Making Contact: The Path to Improving Mortgage 

Industry Communication with Homeowners 

A Report on the U.S. Department of the Treasury’s

Guidance on Homeowner Single Point of Contact
 2

Table of Contents

I. Executive Summary.............................................................................................................................. 3

II. Introduction........................................................................................................................................... 5

III. How We Got Here: The Path Towards the Single Point of Contact Requirement.............................. 9

IV. Development of the SPOC Guidance and Its Requirements .............................................................. 13

V. Overview of Servicers’ Implementation of SPOC Guidance ............................................................. 17

VI. Conclusion .......................................................................................................................................... 20

VII. How Each of the Largest Servicers Is Implementing SPOC Guidance .............................................. 23

1. Bank of America, N.A. (Bank of America)........................................................................................ 23

2. CitiMortgage, Inc. (Citi) ..................................................................................................................... 26

3. GMAC Mortgage, LLC (GMAC)....................................................................................................... 28

4. Homeward Residential (Homeward) .................................................................................................. 30

5. JPMorgan Chase Bank, N.A. (Chase)................................................................................................. 32

6. Ocwen Loan Servicing, LLC (Ocwen)............................................................................................... 34

7. OneWest Bank (OneWest).................................................................................................................. 36

8. Select Portfolio Servicing (SPS)......................................................................................................... 38

9. Wells Fargo Bank, N.A. (Wells)......................................................................................................... 40

Appendix A: MHA Guidance Directed at Protecting Homeowners and Improving Communications to 

Homeowners................................................................................................................................. A-1

Appendix B: Glossary..........................................................................................................................................B-1

Appendix C: Excerpt from Q2 2012 Servicer Assessments................................................................................C-1
 3

I. Executive Summary

At the start of the financial crisis, the mortgage servicing industry was ill-equipped to help the overwhelming 

number of homeowners in need of assistance. Servicers’ business models were focused primarily on collecting 

mortgage payments for investors instead of providing customer service to homeowners. Many homeowners 

were not getting the help they needed. There was no standardized process for assisting homeowners, and when 

mortgage modifications did occur, they often increased—not lowered—monthly payments.

To help responsible homeowners avoid foreclosure, the Obama Administration launched Making Home 

Affordable (MHA) in March 2009, which provided a structured framework for mortgage modifications as well 

as financial incentives to encourage modifications. However, in order for the program to succeed, servicers had 

to change their business models. That is why the Department of the Treasury issued a number of requirements 

for servicers participating in MHA—not only to establish standards as to how to make modifications affordable 

and sustainable, but also to improve the customer service relationship between mortgage servicers and 

homeowners. That is also why over a year ago, Treasury required the largest MHA servicers to provide each 

homeowner seeking help through MHA a “single point of contact” (SPOC) who would work with the 

homeowner to avoid foreclosure. The fact that over one million families have received MHA modifications, and 

more than four million additional families have received proprietary modifications, or other loss mitigation 

assistance through the Federal Housing Administration, is in large part because of the cumulative effect of these 

standards in helping to change the industry’s behavior. 

The purpose of this special report is to review the implementation of the SPOC requirement by the largest 

servicers participating in MHA. This report is intended to serve as a basis for a broader discussion on how the 

SPOC requirement can best be implemented for all servicers, not only those participating in MHA, so that 

communication between the homeowner and servicer can be improved from the dismal conditions that marked 

the beginning of the crisis. 

Highlights from the Report

• Through the Single Point of Contact requirement, homeowners now have dedicated personnel that 

will work with them from the beginning to the end of the process to avoid foreclosure. Servicers 

report that they have reorganized their homeowner communication areas and expanded staff capacity.

The nine servicers surveyed for this report now have more than 12,000 individuals whose primary, if not 

sole, responsibility is to communicate with homeowners seeking assistance. Nearly 6,000 other 

personnel are assigned to help SPOCs collect and process documents from homeowners.

• Three primary implementation models have emerged. Of the nine servicers surveyed for this report, 

seven use a “Direct Model” whereby an individual SPOC serves as the relationship manager, one uses a 

“Pod Model” whereby there is a team of SPOCs available to assist the homeowner, and one uses an 

“Appointment-Based Model” whereby a customer service representative takes inbound calls and 

schedules an appointment with the SPOC. Each is described in detail in the body of the report. 

Regardless of the model, SPOC requires servicers to assign homeowners dedicated personnel to work 

with throughout the complex process of resolving their difficulties paying their mortgages.
 4

• Servicers communicate with homeowners in different ways. While all servicers make their SPOCs 

available to homeowners by phone, some also employ email or web-based interaction capabilities. 

Servicers also vary widely in the alternatives offered to homeowners attempting to contact a SPOC who 

is currently unavailable—for example, some use voicemail, while others route the call to another SPOC. 

• There is no standard caseload for SPOCs. Servicers exhibit a wide range in both the target and actual 

number of homeowner cases a SPOC is expected to handle at any given point in time. Across servicers, 

actual caseloads range from 64 to 210 homeowners per SPOC. Servicers are developing different 

methods of calculating SPOC caseload to optimize their effectiveness since not all cases require the 

same level of effort.

• Challenges remain in improving how servicers communicate with homeowners. While the changes 

discussed in this report have begun to improve the likelihood of better outcomes for homeowners, it is 

still too early to tell whether the industry will improve its customer service to the desired level. The 

SPOC model, as applied to mortgage servicing, is still in the process of maturing and there is likely to be 

a dynamic environment, with servicers continuing to experiment with different concepts and new 

promising practices. 

As with many of the servicing standards and homeowner protections developed under MHA, a SPOC 

requirement was also included in the servicing standards agreed to in the National Mortgage Settlement, and a 

similar requirement (referred to as “continuity of contact”) has been included in the servicing standards recently 

proposed by the Consumer Financial Protection Bureau (CFPB). The changes represent a broad effort to 

implement the Obama administration’s Homeowner Bill of Rights. The fact that the National Mortgage 

Settlement and the CFPB, as well as other Federal and state regulators, are adopting similar SPOC requirements 

will help solidify that this new way of ensuring more personalized help for homeowners will continue beyond 

the life of the MHA program. 
 5

II. Introduction

This is a report on actions being taken to improve how mortgage servicers communicate with homeowners who 

are having trouble paying their mortgages. Specifically, it is a report on the implementation of “single point of 

contact” (SPOC), a servicer-homeowner communications standard required by the U.S. Department of the 

Treasury (Treasury) for servicers participating in the Making Home Affordable Program (MHA). 

The issue of how well mortgage servicers communicate with homeowners has been fundamental to our nation’s 

ability to address the housing crisis. The reason is simple: unless mortgage servicers communicate successfully 

with at-risk homeowners, there can be no modification of a mortgage and no path to avoiding a foreclosure. All 

stakeholders concur that the nation’s mortgage industry did a poor job of this at the outset of the crisis. Servicer 

business models were set up to collect payments on loans, not to work collaboratively with distressed 

homeowners and certainly not with the overwhelming volume of homeowners who were struggling to keep up 

with their mortgage payments in 2008 and 2009 as the crisis unfolded. 

There is a basic business reality to the servicing relationship that is at the core of the situation. Homeowners are 

the customers of financial institutions when it comes to products such as checking accounts, savings accounts, 

or trust and advisory services, but, in most cases a mortgage servicer’s customer is the investor who owns the 

loan and not the homeowner. Mortgage servicers have contracts with and fiduciary duties to the investors who 

own the loans. A servicer’s job is to collect payments from homeowners on behalf of those investors. Investors 

can choose which financial institution has the right to service their loans and can transfer their business if 

service levels are unacceptable. Homeowners do not have those rights and until recently, had very few 

opportunities for redress when they received poor customer service. It is not surprising then that many 

struggling homeowners, who tried unsuccessfully to communicate with their servicers, stopped opening mail, or 

responding to phone calls from those servicers. 

In this crisis, when millions of homeowners had trouble paying their mortgages, whether or not servicers were 

able to communicate effectively with homeowners has mattered a great deal. 

In early 2009, Treasury launched MHA, which combined financial incentives and a standardized modification 

structure to encourage homeowners, servicers, and investors to participate in the first nationwide mortgage 

modification program. However, even before MHA there were efforts within government and the mortgage 

industry to develop more effective foreclosure prevention options and educate homeowners about those options. 

As early as 2005, a coalition of mortgage servicers and housing counselors founded the non-profit 

Homeownership Preservation Foundation (HPF), which established and continues to operate the Homeowner’s 

HOPETM Hotline, a toll-free phone resource for homeowners who are having trouble making their mortgage 

payments. Over the years, millions of homeowners who have called the HOPE Hotline have received free 

foreclosure prevention assistance from housing counselors approved by the U.S. Department of Housing and 

Urban Development (HUD). When Treasury was looking for a way to make information about MHA available 

to the public, it recognized the important resource that HPF provided and contracted with HPF to expand the 

HOPE Hotline to include screening for MHA eligibility.
 6

In 2007, then Treasury Secretary Henry Paulson and HUD Secretary Alphonso Jackson worked with key 

industry leaders to create the HOPE NOW Alliance, a voluntary coalition of nearly 30 mortgage servicers who 

mutually agreed to increase the volume and effectiveness of mortgage modifications through sharing of data 

and best practices, development of new technologies, sponsorship of homeowner outreach events and other 

strategies. Most servicer members of the HOPE NOW Alliance also eventually became participants in MHA. 

Also, in 2007, the National Foreclosure Mitigation Counseling (NFMC) Program was launched with funding

appropriated by Congress to address the nationwide foreclosure crisis by dramatically increasing the availability 

of housing counseling for families at risk of foreclosure. NeighborWorks America was chosen by Congress to

administer the NFMC program. Since that time, Congress has provided annual appropriations totaling $620 

million.

In July 2008, the second largest bank failure in history occurred when the Federal Deposit Insurance 

Corporation (FDIC) seized the assets of IndyMac. This California-based lender had massive mortgage defaults 

and its homeowners needed immediate help. The FDIC created a standard mortgage modification program that 

required limited homeowner data to complete a modification. The program, which because of its streamlined 

nature became known as “Mod in a Box” was extended to all FDIC-regulated entities in November of 2008.

While these, as well as other efforts by cities and counties to implement local mediation programs and 

foreclosure prevention taskforces, laid the foundation for a nationwide modification policy, the pace of 

modifications to struggling homeowners was slow by the time President Obama took office. When mortgage 

modifications did occur, they often increased—not lowered—monthly payments. MHA was launched in an 

environment where there were few – if any – standards regulating how servicers interacted with delinquent 

homeowners. As MHA was implemented, it became apparent that critical changes had to be made in the way 

that mortgage servicers contacted and worked with struggling homeowners.

Treasury spent a good portion of 2009 and 2010 designing and refining requirements that defined how MHA 

participating servicers should communicate with homeowners. These requirements covered such topics as early 

intervention, minimum outreach standards, limitations on dual tracking loss mitigation and foreclosure actions, 

written notices regarding eligibility, ability to request an independent review of servicer decisions, and 

opportunities for escalation of homeowner complaints. These innovative requirements were intended to provide 

struggling homeowners with a fair opportunity to understand their options and be evaluated for assistance.

Treasury reinforced the importance of homeowner communication by implementing compliance efforts to 

determine how effectively servicers implemented these requirements and requiring servicers to improve where 

necessary. As a result, today the largest servicers demonstrate that they are able to make contact and evaluate 

the vast majority of homeowners who are eligible for assistance. Homeowners who receive assistance under 

MHA show a high likelihood of long-term success in avoiding foreclosure. 

These actions helped create standards for mortgage modifications and protections for struggling homeowners 

that had not existed before. While these actions gave rise to many improvements in the industry’s behavior, as 

time went on, it became clear that even more was required. 

In May 2011, Treasury issued Supplemental Directive (SD) 11-04 requiring the largest servicers participating in 

MHA to implement a SPOC homeowner communication model, and to assign a SPOC to each homeowner

potentially eligible for MHA to work with the homeowner through the entire application and resolution 
 7

process.1 The SPOC SD became effective on September 1, 2011 and November 1, 2011, for new and existing 

loss mitigation cases, respectively.

