Column in MILAR 32 Modification request received & review started H T n/a U n/a n/a n/a n/a n/a n/a /01/ /15/ /15/2012 Feb Modification approved /01/ /01/ /15/ /03/2012 Mar Modification Closed /01/ /01/ /15/ /03/ /01/ /01/2012 Apr Borrower made 1st payment on 4/1/12 May Borrower failed to make 2nd payment /01/ /01/ /15/ /01/2012 Jun Changed workout type to Pre-foreclosure Sale /01/ /01/2012