This report is intended to provide an overview of how and why the SPOC guidelines came about and describe 

the implementation of those guidelines by the nine largest MHA servicers of non-GSE loans.

2 Treasury 

collected data for this report through a survey of the nine largest MHA servicers, through discussions with 

servicer personnel, and through observation of performance within the MHA program.

3 The report constitutes 

the most descriptive source of information available on non-GSE servicer implementation of SPOC and serves 

as a snapshot of the approaches being taken across the industry.

The report covers:

• The evolution of MHA servicing standards and the challenges Treasury guidance sought to address;

• A summary of the main requirements of MHA SPOC guidance;

• A general overview of the implementation of the SPOC guidance as reported by the largest MHA servicers;

• An assessment of the servicing industry’s progress in developing best practices for SPOC and a suggested 

framework for future research on the effectiveness of servicers’ implementation of SPOC guidance; and

• Specific descriptions of how each of the largest MHA servicers has implemented the SPOC guidance.

The purpose of this report is to shine a spotlight on SPOC, and to create a more informed public discourse on 

the issues of how the mortgage industry assists struggling homeowners. It is equally important to note what this 

report does not cover:

– It is not a report that offers a conclusion on the best way to implement SPOC. As discussed in the report,

industry participants have created a wide range of approaches. It is vital to evaluate what works and that 

evaluation will benefit from time and experience with the various models. This report seeks to advance that 

effort by outlining the approaches to date as well as some of the questions that will need to be asked and 

debated. There may not be one “right” answer.

– This report is not an audit, or an assessment of how well servicers comply with MHA guidance. Treasury has 

been evaluating servicer compliance with these guidelines, and the results from those compliance reviews 

have been included in the quarterly MHA Servicer Assessments as part of the metrics evaluating servicer 

internal controls for the MHA program.

– This report offers a description rather than an evaluation. Much of the information in this report is based on 

each servicer’s description of how its model is supposed to work. Whether a given model does in fact work as 

 1 SD 11-04 was fully incorporated into Chapter I, Section 4 of the Making Home Affordable Program Handbook for Servicers of Non-GSE Mortgage (the 

“Handbook”). 2 Bank of America, NA; CitiMortgage Inc.; GMAC Mortgage, LLC; Homeward Residential; JPMorgan Chase, NA; Ocwen Loan Servicing, LLC; OneWest Bank; 

Select Portfolio Servicing; and Wells Fargo Bank, NA. 3 Survey data as reported by the servicers as of March, April, and May 2012. Survey data is reported on an aggregate level by servicers. Therefore, it is not subject to 

the same data quality checks as transactional data reported into the Home Affordable Modification Program (HAMP) system of record. 
 8

designed is obviously of critical importance. For now, a report on how the models are designed will help the 

public—as well as other governmental agencies that have an interest in these matters— judge whether they 

are in fact working. 

The purpose of this report is therefore to give as much clarity as possible on a major operational change being 

made by servicers in the way they interact with struggling homeowners. The report is designed to identify the 

issues and questions that must be examined in order to make sure this change succeeds within MHA and more 

broadly.

There are a number of questions with respect to SPOC that are yet to be answered. As discussed later, these 

questions include the timing of SPOC assignment, SPOC caseloads, how SPOCs communicate with 

homeowners, and SPOC compensation and career path. Although it is outside the scope of this report, the 

advent and maturation of SPOC in the servicing industry may also play a role in, and be affected by, a broader 

conversation about changes in the overall servicing industry as well as the methods by which servicers are 

compensated.

While answers to those questions may not yet be clear, what is already clear is that SPOC—together with other 

complementary steps taken to reform servicer behavior—is having an impact on servicers’ capacity to 

communicate with struggling homeowners. The survey data collected for this report indicate that the nine 

servicers in this report have more than 12,000 individuals whose primary, if not sole, responsibility is to 

communicate with and assist homeowners seeking home retention solutions and other foreclosure alternatives, 

with another 6,000 in roles supporting the SPOCs. While not all of this capacity is new, SPOC guidance is 

widely understood by servicers to have vastly increased their capacity for communicating and assisting 

homeowners.

Finally, there is an important caveat on language and terminology. A certain amount of terminology specific to 

the servicing industry is used—terms such as “right party contact,” “homeowner entry point,” and “warm 

transfer,” for example. The report uses the industry terminology for the sake of clarity and efficiency in 

describing and comparing these different models and includes a Glossary of Terms in Appendix B that provides 

plain English definitions of these terms. Readers should keep in mind, however, that underlying this technical 

terminology—which often sounds sterile and cold—is the critical issue of how servicers communicate with 

homeowners struggling to retain their homes. That is one of the most difficult, emotional, and traumatic issues 

any family can face, and the language should not cause us to forget that. The intent of SPOC is to ensure that 

these homeowners receive the best possible outcome as expeditiously as possible.
 9

III. How We Got Here: The Path Towards the Single Point of Contact Requirement 

In early 2009, the U.S. economy was facing the fallout from a housing bubble that by some measures had 

doubled home prices in a period of six years. Delinquency rates had risen significantly, resulting in a backlog of 

seriously delinquent loans as a consequence of the inability of servicers to manage the unprecedented volume of 

defaults. Foreclosures were increasing, yet policy response up until then had been limited, largely leaving it to 

the private sector to decide when a foreclosure or modification was appropriate. During this time, many 

modifications weren’t even reducing homeowner payments. 

In the spring of 2009, Treasury introduced MHA, a program designed to help struggling homeowners obtain 

more affordable mortgages and thereby prevent avoidable foreclosures.

4 MHA was funded through the 

Troubled Asset Relief Program (TARP), under which Treasury was legally authorized to develop certain types 

of programs to assist struggling homeowners, but it did not have the authority to establish a mandatory 

modification program. Consequently, Treasury established a voluntary program, and encouraged mortgage 

servicers representing the vast majority of the industry to participate. In announcing the components of MHA—

most notably the Home Affordable Modification Program (HAMP)—Treasury sought to provide a structured 

plan for affordable and sustainable mortgage modifications that participating servicers would adopt as their first 

response for homeowners who had experienced a financial hardship. Under HAMP, servicers receive financial 

incentives in recognition of the additional staff and administrative expenses involved in gathering 

documentation, underwriting, and processing modifications necessary to help at-risk homeowners. At the time 

the program was launched, there were no comprehensive servicing standards or homeowner communication 

guidance. 

Designing a program to improve the affordability of mortgages for responsible homeowners was challenging 

particularly because of the nature of the mortgage industry at that time: mortgage servicers were simply 

unequipped to manage the magnitude of the crisis before them. The servicers were structured and staffed to 

perform a limited role: collecting payments on mortgages and managing delinquencies based on historical levels 

using traditional approaches. They did not have the systems, staffing, or operational capacity to engage with 

homeowners on a large scale and offer meaningful relief from unaffordable mortgages. Indeed, as Treasury5

conducted its initial reviews of servicer performance, it became clear that servicing organizations were 

significantly challenged in implementing MHA and in communicating with delinquent homeowners in a timely 

and efficient manner. Treasury observed that servicer response to delinquent homeowner communication was 

often compartmentalized based on factors such as length of delinquency, cause of the hardship, investor type, 

loan type, and geographic location. Additionally, in large to mid-sized servicing organizations, separate teams 

or departments handled different aspects of default servicing (e.g., collections, bankruptcy, repayment plans, 

modifications, short sales, foreclosure processing) with communication among these teams frequently 

ineffective or non-existent. Moreover, these teams often lacked adequate technology to easily share data or 

provide effective homeowner communications either orally or in writing.

 4 http://www.treasury.gov/press-center/press-releases/Pages/tg33.aspx 5 Treasury has engaged Freddie Mac as the Compliance Agent. Freddie Mac has created an independent division, Making Home Affordable Compliance (MHA-C), 

which works with Treasury, for this purpose.
 10

Thus, during the early months of the housing crisis, many homeowners who tried to get help had difficulty in 

dealing with their servicers. They typically had to work with multiple servicer employees across different 

departments and locations to obtain help, with no assurance that any single individual knew all aspects of their 

situation. Typically, there was no single servicer representative that was capable of explaining available 

foreclosure prevention options or that had responsibility for ensuring that homeowners received the help 

appropriate for their circumstance. 

In addition to the observations from Treasury’s compliance activities, there were frequent homeowner 

complaints and reports from homeowner advocacy organizations that:

• Homeowners were unable to locate an informed representative at the servicer who could assist them in 

completing required documents or who could verify that the documents had been received.

• Homeowners were directed to a different servicer representative each time they called for assistance 

and, each time, were required to begin again with their request for assistance because the new 

representative could not access notes from prior conversations. Homeowners reported that they were 

often required to submit multiple copies of the same documents or were denied assistance because the 

servicer could not find documents that had previously been provided. 

• Homeowners frequently received contradictory oral or written policy information from different servicer 

representatives and information that was not consistent with published HAMP program requirements.

• Homeowners were concurrently offered modification assistance from one department while receiving 

foreclosure notices from another. 

This confusing experience increased homeowner frustration and slowed down the pace of modifications. It 

discouraged many from even seeking help. 

Many who tried to help homeowners—such as Congressional staff, housing advocates, and counselors—also 

became frustrated and pushed for creation of an Office of Borrower Advocacy, independent of all regulators 

and empowered to direct servicers to stop foreclosures. Eventually, in 2010, the Dodd-Frank Wall Street 

Reform and Consumer Protection Act (Dodd-Frank Act) created such a function within the new Consumer 

Finance Protection Bureau (CFPB). However, Treasury, realizing that it would be many months before the 

newly formed bureau could effectively provide this needed homeowner assistance, reconfigured the existing 

HOPE hotline to provide a direct and effective means for MHA homeowners to reach a Treasury advocate 

empowered to interact with servicers on their behalf. Additionally, MHA participating servicers were required 

to establish internal escalation offices independent of the servicing staff who make foreclosure prevention 

decisions. 

To ensure adherence to these new customer care requirements, Treasury launched a compliance effort to 

examine what servicers were doing on a daily basis. Compliance activities consisted of both on-site and off-site 

reviews of servicers’ compliance with MHA requirements, which ranged from examining servicers’ internal 

controls and processes to reviews of individual loan files. As issues were identified, Treasury required 

participating servicers to take remedial action at two levels. First, servicers were required to identify 

homeowners who had been affected by a particular problem, correct any errors, and re-evaluate the 

homeowners for assistance under MHA. Second, servicers were directed to correct the underlying process and 

improve internal controls to ensure that the weaknesses that gave rise to the initial errors did not recur.
 11

While Treasury did not have regulatory authority over the servicing industry or particular servicers, it could 

issue guidance defining servicers’ responsibility to communicate with homeowners potentially eligible for 

HAMP and other MHA foreclosure prevention options, as part of the terms of the program. 

Throughout the life of MHA, Treasury has continued to define specific actions participating servicers must take 

to reach out and work with struggling homeowners. Specifically, in the fall of 2009, Treasury defined standard 

time frames within which servicers must respond to homeowner inquiries regarding eligibility for a 

modification and also established requirements regarding the format, content, and timing of notices that are sent 

to homeowners regarding their HAMP modifications. In January, and again in March 2010, Treasury provided 

additional guidance to servicers regarding how to acknowledge receipt of homeowners’ modification packages, 

defined the reasonable actions a servicer must take to make contact with a homeowner who has missed more 

than two mortgage payments, and established additional protections regarding when a loan could be referred to 

the foreclosure process or a foreclosure sale. In the fall of 2010, Treasury issued guidance for addressing and 

resolving homeowner complaints regarding their modification, and provided additional guidance in March 2011 

on homeowner case escalations. That same month, Treasury also established the homeowner net present value 

(NPV) calculator (at CheckMyNPV.com) to independently validate the inputs used by servicers in making 

MHA decisions. Each of these steps resulted in incremental improvements in the homeowner experience under 

MHA.

As a result of these policies, servicers are now required to:

• Proactively contact delinquent homeowners early in the delinquency when it is most likely they will be 

eligible for assistance;

• Abstain from referring a loan to foreclosure or conducting a foreclosure sale while a homeowner is 

actively working with the servicer on a MHA foreclosure prevention option to resolve the delinquency;

• Use standard, plain-language homeowner notices and adhere to Treasury timelines for collection of 

income verification documents;

• Provide written notices to homeowners who are evaluated and determined to be ineligible for a 

modification that includes all the data used to make the decision and allow the homeowner 30 days to 

request an independent review of most denial decisions before holding a foreclosure sale;

• Certify in writing that all foreclosure prevention options have been exhausted before they can hold a 

foreclosure sale;

• Establish a defined process for resolution of homeowner complaints that for all large and mid-sized 

servicers must be separate from the staff evaluating the homeowner for a modification; and,

• Provide each delinquent homeowner who asks for help with a single point of contact who is responsible 

for coordinating all servicer efforts to help the homeowner.

While these changes are many in number and have a cumulative effect, the most significant single change is the 

implementation of the SPOC requirements. Attached as Appendix A is a chronology of the specific homeowner 

protections and communications guidance issued by Treasury over the last three and a half years.

Technically, these standards applied only to mortgages eligible for MHA, and many mortgages fell outside that 

eligibility pool. Because Treasury required servicers to consider any mortgage that failed to qualify for MHA 

for other loss mitigation options before proceeding with foreclosure, the standards helped change servicer 

behavior more generally.
 12

Just as the standards developed in MHA concerning how to make mortgage modifications sustainable—for

example, the debt-to-income standards and NPV model—were subsequently adopted widely in the industry, so 

too were many of these customer care and communication servicing standards. Over time, the body of guidance 

issued to enhance the effectiveness of MHA was subsequently used by other industry stakeholders as source 

material in developing other industry standards and guidance. The servicing requirements included in the 

National Mortgage Settlement between the five largest national servicers, HUD and the Department of Justice,

and 49 State Attorneys General in settlement of mortgage servicing deficiencies drew heavily on MHA 

servicing standards.6 Most recently, the CFPB—which was given the responsibility to develop standards on 

homeowner outreach under the Dodd-Frank Act—used MHA guidance as a reference in creating its proposed 

rulemaking that, when published as final regulations, would apply to all mortgage servicers.

In 2011, Treasury began publishing quarterly compliance assessments on the largest servicers participating in 

MHA. Using a variety of compliance metrics, the reports reflect the level of servicer compliance with specific 

MHA guidelines. These reports are based on the extensive compliance reviews conducted by Treasury’s 

compliance agent, which involve thousands of loan file reviews and multiple internal control reviews on-site at 

servicers. The metrics include the accuracy of a servicer’s determination of whether a homeowner qualified for 

assistance under MHA as well as the accuracy of the servicer’s calculation of a homeowner’s monthly income, 

a central input in determining eligibility as well as an accurate modification payment. The assessments also 

include reviews of internal controls regarding processes for contacting and working with homeowners as well as 

reporting modifications properly. Treasury has withheld payment of servicer incentives where a servicer was 

deemed to be in need of substantial improvement until specified improvements were made. The assessments are

also coupled with measurements of performance in several additional areas, such as how timely servicers are in 

assisting eligible homeowners, servicer effectiveness in modifying eligible mortgages, time needed to resolve 

homeowner complaints, and timely reporting of modification activity. 

The publication of these assessments brought a much needed public spotlight on servicer behavior. It also 

attracted the attention of the senior management of servicers. As a result, servicer performance in HAMP has 

improved significantly. The compliance assessments include charts showing how performance on the 

designated metrics has improved over time, which are included in Appendix C.

 6 Press release issued by the U.S. Department of Justice: http://www.justice.gov/opa/pr/2012/February/12-ag-186.html
 13

IV. Development of the SPOC Guidance and Its Requirements

With the evolution of MHA servicing standards, communication between servicers and homeowners applying 

for mortgage relief improved in the areas of proactive outreach to newly delinquent homeowners and resolution 

of homeowner complaints related to denials, especially as it pertained to the MHA process. However, more 

progress was still needed. Homeowners and many housing advocates continued to report challenges with the 

application process. They continued to report requests for assistance and homeowner income documents were 

lost and that homeowners seldom spoke to the same servicer representative or one who was knowledgeable 

about their situation, requiring them to repeat or re-send information. Many stakeholders began to call for

servicers to provide one designated servicing representative for delinquent homeowners, similar to the model 

widely used in loan originations, where a prospective homeowner interacts with a single individual (the loan 

officer) when obtaining a mortgage.

In early 2011, Treasury began discussing options for a single point of contact concept with other key 

stakeholders and constituencies, including Fannie Mae and Freddie Mac (the Government Sponsored 

Enterprises or GSEs) and their conservator the Federal Housing Finance Agency (FHFA); other Federal 

banking regulators and housing agencies including HUD; representatives of homeowner advocacy 

organizations; and large and mid-sized servicers participating in MHA.

Over a period of months, through discussions, face-to-face meetings and shared draft guidance, Treasury sought 

input on a number of key points including: 

• When a SPOC should be assigned and when the SPOC’s responsibility with respect to a homeowner 

should end; 

• Whether the SPOC must be an employee of the servicer or whether the role could be performed by a 

contractor;

• The format and timing of notifications to the homeowner about the identity of the SPOC or any changes 

in SPOC assignment necessitated by employee departures or transfers; 

• The specific responsibilities of the SPOC and whether these responsibilities must only be completed by 

a single individual or could be completed by any member of a team; 

• Whether the SPOC should have the authority to stop a pending foreclosure or should be consulted prior 

to a foreclosure sale; and

• The impact of this requirement on servicer operations, staffing, and systems.

At the same time, the Office of the Comptroller of the Currency (OCC) was preparing to issue consent orders to 

a number of large banks under its supervision to address inappropriate foreclosure practices. The consent orders 

would eventually include a requirement to establish “an easily accessible and reliable single point of contact for 

each borrower,” although the OCC did not provide in-depth guidance on implementation.

7

The GSEs elected not to issue unique Fannie Mae or Freddie Mac SPOC requirements, but instead leveraged 

requirements of other agencies by stating that if a servicer of GSE loans was obligated by virtue of regulatory 

orders or contract compliance (via MHA), to implement a SPOC program, the same requirements would apply 

to all loans serviced for the GSEs.

 7 Press release issued by the OCC: http://www.occ.gov/topics/consumer-protection/foreclosure-prevention/correcting-foreclosure-practices.html
 14

Treasury published its guidance containing the SPOC requirements in May 2011. The guidance provides 

comprehensive standards that reflected the input received from the diverse stakeholders who were consulted. 

The twenty largest MHA servicers are required to adhere to these standards, and all other MHA servicers are 

encouraged to implement the guidance.8 

Under the SPOC guidance:

• Servicers must assign a SPOC to a delinquent homeowner, or a homeowner who requests consideration 

under imminent default, immediately upon successfully establishing contact with the homeowner, known as 

right party contact (RPC), and when it is determined that the homeowner may be eligible for any of the 

following MHA programs: HAMP, the Home Affordable Unemployment Program (UP), or the Home 

Affordable Foreclosure Alternatives Program (HAFA);

• The assigned SPOC must work with the homeowner until all available home retention and other nonforeclosure options, such as a HAFA short sale, have been exhausted;

• If a loan is subsequently referred to foreclosure, the SPOC must be available to respond to homeowner

inquiries regarding the status of the foreclosure and must have immediate access to those who can stop 

foreclosure proceedings where appropriate;

• Servicers must make available an independent escalation team to receive and address homeowners concerns 

regarding the process or their evaluations; and

• Servicers must develop effective processes for assisting homeowners whose primary language is not 

English.

Once the servicer has assigned a SPOC to a homeowner, the SPOC is responsible for all actions taken by the 

servicer to resolve the homeowner’s delinquency or imminent default. The SPOC must:

• Promptly contact the homeowner and provide written notice to the homeowner within five business days of 

being assigned. The notice must include a toll-free contact number for reaching the SPOC directly, other 

contact options, and the preferred method for sending documents to the servicer;

• Communicate all options available to the homeowner and the actions the homeowner must take to be 

considered for these options;

• Track all documents so that the homeowner won’t be required to re-submit documents and to ensure that the 

homeowner is notified promptly of any need for additional documents; 

• Respond to inquiries, be knowledgeable about the homeowner’s current status, and communicate 

underwriting decisions on modification requests;

• Coordinate with other servicer personnel responsible for ensuring that a homeowner not eligible for MHA is 

considered for other foreclosure prevention options; and

• Be properly trained, have appropriate caseloads, and be supported by others in the organization who can 

fulfill these responsibilities when the homeowner’s assigned SPOC is unavailable.

Differences in servicers’ organizational structure and size, investor base, technology, and the size and 

characteristics of their servicing portfolios have resulted in SPOC implementation plans that differ in certain 

specifics while attempting to meet the overall objective of improved homeowner-servicer communication. This 

 8 As used in this report, the term “MHA servicers” means servicers of non-GSE mortgages participating in MHA.
 15

report describes how the largest servicers are implementing SPOC in order to provide industry stakeholders, 

researchers, the public, and other interested parties with a deeper understanding of how SPOC is being 

implemented and how it may be affecting the experience of homeowners applying for help through MHA. As 

mentioned at the outset, it does not attempt to assess the relative merits or effectiveness of each servicer’s 

implementation, nor the level of compliance with MHA guidelines in each servicer’s SPOC implementation and 

effectiveness.

9

The reasons for the focus on describing, rather than evaluating the merits of, servicers’ SPOC implementations 

are straightforward. SPOC represents a significant operational and conceptual shift for the servicing industry as 

a whole; one that a number of stakeholders believe will improve customer service for homeowners. Servicers’ 

descriptions to Treasury of their SPOC implementation show that when presented with the same general 

challenge, industry participants have attempted to create a wide range of solutions. As discussed in the 

Conclusion to this report, it is unlikely that there is one “right” answer to this challenge, and if there is, it is far 

too early to determine its nature. Thus, the focus is to provide a view into the different solutions to this common 

problem, and to identify the key questions and issues that must be considered in evaluating these solutions, in 

order to help further the dialogue among interested parties.

The chart below provides a generic, high-level overview of what the prior interaction between homeowners and 

servicers used to be compared to what the SPOC guidance now requires. It is a general depiction of what should 

occur in the interactions between the SPOC, the homeowner, and other key groups within the servicing 

organization. It is not a depiction of any particular servicer’s operation.

 9 Treasury publishes quarterly Servicer Assessments for the servicers included in this White Paper. Results from reviews of servicers’ SPOC implementation are 

factored into the Servicer Assessments.
 16
 17

V. Overview of Servicers’ Implementation of SPOC Guidance

The survey data collected for this report indicate that following SPOC implementation, servicers have made 

significant changes in how they communicate with homeowners seeking assistance. Among the nine largest 

MHA servicers, there are now over 12,000 individuals whose primary, if not sole, responsibility is to 

communicate with and help homeowners seeking home retention solutions and other foreclosure alternatives—

with nearly another 6,000 assigned to helping SPOCs with document collection and processing. While not all of 

this capacity was added since the policy became effective, the MHA guidance and other federal actions are 

widely acknowledged by the servicers to have significantly increased their capacity in this regard.

For the largest servicers, compliance with MHA’s SPOC guidance is mandatory. However, servicers have

flexibility in how they implement SPOC guidance, and, as noted above, servicing organizations have taken 

different approaches in integrating the SPOC guidance into their systems and processes for engaging 

homeowners. Thus, in implementing the SPOC guidance, servicers have adopted approaches that have a 

number of common elements, as well as significant differences.

Common Elements and Differences

Based on the surveys and interviews conducted by Treasury in connection with this report, the similarities in the 

models developed by servicers include the following:

• Homeowners are assigned a single identified individual or small team of individuals responsible for 

assisting the homeowner in preparing the necessary documents needed to evaluate a request for a 

modification and for communicating decisions;

• Homeowners are provided with multiple channels by which they can correspond with the SPOC or SPOC 

team (e.g., telephone, email);

• Homeowners’ SPOCs are expected both to handle incoming calls from homeowners and to initiate outbound 

calls to homeowners, as circumstances warrant; 

• SPOCs are responsible for discussing liquidation options (short sale or deed-in-lieu of foreclosure) with 

homeowners in the event a home retention option is not feasible, with the SPOC remaining as the primary or 

secondary point of contact for the homeowner for 30 to 60 days after the close of the short sale or the 

foreclosure process.

• There are programs to provide training for SPOCs, benchmarks for managing SPOC caseloads, and 

performance metrics to measure SPOC effectiveness.

At the same time, survey data indicate differences among the largest servicers in the following:

• SPOCs’ roles and responsibilities vary by servicers. SPOCs at some servicers, for example, are solely 

responsible for communication with the homeowner, relying on support teams for document processing and 

preparing the modification package for underwriting, while at other servicers the SPOCs are involved in 

most aspects of the evaluation process, including document collection and processing. Some servicers also 

have the SPOC lead the discussion regarding short sale or deed-in-lieu options, while other servicers 

dedicate short sale staff to work with the homeowner with the SPOC in a support role.

• One servicer assigns homeowners to a “SPOC team” rather than a specific individual.

• There is a wide range in both the target and actual number of homeowner cases the SPOC is expected to 

handle at any given point in time. This appears to be largely a function of organizational structure and the 
 18

roles and responsibilities of the SPOC—actual caseloads at servicers range from 64 to 210 homeowners per 

SPOC. Servicers continue to develop different methods of calculating SPOC caseloads to set appropriate 

targets, in some instances recognizing that different types of cases require different levels of effort.

• There are differences in the alternatives offered to homeowners attempting to contact a SPOC who is 

currently unavailable (e.g., voicemail, routing the call to another SPOC, etc.).

• The metrics by which SPOC performance is measured appear to vary widely, with servicers measuring 

traditional call center metrics such as volume of calls and call abandonment rates, as well as newer metrics 

such as the average number of days from the receipt of the first document from the homeowner to 

completion of the full modification request package, or the number of loss mitigation resolutions achieved 

per SPOC. 

It is important to understand the different ways in which servicers begin the process of working with a 

struggling homeowner and their various homeowner (or customer) relation models. These are summarized 

below, based on the information provided by the servicers during the surveys and interviews conducted. (The 

discussion below employs the servicing industry convention of referring to homeowners as “customers,” even 

though, as noted previously, it is investors who are, in some fundamental respects, the true customers in the 

servicing industry’s current business model). 

How the SPOC Process Begins

For the largest servicers, the SPOC process begins for a typical homeowner through a collections team or 

customer service representative. This occurs either when a homeowner calls the servicer to discuss his or her 

situation or a collections team initiates outbound calls and other solicitations to the homeowner. Upon 

establishing RPC, the servicer conducts a preliminary evaluation of the homeowner’s situation and, if 

appropriate, sends the loan modification application package to the homeowner. In some cases, the collections 

team begins collecting some or all of the required documents.

At this point, homeowners who require further payment assistance are assigned to a SPOC through a system 

transfer, a “warm” transfer, or an appointment-based transfer. The SPOC representative will explain the 

servicer’s processes for resolving delinquent loans, discuss different options that are available for the 

homeowner, answer any questions the homeowner might have, and establish the best times and methods for 

communicating with the homeowner moving forward.

In a system transfer, the homeowner is told by the collection agent that a SPOC will be assigned and that the 

SPOC will return the homeowner’s call within a set timeframe. The SPOC is then assigned to the homeowner 

automatically by a workflow system or other automated technology, often through a batch process at the end of 

the business day. Under this method, all new homeowner contacts received during the day are grouped together 

and then assigned to a SPOC based on current caseloads to ensure even distribution across the different SPOCs 

or SPOC teams. At the start of the next day, SPOCs receive their new assignments and are expected to reach out 

to the homeowner within a set timeframe.

A “warm” transfer, on the other hand, occurs when the collections agent is still in contact with the homeowner.

With the homeowner still on the phone, the collections agent reaches out to the first available SPOC and 

initiates a conference call between the homeowner, collections agent, and the SPOC. 
 19

In an appointment-based transfer, the customer service representative schedules an appointment time for the 

homeowner to speak with the assigned SPOC. The assigned SPOC will then contact the homeowner at the date

and time specified in the appointment.

Customer Relationship Models

There are generally three types of customer relationship models employed by the largest MHA servicers: the 

Direct Model, the Pod Model, and the Appointment-Based Model. 

SPOC Direct Model

The most common model is the SPOC Direct Model, in which the servicer assigns the homeowner a SPOC who 

is responsible for all inbound and outbound communications with that homeowner and for ensuring that an 

appropriate loss mitigation solution is reached. Seven of the servicers (Bank of America, CitiMortgage, GMAC 

Mortgage, Homeward Residential, JPMorgan Chase, Select Portfolio Servicing, and Wells Fargo Bank) 

surveyed for this report have adopted this general model. Within this group, however, servicers have adopted 

different approaches for handling homeowner communications when the SPOC is not available or assisting 

another homeowner. Some servicers use voicemail while others route the call to other available members of the 

SPOC’s team or to another available SPOC. Even in situations where voicemail is used as the first choice for 

the caller, homeowners always have the option to request to speak to the next available SPOC.

SPOC Pod Model

One MHA servicer surveyed, OneWest Bank, uses a SPOC Pod Model. Under this model, a homeowner is not 

assigned to an individual SPOC, but is instead assigned to a SPOC team (referred to as a “pod”). The name of 

the manager of the team will be provided to the homeowner as his or her assigned SPOC, but when the 

homeowner calls, any available team member can take that call. Processors and underwriters are assigned to the 

team to provide assistance when dealing with specific customer homeowner questions or issues. One of the 

stated goals of the Pod Model is to increase the likelihood that homeowners calling the servicer will reach a live 

agent who can immediately answer the homeowner’s questions or otherwise assist them. A homeowner is also 

given the option of speaking to a specific individual on the SPOC team (often one with whom he or she has 

recently spoken) or, if that individual is unavailable, scheduling an appointment for a return phone call. 

SPOC Appointment-Based Model

Another customer relationship model employed by one servicer, Ocwen Loan Servicing, is the SPOC 

Appointment-Based Model. In this model, a customer service representative acts as an intermediary to receive 

in-bound calls from homeowners and to schedule an appointment time for the homeowner to speak to the 

homeowner’s SPOC. Customer service representatives are also available to answer simple questions that the 

homeowner might have about the process, although they are generally not in a position to answer questions 

about a homeowner’s specific situation. This model seeks to ensure that the homeowner is always able to reach 

a live agent with little or no delay, and that when the homeowner holds the scheduled appointment with the 

SPOC, the homeowner will be better prepared for the conversation (including compiling any necessary 

documentation in advance) as a result of the discussion held at the time the appointment was scheduled.
 20

VI. Conclusion

While SPOC is not a new concept in loan servicing, never before has it been the focus of such broad attention in 

the mortgage servicing industry. A number of stakeholders in addition to mortgage servicers and Treasury—

including the Federal banking regulators, the CFPB, HUD, and the parties to the National Mortgage 

Settlement—are now examining the ways servicers interact with homeowners seeking assistance, especially 

those homeowners who have fallen behind on their payments. 

Since the launch of MHA in the spring of 2009, servicers have invested significant resources in changing their 

organizational structures, technology systems, and workflows, as well as enhancing training for their 

employees, in order to change the way they engage with struggling homeowners. While these changes are many 

in number and have a cumulative effect, the most significant single change is the implementation of the SPOC 

requirements. The totality of these changes has resulted in better outcomes for homeowners, but it is still too 

early to tell whether the industry will improve its customer service to the desired level.

While SPOC guidance has led to the creation of significant new capacity for communicating with 

homeowners—including over 12,000 SPOCs and another 6,000 personnel assigned to helping SPOCs—the 

SPOC model, as applied to mortgage servicing, is still in the process of maturing. As the details communicated

in this report demonstrate, SPOC implementation models are varied. Furthermore, there are still areas of debate 

related to SPOC requirements which have been articulated by the various federal stakeholders that have yet to 

be resolved. 

Discussions on the best ways to put the SPOC concept into practice will likely continue for some time. As 

MHA winds down, other federal and state agencies will continue to examine servicing practices and may 

promulgate SPOC-related standards. There is likely to be a dynamic environment, with servicers continuing to 

experiment with different concepts and new promising practices. It is unlikely that one “best model” will 

emerge as differences in servicer organizations, homeowner and loan characteristics, and the ongoing evolution 

of regulatory requirements and new technologies will encourage different approaches to the same core issue—

improved homeowner communications.

While the process is still too new to support definitive conclusions about the impact of SPOC implementation 

on improving the homeowner experience, servicers believe that the preliminary information they have received 

from their homeowner satisfaction surveys shows positive trends that they attribute to SPOC. However, 

independent analysis over time will be necessary to make any definitive conclusions. The information collected 

for this report provides a description of the practices, timelines, and operations of the SPOC process at the nine 

largest MHA servicers that can serve as a starting point for that evaluation. 

There are several issues and areas that merit additional review, including:

• SPOC Effectiveness: What are the appropriate metrics for measuring the effectiveness of SPOC? For 

example, can SPOC effectiveness be measured by looking at:

• Time from Right Party Contact to loss mitigation decision?

• Percentage of SPOC assignments that result in home retention or other outcomes that prevent 

foreclosure?

• Numbers of escalated complaint calls?
 21

• Customer satisfaction scores?

• Internal efficiencies and employee satisfaction?

• SPOC Assignment Timing: Servicers have slightly different methodologies for assigning SPOCs, 

ranging from the moment of RPC to after receipt of all or part of a loss mitigation application. How does 

the timing of SPOC assignment affect homeowner outcomes and service levels?

• SPOC Staffing and Caseload: What is the optimal level of staffing in the SPOC function, and what 

are the drivers that determine optimum case load? The number of homeowners is clearly one driver, but 

loan characteristics, status, use of technology, organizational structure and the specific responsibilities 

the SPOC is required to perform are others. “Optimal” case load is highly dependent on these factors 

and may be difficult to determine. 

• SPOC Communications: Servicers have different methods of communication between SPOCs and 

homeowners. All servicers employ phone and mail, but some also use secure email, texting, secure web 

sites, and other technologies. Some of these differences are operational in nature, while others derive 

from differing perceptions of risk. Many servicers consider “contact rates” to be one of their major 

challenges. “Contact rate” is the percentage of time the homeowner reaches the assigned SPOC when 

they call the servicer, and these are lower than many servicers prefer. Electronic communication such as 

email and text are ways that servicers could potentially improve contact rates, however some servicers 

are particularly concerned about legal and compliance risks that might result from allowing SPOCs to 

rely on email communications.

• SPOC Compensation and Career Path: For many servicers, the position of SPOC is relatively new, 

although most servicers have leveraged existing staff to fill the role to the greatest extent possible. It is 

considered a high-stress role, requiring continuous training on evolving programs available for 

distressed homeowners and improving relationship management skills. Many servicers consider 

turnover in the SPOC position to be one of their most significant challenges. As with any newly created 

function, setting appropriate compensation, evaluation, and incentive parameters will be crucial to 

maintaining a stable, motivated work force and allow servicers the best opportunity to meet the goal of 

improved customer service. A review of compensation and incentive programs for SPOCs would be 

worthwhile. 

Clearly, servicing as an industry has been in the process of changing since the housing crisis began. MHA, 

including the requirements for implementing SPOC, has served as a catalyst for many of those changes. In 

addition to the specific questions above regarding how SPOC will mature, SPOC and other changes influenced 

by MHA will play a role in a larger conversation about how the mortgage servicing industry should continue to 

evolve and the way servicers are compensated. 

Treasury’s MHA program (and the significant compliance efforts related to it) has served an important role in 

creating and improving servicing standards during the crisis. As the MHA program approaches its termination 

date, Treasury’s role in the development of servicing standards will understandably reduce as others fill this 

need, particularly the CFPB as well as the National Mortgage Settlement. All of these represent continuing 

efforts to implement the Obama Administration’s Homeowner Bill of Rights. Treasury hopes that the initiation 

of SPOC by MHA servicers, and now more broadly across the industry, is establishing a framework that will 

improve outcomes for homeowners long after the sunset of the MHA program.
 22

It is important to the continued development and improvement of the SPOC concept that all stakeholders 

engage in open and constructive dialogue about what works, what doesn’t, and how to measure performance at 

the individual and organizational levels. It is Treasury’s hope that this report, which offers a spotlight on the 

SPOC organizations at the largest servicers in the country, contributes to that dialogue.
 23

VII. How Each of the Largest Servicers Is Implementing SPOC Guidance

Bank of America, N.A. (Bank of America)

This description of Bank of America’s SPOC process is based on information provided by Bank of America.

Homeowner Entry Point

When a homeowner engages Bank of America and communicates a hardship, the customer service 

representative confirms the establishment of RPC and enters the information provided by the homeowner into 

an internal decision tool, which is designed to identify initial eligibility and workout options. At this point, Bank 

of America uses a system transfer to assign a SPOC (which Bank of America refers to as a Customer 

Relationship Manager) to the homeowner. A homeowner can also be assigned a SPOC, even if RPC has not 

been previously achieved, when at least one document of the initial package is submitted to Bank of America 

for review.

Customer Relationship Model – SPOC Duties and Processing Support

Bank of America uses a SPOC Direct Model, with each homeowner assigned to a SPOC who is responsible for 

all in-bound and out-bound communications and for ensuring that an appropriate loss mitigation solution is 

reached. 

Bank of America’s SPOCs are responsible for assisting the homeowner with completing the modification 

package and for communicating with the homeowner to provide status information as necessary. Once an 

application for assistance is evaluated and a decision is made, the SPOC is responsible for communicating the 

decision to the homeowner as well as the next steps or any additional options (depending on the circumstances).

Bank of America uses a process support staff to assist the SPOC with the collection and validation of 

documents prior to submitting a HAMP modification application to underwriting. In the event a homeowner is 

not approved for HAMP, the process support staff and underwriters, in conjunction with the SPOC, will work 

with the homeowner on any available alternative retention solutions.

If the homeowner is approved for a modification, the SPOC remains assigned for an additional 30 days after the 

modification is completed to answer any questions the homeowner may have throughout the process. 

Bank of America reports that for the three-month period from March 2012 through May 2012, it averaged 

1,968,026 total inbound and outbound calls per month and that contact was successfully achieved for 1,564,662, 

or 80 percent, of those calls. Bank of America also reports that the average number of days from SPOC 

assignment to HAMP decision (for all acceptances and denials) was 86 days.
 24

Relationship with Liquidation Department

If a loan modification (either MHA or proprietary) is not feasible for the homeowner, Bank of America explores 

liquidation options. Although the SPOC remains assigned to the homeowner during the liquidation process, a 

member of Bank of America’s liquidation team becomes the primary point of contact for the homeowner. If the 

homeowner does contact his or her assigned SPOC, the SPOC has access to pertinent information to update the 

homeowner and the SPOC can also conference in the liquidation team member assigned to the case. 

Process if the Assigned SPOC Is Not Available

If the assigned SPOC is not available, homeowners have the option of leaving a voicemail with the SPOC or 

speaking to another SPOC associate within the “concierge” group. The concierge group offers expanded hours 

and is intended to handle inbound calls from homeowners who are otherwise unable to reach their assigned 

SPOC.

Bank of America recently completed a pilot of this concierge approach and has now rolled it out across the 

company. Bank of America reports that for calls routed to the concierge group during the pilot, the concierge 

agent was able to answer the homeowner’s question 70% of the time with one call and without scheduling an 

appointment for a return call from the SPOC. 

Staffing and Organization

Bank of America reports that it has over 8,700 personnel supporting its implementation of the SPOC guidance, 

including 4,594 SPOCs and 4,122 processing support staff, which include processors as well as 400 proficiency 

coaches and 1,000 managers. Proficiency coaches perform quality control checks of SPOC calls and offer 

guidance to SPOCs.

Bank of America has SPOCs located in 24 different geographic locations. The SPOCs are also segmented by 

investor type (e.g., GSE, private label, portfolio, etc.). 

Caseload

Bank of America’s target caseload for retention options is 100 cases per SPOC. Bank of America utilizes a 

weighted average to calculate the SPOC caseload contingent upon the loss mitigation option the homeowner is 

seeking. For example, a homeowner that is being evaluated for a modification option will require a higher 

number of interactions than a homeowner seeking a liquidation option who is also working with a real estate 

professional. 

For the three-month period from March 2012 through May 2012, Bank of America’s average SPOC 

modification caseload—i.e., those homeowners being explicitly considered for a retention option—was 85 

cases. Bank of America did not report total SPOC caseload, which includes short sale or deed-in-lieu options as 

well as modifications or repayment plans, because they do not determine caseloads in that manner. 
 25

Training

Bank of America reports that it uses a training program for SPOC implementation with different curricula for 

each associate function (SPOC/ Process Support, Proficiency Coach, and Manager). In addition, each member 

of the staff must complete a SPOC core curriculum, which includes more than 80 learning modules addressing 

broad topics such as enterprise compliance, systems training, and customer treatment, as well as more specific 

topics on MHA and proprietary home retention options. Bank of America uses a combination of instructor-led 

and web-based modules, all of which require trainees to successfully complete assessments before receiving 

credit.
 26

CitiMortgage, Inc. (Citi)

This description of Citi’s SPOC process is based on information provided by CitiMortgage.

Homeowner Entry Point

Citi utilizes a warm transfer when assigning a SPOC (which Citi refers to as a Homeowner Support Specialist).

Once a homeowner is contacted, basic information, including income data, tax and insurance information, as 

well as certain other eligibility information, is taken over the phone and run through Citi’s internal decision 

tool. If a retention or liquidation solution is identified, a SPOC is then assigned. This assignment is done in real 

time, which allows the customer service representative to attempt a warm transfer by introducing the SPOC to 

the homeowner. In this introductory call, the SPOC notifies the homeowner that a welcome package will be sent 

out which will include the materials necessary for requesting assistance through MHA. In cases where a warm 

transfer is not possible, the assigned SPOC is expected to complete a welcome call with the homeowner within 

five business days. 

Customer Relation Model – SPOC Duties and Processing Support

Citi uses a SPOC Direct Model, with each homeowner assigned to a SPOC who is responsible for all inbound 

and outbound communications and for ensuring that an appropriate loss mitigation solution is reached.

Once assigned, the SPOC works with the homeowner to collect all required documents and verify any possible 

loss mitigation solutions available to the homeowner. The SPOC submits the homeowner’s completed package 

to underwriting and informs the homeowner of all decisions. Citi requires SPOCs to call each active 

homeowner at least once a week. The SPOC stays as the homeowner’s point of contact until the loan is 

modified or liquidated.

Citi employs a variety of media to communicate with homeowners. In addition to phone communications, Citi 

SPOCs also interact with homeowners through email and automated outbound text messages communicating a 

status change in the modification review process. Additionally, a homeowner is able to access citimortgage.com

to determine his or her documentation status. 

Citi reports that for the three-month period from March 2012 through May 2012, it averaged 374,513 total calls 

(inbound and outbound) per month and that contact was successfully achieved for 217,398, or 58 percent, of 

those calls. Citi also reports that the average number of days from SPOC assignment to HAMP decision (for all 

acceptances and denials) was 95 days.

Relationship with Liquidation Department

If the homeowner is not eligible for a modification, the SPOC will refer the homeowner to the liquidation team.

The SPOC will work with the homeowner and the homeowner’s real estate agent during the liquidations 

process. The homeowner will remain in the SPOC’s caseload, and the SPOC has access to the homeowner’s 

information through final disposition.
 27

Process if the Assigned SPOC Is Not Available

Citi does not utilize voicemail within the SPOC call centers. When a SPOC is unavailable to take a 

homeowner’s call, the next available agent within the team will answer the call. If an agent on the team is not 

available, the homeowner’s call rolls to an agent on a similar investor’s team. If this agent is unavailable, the 

call will roll to any available SPOC regardless of investor. If a call is received after SPOC business hours or if 

the call is unauthenticated, it will be routed to the Customer Contact Center (which Citi refers to as the 

Homeowner Assistance Team). At this point in the process, any agent who receives the homeowner’s call can 

access a scheduling system to set up a return call at the homeowner’s convenience.

Staffing and Organization

Citi reports that it has 681 SPOCs and 79 processing support staff. In addition, Citi has a program that utilizes a 

separate document collection process to work with the homeowner to collect missing documents and help to 

complete packages. However, the SPOC will remain the homeowner’s primary point of contact throughout the 

process.

The SPOC teams are located in four locations: St. Louis, MO; Tucson, AZ; Dallas, TX; and Fort Mill, SC.

SPOCs are organized in teams of 12 and segmented by investor.

Caseload

Citi has a target caseload of 100 homeowners per SPOC, regardless of the type of resolution being pursued.

For the three-month period from March 2012 through May 2012, Citi’s average SPOC modification caseload—

i.e., those homeowners being explicitly considered for a retention option—was 95 cases and the total monthly 

caseload, which includes short sale or deed-in-lieu options as well as modifications and repayment plans, was 

117 cases per SPOC.

Training

Citi's SPOC training varies, depending on the employee’s background and tenure at Citi. If an existing 

representative transfers to a SPOC position, he or she obtains 15 days of training. The first 10 days consist of 

instructor-led classroom training and web-based training on Citi’s internal systems. The remaining 5 days 

consists of on-the-job training accompanied by a training coach. In order to complete the training, 

the employees are required to complete 7 knowledge assessments and 3 skills assessments. A newly-hired 

employee is required to obtain 25 days of more detailed training. Starting with day 5, the employee 

will participate in call observation for the first 1/2 hour of each day until the end of the training period. New 

hires are required to complete 7 knowledge assessments and 5 skills assessments. 
 28

GMAC Mortgage, LLC (GMAC)

This description of GMAC’s SPOC process is based on information provided by GMAC.

Homeowner Entry Point

GMAC sends a loss mitigation notice on the 45th day of delinquency advising the homeowner of available loss 

mitigation options and inviting them to complete a workout package and/or call for SPOC assignment if they 

require assistance. GMAC assigns a SPOC to a homeowner once any portion of the homeowner’s loss 

mitigation workout package is received or if the homeowner requests assistance in completing the package.

GMAC will also assign a SPOC upon RPC to all homeowners who are eligible for referral to foreclosure or 

already in foreclosure. GMAC uses a system transfer to assign a SPOC to the homeowner, with assignments 

based on SPOC caseloads and availability. 

Customer Relation Model – SPOC Duties and Processing Support

GMAC uses a SPOC Direct Model. The SPOC is responsible for all in-bound and out-bound communications 

and working with the homeowner to ensure that an appropriate loss mitigation solution is obtained. A “triage 

team” works with the SPOC to obtain all necessary documents from the homeowner, prepare homeowner 

communications, prepare the package for processing, and forward the completed package to underwriting.

Homeowners stay with their assigned SPOC for 60 days after the permanent modification or other resolution, 

including foreclosure.

GMAC reports that for the three-month period from March 2012 through May 2012, it averaged 295,336 total 

inbound and outbound calls per month and that contact was successfully achieved for 128,017, or 43 percent, of 

those calls. GMAC also reports that the average number of days from SPOC assignment to HAMP decision (for 

all acceptances and denials) was 26 days.

Relationship with Liquidation Department

When a loan workout option is no longer feasible or the homeowner indicates they no longer wish to keep the 

property, the SPOC refers the homeowner to a contact on the liquidation team. However, the SPOC continues to 

remain the homeowner’s primary contact throughout the foreclosure process.

Process if the Assigned SPOC Is Not Available

If the SPOC is not available when a homeowner calls, the call is routed to one of the other members of the 

SPOC’s team. If no one on the team is available, the call is routed to any other available SPOC within that 

geographic location. If those SPOCs are unavailable, the call is routed to any other available SPOC at any 

location. A homeowner who reaches a SPOC other than his or her assigned SPOC may speak with that staff 

member or schedule an appointment for the SPOC to return the call.
 29

Staffing and Organization

GMAC reports that it has 280 SPOCs and 257 SPOC support professionals in two locations (Waterloo, IA and 

Dallas, TX). Each individual SPOC is assigned to a SPOC team. A team manager leads each team and is 

assisted by a team leader. Specialty teams are set up for accounts in bankruptcy, bank-owned accounts, private 

label servicing, and Spanish-speaking homeowners. 

Caseload

GMAC has a total target caseload of 75-150 cases per SPOC, depending on the case type and disposition.

GMAC does not set SPOC caseload targets for retention-only workouts; all targets are established for overall 

caseloads, including modifications, repayment plans, and short sale or deed-in-lieu options.

For the three-month period from March 2012 through May 2012, GMAC’s average SPOC modification 

caseload—i.e., those homeowners being explicitly considered for a retention option—was 122 cases and the 

total caseload, which includes short sale or deed-in-lieu options as well as modifications or repayment plans, 

was 150 cases per SPOC.

Training

SPOCs at GMAC attend a six-week training program for experienced collections professionals. This training 

includes five weeks of training on all types of modification programs and foreclosure alternatives. Trainees 

must also pass a one-week certification program in order to take inbound calls and receive case assignments.

The training extends up to 13 weeks for hires without prior servicing/collections experience. The expanded 

training includes customer service, collections, and experiential/soft skills training. During the course of 

training, SPOCs role play, shadow, and engage in side-by-side live calls with their coach. SPOCs in training 

also make outbound calls to inactive accounts. 
 30

Homeward Residential (Homeward)

This description of Homeward’s SPOC process is based on information provided by Homeward.

Homeowner Entry Point

Homeward utilizes a system transfer method to assign SPOCs to homeowners. Once a Homeward collections 

department member establishes RPC with a homeowner and identifies the homeowner as being potentially 

eligible for a loan modification, Homeward executes a system transfer to assign a SPOC and send the 

homeowner an application package.

Customer Relation Model – SPOC Duties and Processing Support

Homeward uses a SPOC Direct Model. The homeowner is given the choice of contacting his or her SPOC 

either by calling the SPOC’s direct line or by email through Homeward’s web portal.

Homeward’s SPOCs are primarily responsible for all homeowner communications. SPOCs are responsible for 

reaching out to the homeowner within 5-10 business days of assignment to begin assembling the necessary 

documents for the loan modification application (as well as any additional documents required by the mortgage 

investor). SPOCs have teams of processors (known as Retention Specialists) to help with document collection 

and processing prior to submission to underwriting, but it is the SPOC’s responsibility to ensure that all 

documents are received and transferred to the underwriter. The Retention Specialists might also contact 

homeowners directly in connection with document collection.

The SPOC remains the homeowner’s point of contact throughout the entire resolution process, including any 

home retention and non-foreclosure liquidation options. The homeowner receives follow-up calls from the

SPOC on final document completion. The SPOC is removed upon successful implementation of a permanent 

solution.

Homeward reports that for the three-month period from March 2012 through May 2012, it averaged 40,146 total 

inbound and outbound calls per month and that contact was successfully achieved for 17,919, or 45 percent, of 

those calls. Homeward also reports that the average number of days from SPOC assignment to HAMP decision 

(for all acceptances and denials) was 106 days.

Relationship with Liquidation Department

In the event a loan workout option is not feasible for the homeowner, Homeward will explore liquidation 

options with the homeowner. Homeward has specific associates who process liquidations and the SPOC 

introduces the homeowner to these associates, but the SPOC remains assigned to the homeowner during this 

phase, has access to all of the systems used by these specialists, and can review the status at any time.

Process if the Assigned SPOC Is Not Available

Homeowners unable to reach the SPOC on the phone are given the option of leaving voicemail or speaking to 

another member of the SPOC team. When speaking with the SPOC team member, the homeowner can either 
 31

schedule a return phone call from the SPOC or receive immediate assistance on basic questions and status. If 

the SPOC is out of the office, the SPOC’s supervisor is responsible for checking the SPOC’s voicemail and 

responding to any homeowner questions. 

Staffing and Organization

Homeward reports that it has 139 SPOCs and 112 processing support staff. All SPOC resources are located in 

one location in Addison, TX. The SPOCs are segmented into two groups by investor (GSE and non-GSE). 

Caseload

Homeward’s target modification caseload is 150 active accounts per SPOC. For the three-month period from 

March 2012 through May 2012, Homeward’s average SPOC modification caseload—i.e., those homeowners 

being explicitly considered for a retention option—was 149 cases and the total caseload, which includes short 

sale or deed-in-lieu options as well as modifications or repayment plans, was 494 cases per SPOC. 10

Training

Homeward offers training for new hires and existing employees. SPOCs receive 16 days of classroom and onthe-job training (11 days of classroom training and 5 days of shadowing subject matter experts). SPOC training 

includes soft skills training and role play. SPOCs must pass a final certification for new hire training (where 

appropriate) and customer experience training.

 10 In most situations, Homeward will assign a SPOC to a homeowner at the earliest contact with a delinquent homeowner, regardless of the number of days the 

homeowner is delinquent when the contact is made. As a result, many homeowners have SPOCs assigned to them even though the homeowner has not missed more 

than one mortgage payment and is not actively pursuing a loan modification. These assignments remain in place with the SPOC until the delinquency is successfully 

resolved, the loan is modified, the homeowner receives a short sale or deed-in-lieu, or the loan ends in foreclosure.
 32

JPMorgan Chase Bank, N.A. (Chase)

This description of Chase’s SPOC process is based on information provided by Chase.

Homeowner Entry Point

Once Chase’s collections or customer care team establishes RPC, Chase sends the homeowner a loan 

modification package. On the basis of discussions with the customer, or the return of at least one document 

from the solicitation package (such as the application, an income document, or a liquidation document), Chase 

assigns the homeowner a SPOC (which Chase refers to as a Customer Assistance Specialist) using a system 

transfer. The system assigns SPOCs based on several business rules including SPOC capacity.

Customer Relationship Model – SPOC Duties and Processing Support

Chase uses a SPOC Direct Model. Homeowners calling in to Chase using the SPOC’s phone extension are 

automatically routed to their SPOC. Chase SPOCs handle all inbound and outbound communications and stay 

assigned to the homeowner throughout the resolution process, and for 60 days after a permanent modification. 

Chase also has a group of processors (which it calls the Customer Assistance Operations group) that works 

directly with SPOCs to handle written correspondence and to review and organize incoming homeowner 

documents. The processor group does not interact with the homeowner.

Chase reports that for the three-month period from March 2012 through May 2012, it averaged 1,589,679 total 

inbound and outbound calls per month and that contact was successfully achieved for 1,146,353, or 72 percent, 

of those calls. Chase also reports that the average number of days from SPOC assignment to HAMP decision 

(for all acceptances and denials) was 78 days.

Relationship with Liquidation Department

In the event the case goes to liquidation, the SPOC will counsel the homeowner on short sale alternatives and 

refer the homeowner to a liquidations specialist (which Chase refers to as a List Assist Specialist). For any case 

that results in a short sale or deed-in-lieu, the SPOC remains assigned as a contact throughout the disposition 

process, although the liquidations team representative will become the homeowner’s primary point of contact 

during the process.

Process if the Assigned SPOC Is Not Available

If a homeowner is unable to reach his or her SPOC, the homeowner has the option of leaving a voicemail 

message with the assigned SPOC, speaking to the next available agent with similar skills, or scheduling a return 

call from the homeowner’s SPOC. 

Staffing and Organization

Chase reports that it has 2,381 SPOCs and 946 additional processing staff. There are 13 SPOC sites in 10 cities.

The sites are managed across two geographic divisions (East and West). SPOCs are also segmented into five 
 33

additional sub-groups according to homeowner status or investor. Specialty teams are set up to handle military, 

employee, and litigation and bankruptcy cases. Additionally, Chase has 83 Homeownership Centers in 29 states 

and the District of Columbia where customers can meet face-to-face with a SPOC representative.

Caseload 

 

Chase’s target caseload for modification options is 75 cases per SPOC. For the three-month period from March 

2012 through May 2012, Chase’s average SPOC modification caseload—i.e., those homeowners being 

explicitly considered for a retention option—was 64 cases and its total caseload, which includes short sale or 

deed-in-lieu options as well as modifications or repayment plans, was 154 cases per SPOC.

Training

Chase has a four-week training program consisting of two weeks of classroom and two weeks of on-the-job 

training. SPOCs must complete soft skills and negotiations training. SPOCs must pass a knowledge assessment 

test conducted in conjunction with the SPOC training and are also tested on weekly policy and procedure 

changes.
 34

Ocwen Loan Servicing, LLC (Ocwen)

This description of Ocwen’s SPOC process is based on information provided by Ocwen.

Homeowner Entry Point

Ocwen utilizes an appointment-based approach for assigning SPOCs to a homeowner. Ocwen’s first point of 

contact for a homeowner seeking a loss mitigation resolution is the Customer Care Center. Once RPC has been 

established and potential HAMP eligibility has been established or when a homeowner requests assistance for 

any resolution, the customer service representative (referred to by Ocwen as the Customer Care Agent) is 

responsible for scheduling an appointment between the homeowner and an available SPOC (which Ocwen 

refers to as a Relationship Manager). In addition, even if RPC has not been established a SPOC will also be 

assigned if the homeowner submits any type of loss mitigation documentation.

The appointment date and time is determined based on customer requirements including the expected time 

required to fill out a package or provide any missing documentation. The Customer Care Agent sends the 

appropriate package to the homeowner in advance of the appointment, and provides instructions on how to 

complete the package and what documentation is required for evaluation.

Customer Relationship Model – SPOC Duties and Processing Support

Ocwen is the only large MHA servicer to use a SPOC Appointment-Based Model for having homeowners 

interact with their assigned SPOC. Any homeowner call into the SPOC is first routed through the Customer 

Care Center. The Customer Care Agent answers simple questions as appropriate, determines when the assigned 

SPOC is available, and schedules an appointment for the SPOC to contact the homeowner. 

Ocwen’s SPOCs are responsible for communicating with the homeowner at the scheduled appointment time, 

setting expectations, and providing timelines to the homeowner. The SPOC initiates any requests for any 

additional or missing information or documentation. It is also the responsibility of the SPOC to work with the 

homeowner to ensure receipt of a complete package, answer status questions, and communicate loss mitigation 

decisions and next steps. 

The assigned SPOC remains the homeowner’s single point of contact until a final resolution is reached, 

including cases of foreclosure.

Ocwen reports that for the three-month period from March 2012 through May 2012, it averaged 110,580 total 

inbound and outbound calls per month and that contact was successfully achieved for 70,025, or 63 percent, of 

those calls. Ocwen also reports that the average number of days from SPOC assignment to HAMP decision (for 

all acceptances and denials) was 47 days.

Relationship with Liquidation Department

In the event a loan workout option or other foreclosure alternative is not feasible for the homeowner, the SPOC 

refers the homeowner to Ocwen’s Foreclosure Department. The SPOC remains the homeowner’s single point of 

contact through the completion of a foreclosure. 
 35

Process if the Assigned SPOC Is Not Available

The Customer Care Agent answers any simple homeowner questions as appropriate and schedules an 

appointment when the SPOC will contact the homeowner at a time convenient for the homeowner. If the 

homeowner’s assigned SPOC is not available at the time of a scheduled appointment, then the call is routed to a 

buffer agent who does not carry a caseload. The buffer agent offers to provide assistance or set up a new 

appointment with the assigned SPOC.

Staffing and Organization 

Ocwen reports that it employs 687 Relationship Managers in West Palm Beach, Houston, and India. The 

Houston and West Palm Beach locations include specialized SPOCs who handle mediation and litigation cases. 

The majority of SPOCs are located in India. 

Caseload

Ocwen does not have a target caseload specific to modification options. For the three-month period from March 

2012 through May 2012, Ocwen’s average SPOC modification caseload—i.e., those homeowners being 

explicitly considered for a retention option—was 161 cases and its total caseload was 274 cases per SPOC.

Training

Ocwen has established a specific SPOC training plan that employs both course work and on-the-job 

training. Individuals newly hired by Ocwen for the SPOC position must complete a total of 200 hours of 

training, encompassing 160 hours of classroom training and 40 hours of on-the-job training. Internal employees 

transferring from an internal customer-facing department are required to complete an 8-hour training on MHA 

programs. As part of the training curriculum, SPOCs in-training are evaluated on call-handling skills. All 

employees hired for the SPOC role (internal and external hires) must complete and pass a 2-hour SPOC

certification course to become a SPOC at Ocwen.
 36

OneWest Bank (OneWest)

This description of OneWest’s SPOC process is based on information provided by OneWest.

Homeowner Entry Point

OneWest utilizes a system transfer process to assign SPOCs to eligible homeowners. After RPC is established 

and an evaluation of the homeowner’s potential eligibility for a workout option has been completed, a SPOC 

(which OneWest refers to as a Contact Manager) is assigned through a system transfer. If RPC is established

directly through a phone call, the agent informs the homeowner that a SPOC representative will be sending a 

welcome packet and providing a welcome call within 48 hours. In addition, the homeowner will be assigned a 

SPOC if he or she applies for a modification or other foreclosure alternative or if the homeowner enters the 

foreclosure process and has not yet been assigned a SPOC.

Customer Relationship Model – SPOC Duties and Processing Support

OneWest uses a SPOC Pod Model, with homeowners not assigned to an individual SPOC, but to a SPOC team.

Once SPOC assignment has been made via any of the processes described above, the homeowner receives a 

welcome letter that includes the name of the Contact Manager for the specific SPOC team.

Upon assignment, a SPOC within the assigned team reaches out to the homeowner with a welcome call 

explaining the SPOC process and providing the homeowner with necessary contact information. The SPOC is 

responsible for all document collection, submitting the package to an underwriter, and communicating any 

decisions back to the homeowner. In situations where additional documentation or information is needed from 

the homeowner, OneWest requires the assigned SPOC team members to place outbound calls to homeowners at 

least 3 times a day at various times throughout the day.

OneWest SPOCs remain with the homeowner through the entire resolution process until 30 days after the 

resolution option or foreclosure is completed.

OneWest reports that for the three-month period from March 2012 through May 2012, it averaged 1,441,713 

total inbound and outbound calls per month and that contact was successfully achieved for 119,246, or 8 

percent, of those calls. OneWest believes that this last figure (8 percent) is driven to a great degree by its 

practice (referenced above) of placing outbound calls at least 3 times a day to homeowners from whom 

additional documentation or information is needed. OneWest also reports that the average number of days from 

SPOC assignment to HAMP decision (for all acceptances and denials) was 69 days.

Relationship with Liquidation Department

If a loan modification is not feasible for the homeowner or the homeowner asks to be considered for a short 

sale, the SPOC will provide the required documents to the homeowner in order to be considered for a workout 

with the liquidation team. A short sale negotiator will be assigned to work with the homeowner (or the 

homeowner’s real estate agent). Notwithstanding the resolution type, the homeowner remains in the SPOC’s 

active inventory through foreclosure. 
 37

Process if the Assigned SPOC Is Not Available

OneWest has eliminated voicemail for all of their SPOCs. When a homeowner calls the SPOC team, if the 

Contact Manager is unavailable, the next available agent within the SPOC team answers the call. If an agent on 

the homeowner’s SPOC team is not available, the call will go to an agent on a SPOC team familiar with the 

investor’s guidelines for the homeowner’s loan. If all agents are unavailable, the call will roll to the Customer 

Contact Center (or if the call is received outside of the Customer Contact Center’s business hours, the call is 

answered by OneWest’s Enterprise Call Center). 

Regardless of who answers the call, any call center member has access to a scheduling system for each team 

and can arrange a return call at a homeowner’s chosen time. The homeowner also always has the option to 

speak with a particular individual if he or she chooses. OneWest reports that less than 1 percent of homeowners 

actually ask for the SPOC named in the welcome letter, 6 percent of homeowners ask for the last person they 

spoke with, and 42 percent of homeowners ask for an individual on the team they have worked with in the past.

Staffing and Organization

OneWest reports that it has 289 SPOC team members and 58 processors in two locations in Austin, TX and 

Irvine, CA. Agents are divided into 28 teams that are segmented by investor type. Each team is comprised of 

one manager, 11 SPOC team members and two underwriters. The underwriters sit with the contact team to 

assist with the resolution of document questions. 

Caseload

OneWest’s target modification caseload is 131 cases per SPOC team member.

For the three-month period from March 2012 through May 2012, OneWest’s average SPOC modification 

caseload—those homeowners being explicitly considered for a retention option—was 137 cases and its total 

caseload, which includes short sale or deed-in-lieu options as well as modifications or repayment plans, was 140 

cases per SPOC.

Training

OneWest divides SPOC training into two curricula: one curriculum for existing associates and one curriculum 

for new employees. The training for existing associates is 40 hours. This training is classroom-based and 

includes training on all phases of the SPOC process. Trainees are required to pass daily tests. New associate 

training is more extensive, with each new employee receiving eight weeks of training comprising both 

classroom and on-the-job sessions. The first two weeks consist of classroom training on OneWest systems as 

well as homeowner interactions. This is followed by a mix of both classroom and on-the-job training with 

existing associates and supervisors. There is no additional training or certification required before a SPOC is 

assigned cases.
 38

Select Portfolio Servicing (SPS) 

This description of SPS’s SPOC process is based on information provided by SPS.

Homeowner Entry Point

When a homeowner first engages SPS through the collections team, the customer center representative will 

determine initial eligibility for HAMP, which includes collecting income information and informing the 

homeowner of supporting document requirements. Once potential HAMP eligibility is confirmed, a SPOC is 

automatically assigned. The customer center representative will then attempt to connect the homeowner to the 

assigned SPOC through a warm transfer. If the SPOC is not available, the SPOC is required to attempt to 

communicate with the homeowner within the next few days.

Customer Relation Model – SPOC Duties and Processing Support

SPS uses a SPOC Direct Model. The SPOC is responsible for all inbound and outbound communications with 

the homeowner and for ensuring that an appropriate loss mitigation solution is reached. 

SPOCs are supported by processors who are responsible for collecting documents and for reviewing the 

homeowner’s initial package for completeness. If an incomplete package is identified, the processer notifies the 

SPOC to follow-up with the homeowner. Once the package is complete, processors make the final eligibility 

determination. 

The SPOC remains assigned to the homeowner through the resolution process.

SPS reports that for the three-month period from March 2012 through May 2012, it averaged 30,063 total 

inbound and outbound calls per month and that contact was successfully achieved for 8,587, or 29 percent, of 

those calls. SPS also reports that the average number of days from SPOC assignment to HAMP decision (for all 

acceptances and denials) was 61 days.

Relationship with Liquidation Department

If the homeowner is not eligible for a modification, a SPOC will remain assigned to the homeowner. In the 

event a liquidation option is pursued, a SPOC remains engaged until completion of the deed-in-lieu, short sale, 

or foreclosure sale.

Process if the Assigned SPOC Is Not Available

If the assigned SPOC is unavailable when the homeowner calls, the homeowner can either request to speak with 

the next available SPOC or request that the assigned SPOC return the call. If the homeowner elects to have the 

SPOC call them back, SPS requires this call to be returned within 48 business hours. 

Staffing and Organization

SPS reports that it has 26 SPOCs and 91 processing support staff. 
 39

Caseload

Each SPOC has a targeted caseload of 360 loans, which includes all workout options. 

For the three-month period from March 2012 through May 2012, SPS’s average SPOC modification caseload—

i.e., those homeowners being explicitly considered for a retention option—was 210 cases and its total caseload, 

which includes short sale or deed-in-lieu options as well as modifications or repayment plans, was 344 cases per 

SPOC.

Training 

SPS SPOC-specific training lasts two days, half of which is devoted to shadowing and the remainder consisting 

of both classroom and online training. The instructor-based classroom training covers an overview of the SPOC 

process, the MHA Handbook, and SPOC expectations and responsibilities. At the completion of training each 

SPOC must successfully complete a certification exam. All SPOCs undergo Loss Mitigation training at the time 

of hire which spans a 60 day timeframe.
 40

Wells Fargo Bank, N.A. (Wells)

This description of Wells’ SPOC process is based on information provided by Wells. 

Homeowner Entry Point

Once RPC is established and basic eligibility (including initial evaluation of the homeowner’s financial 

information) is confirmed either verbally or in writing, the Wells collections agent or customer service 

representative uses a warm transfer to connect the homeowner with his or her assigned SPOC (which Wells 

refers to as a Home Preservation Specialist). This is done through a conference call among the homeowner, the 

agent, and the SPOC. Typically in these calls, the SPOC answers any immediate questions the homeowner 

might have, walks through the modification application process, the required documentation and timeline for 

delivery of these documents, and identifies next steps.

Customer Relationship Model – SPOC Duties and Processing Support

Wells uses a SPOC Direct Model. The SPOC is responsible for helping the homeowner complete the 

modification package, collect necessary documents, submit completed packages to underwriting, and 

communicate all decisions and status updates to the homeowner.

The SPOC is responsible for understanding all retention solutions and answering questions from the 

homeowner. Wells maintains assistance lines that SPOCs can access to assist them in responding to technical 

questions, such as foreclosure, bankruptcy and escrow related activities. The SPOC remains assigned to the 

relationship through the final resolution.

Wells reports that for the three-month period from March 2012 through May 2012, it averaged 1,293,008 total 

inbound and outbound calls per month and that contact was successfully achieved for 639,023, or 49 percent, of 

those calls. Wells also reports that the average number of days from SPOC assignment to HAMP decision (for 

all acceptances and denials) was 103 days.

Relationship with Liquidation Department

If a case goes to liquidation, the SPOC remains as the primary point of contact to the homeowner. The 

liquidation team will act as a technical resource to the SPOC, but the SPOC is still the point of contact to the 

homeowner throughout the process.

Process if the Assigned SPOC Is Not Available

All calls from a homeowner are directed to the assigned SPOC’s direct phone line and are sent to voicemail if 

the SPOC is assisting another homeowner or otherwise unavailable. Homeowners also have the option to 

request an opportunity to speak immediately to another SPOC team member. 
 41

Staffing and Organization

Wells reports that it has 3,026 SPOC and 121 additional processing support personnel in 15 separate geographic 

locations. SPOCs are segmented by investor type (GSE, private label, portfolio, etc.).

 

Caseload

Wells’ target caseload includes all resolution options. Its current overall caseload target for SPOCs is 85. 

For the three-month period from March 2012 through May 2012, the Wells average SPOC modification 

caseload— i.e., those homeowners being explicitly considered for a retention option—was 67 cases and the 

total modification caseload, which includes short sale or deed-in-lieu options as well as modifications or 

repayment plans, was 80 cases per SPOC.

Training

Wells offers training for both new hires and existing employees. All new SPOCs receive 120 hours of training, 

consisting of 16 training modules, each with a knowledge check. Training includes self-study, instructor-led 

training, and a final assessment that all SPOCs must pass. After their initial training, all SPOCs receive ongoing 

training on a monthly basis and are assessed to ensure understanding of new initiatives and investor 

implementations. All change training content is incorporated into the new hire program as appropriate.
 A-1

Appendix A: MHA Guidance Directed at Protecting Homeowners and Improving 

Communications to Homeowners

Treasury’s issuance of guidance in May 2011 for servicers to establish a Single Point of Contact was just one of 

a series of steps taken under the MHA Program to protect homeowners and facilitate communications between 

struggling homeowners and mortgage servicers. Others steps directed at these goals include:

Supplemental 

Directive 

Number Issue Date Effective Date Summary

09-01 April 6, 2009 - Established and defined guidelines for HAMP, which 

uses a uniform loan modification process to provide 

the homeowner with sustainable monthly payments.

09-02 April 21, 2009 - Established additional HAMP guidelines, including 

provisions for the collection of homeowner 

information as part of the Hardship Affidavit.

09-03 July 6, 2009 - Defined requirements for setting up and reporting 

HAMP trial period and permanent modifications.

09-06 Sep. 11, 2009 - Provided guidance to servicers for the collection and 

reporting of information for homeowners evaluated 

for HAMP.

09-07 Oct. 8, 2009 Oct. 8, 2010/ 

March 1, 2010

Streamlined the HAMP evaluation processes by (1) 

defining standardized homeowner response 

timeframes, (2) introducing a uniform Request for 

Modification and Affidavit (RMA) form, and (3) 

updating income verification requirements.

09-08 Nov. 3, 2009 Jan. 1, 2010 Defined additional HAMP requirements related to 

the format, content (including the use of standard, 

plain language), and timing of notices that are 

provided to all homeowners who request 

consideration for a HAMP modification. 

10-01 Jan. 28, 2010 June 1, 2010 Updated HAMP guidance to require full verification 

of HAMP eligibility prior to offering a trial plan. 

Established timeline requirements for acknowledging 

receipt of a homeowner’s modification package, 

collecting income documents, and sending a (1) 

incomplete information notice, (2) trial period plan 

notice, or (3) notice that the homeowner is not 

eligible for HAMP.

10-02 March 24, 

2010

June 1, 2010 Amended homeowner outreach and communication 

requirements:

– Defined requirements prohibiting a loan from 

being referred to foreclosure or conducting a 

foreclosure sale while a homeowner is actively 

working with the servicer to obtain or maintain a 

HAMP modification. 

– Extended HAMP benefits for homeowners who 

have filed for bankruptcy.
 A-2

Supplemental 

Directive 

Number Issue Date Effective Date Summary

– Established reasonable effort standards for 

servicers to solicit homeowners for HAMP.

– Created a 30-day response period for homeowners 

to request an independent review of most HAMP 

denial decisions, during which time a foreclosure 

sale cannot be conducted.

10-15 Nov. 3, 2010 Feb. 1, 2011 Established guidance for the resolution of 

homeowner complaints, especially servicer processes 

for handling homeowner inquiries and disputes, 

including the following:

– Servicer obligations for addressing homeowner 

escalations, including establishing an escalations 

team separate from the staff evaluating the 

homeowner for a modification.

– Descriptions of the homeowner support centers 

(MHA Help for individual homeowners and the 

HAMP Support Center (HSC) for housing 

counselors and other third parties).

– Requirements for providing the information (such 

as NPV inputs) used in the HAMP evaluation in 

the notices sent to homeowners when they are 

determined to be not eligible for HAMP.

– Introduction of the Borrower NPV Calculator for 

homeowners to independently validate the 

information used in the HAMP evaluation.

11-02 March 30, 

2011

March 30, 2011/

June 1, 2011

Defined additional guidance on case escalations, 

such as timing requirements associated with a 

homeowner escalation and new case resolution 

requirements.

Also provided additional clarification on NPV inputs 

that are provided to homeowners as part of a HAMP 

non-approval notice.

11-04 May 18, 2011 Sep. 1, 2011 Required top 20 MHA servicers to establish a Single 

Point of Contact for all homeowners being evaluated 

for an MHA program and, among other things, to 

have the SPOC certify that all foreclosure prevention 

options were exhausted before a foreclosure sale is 

conducted.

11-10 Sep. 29, 2011 Dec.1, 2011 Provided additional HAMP clarifications for 

homeowner reconsideration, homeowner 

solicitations, and eligibility of non-responsive 

homeowners; established processes for rectifying 

situations where a homeowner is incorrectly declined 

for HAMP; and updated the RMA, Hardship 

Affidavit, and Dodd-Frank Act Certification forms.
 B-1

Appendix B: Glossary

Appointment-Based Transfer: A method of assigning a SPOC to a homeowner. The customer service 

representative schedules an appointment time for the homeowner to speak with his or her SPOC, and then the 

SPOC calls the homeowner back at the scheduled time. 

Caseload: The number of homeowners that have been assigned to a particular SPOC. Caseloads can be a 

target number – the ideal number of homeowners a SPOC can work with – or an actual number – the number of 

homeowners a SPOC is actually assigned.

Collections: A department within the servicer’s organization that is tasked with contacting homeowners and 

collecting past due payment amounts.

Concierge Group: An additional support team implemented by Bank of America to handle inbound calls from 

homeowners who are not able to reach their assigned SPOC. 

Consent Orders: A voluntary agreement worked out between two or more parties to a dispute generally with 

the same effect as a court order and enforceable by the court if anyone does not comply.

Customer Contact Center: A typical contact method for homeowners attempting to reach their assigned 

servicer for any mortgage-related questions. For modification-related questions when a SPOC has already been 

assigned, the Customer Contact Center will typically arrange an appointment with the homeowner for the SPOC 

to call them back. 

Customer Relationship Model: Process by which a homeowner interacts with his or her assigned SPOC. 

Customer Service Representative: A servicer representative who handles customer telephone calls and 

contacts on behalf of the servicer, including account inquiries, complaints, or support calls. 

Deed-in-Lieu of Foreclosure: A foreclosure alternative in which the homeowner transfers all interest in a 

property to a lender/mortgagee to satisfy a debt and avoid foreclosure. 

Delinquency: Failure of a homeowner to make timely mortgage payments specified under a loan agreement. 

Delinquent: A loan in which the expected monthly contractual payment has not been received. A mortgage is 

generally considered delinquent when at least one payment is due and unpaid by the end of the month in which 

it is due. 

Entry Point: The point at which the homeowner enters into the loss mitigation process. 

Foreclosure Sale: The legal process by which a property is sold and the proceeds of the sale applied to an 

outstanding mortgage debt. A foreclosure occurs when the loan becomes delinquent because payments have not 

been made or when the homeowner is in default for a reason other than the failure to make timely mortgage

payments.

Forbearance: A temporary reduction or suspension of a mortgage payment.

Government Sponsored Enterprise (GSE): Private organizations with government charters and backing. For 

example, Fannie Mae and Freddie Mac are GSEs. Fannie Mae and Freddie Mac own or guarantee mortgage 

loans. They have modification programs and requirements similar to MHA.
 B-2

Home Affordable Modification Program (HAMP): An MHA loan modification program that provides 

homeowners the opportunity to modify their first lien mortgage loans to make them more affordable.

Home Affordable Foreclosure Alternatives (HAFA) Program: An MHA program that provides 

opportunities for homeowners who can no longer afford to stay in their home but want to avoid foreclosure to 

transition to more affordable housing through a short sale or deed-in-lieu of foreclosure.

Home Affordable Unemployment Program (UP): An MHA program that provides homeowners facing 

hardship due to unemployment with a temporary forbearance, during which their regular monthly mortgage 

payment is reduced or suspended.

Home Retention Options: A loss mitigation solution available to a homeowner struggling to make a mortgage 

payment that allows the homeowner to stay in his or her home. Home retention options generally include 

HAMP or other types of loan modifications, forbearance or deferment, and repayment plans. 

Imminent Default: A homeowner status in which the homeowner has one or less mortgage payments 

outstanding, but is at risk of not being able to continue paying the monthly home loan payments due to financial 

hardship. 

In-Process Caseload: The actual number of homeowners in the process of being evaluated for home retention 

solutions (e.g., HAMP, alternative modifications, and other payment plan arrangements). 

Knowledge Assessment: A test given at the end of a training course to evaluate how well the participant 

learned the materials that were covered.

Liquidation Department: A department within the servicer’s organization that is tasked with working with 

homeowners that are completing a short sale, deed-in-lieu of foreclosure, or foreclosure transaction. 

Liquidation Options: Options available to a homeowner who can no longer stay in his or her home. 

Liquidation options include short sales, deeds-in-lieu of foreclosure, and foreclosure. 

Loan Workout: An alternative action to foreclosure to provide assistance to a homeowner who is facing 

difficulties making his or her monthly mortgage payment due to a hardship. Can include loan modifications, 

short sales, repayment plans, and various other forms of mortgage forbearance. 

Loss Mitigation: The process of a homeowner and the servicer working together to devise a solution for 

avoiding foreclosure. Includes home retention options as well as short sales or deeds-in-lieu of foreclosure. 

Modification: A change made to the terms of a homeowner’s loan. Loan modifications may include lowering 

the loan’s interest rate, extending the term of the loan, moving from an adjustable to a fixed-rate loan, deferring 

some portion of the unpaid principal balance to the end of the loan, and/or forgiving some portion of the unpaid 

principal balance. 

Modification Application Package: A set of required documents needed to apply for a mortgage 

modification. For purposes of MHA, the application package includes a (1) Request for Mortgage Assistance 

(RMA), (2) list of income documents necessary to support evidence of income, and (3) an IRS 4506T form 

which allows a servicer to access tax records.

Portfolio: The collection of loans held for servicing or investment. 

Private Label: Loans that have been securitized but that are not owned, insured or guaranteed by Fannie Mae, 

Freddie Mac, Ginnie Mae, or another Federal agency. 

Processor: Servicer personnel that support the SPOCs in the collection and review of homeowner’s 

documentation required for a loan modification application prior to being sent to underwriting.
 B-3

Real Time: The actual time during which a process takes place or an event occurs.

Relationship Manager: An alternative title for a homeowner’s single point of contact or SPOC. 

Repayment Plan: A home retention option in which the homeowner and servicer agree to a schedule for past 

due amounts to be paid in addition to paying the regularly scheduled mortgage payments. 

Resolution Times: The number of days from the date on which a SPOC is assigned to a homeowner to the date 

on which the servicer makes a final decision on a homeowner.

Right Party Contact (RPC): The successful effort by a servicer to establish contact and communicate with a 

homeowner. 

Seriously Delinquent: A homeowner mortgage payment status in which the homeowner is generally at least 

60 days or more past due on his or her mortgage payment. 

Servicer: A firm that works on behalf of a mortgage investor in support of a mortgage, including collecting 

payments, ensuring payment of real estate taxes and insurance premiums, managing escrow accounts, managing 

communications with the homeowner, and negotiating loss mitigation options or foreclosure when necessary. 

Short Sale: A loan workout program wherein the lender accepts the sale of a property to a third party for less 

than the total amount of the unpaid balance of the loan.

Single Point of Contact (SPOC): The single individual or team of individuals at the servicer organization who 

is responsible for serving as the homeowner’s contact point through the entire process of seeking help with his 

or her mortgage. Also known as a relationship manager. 

Skill Assessment: A test used to gauge how well a person can perform a particular task or action. 

SPOC Appointment-Based Model: A customer relationship model in which a customer service representative 

acts as an intermediary to receive inbound calls from homeowners to schedule an appointment time for the 

homeowner to speak to his or her SPOC. 

SPOC Direct Model: A customer relationship model in which the servicer assigns the homeowner a 

representative who is directly responsible for all inbound and outbound communications with that homeowner 

and for ensuring that an appropriate loss mitigation solution is reached. 

SPOC Pod Model: A customer relationship model in which a homeowner is not assigned to an individual 

SPOC, but is instead assigned to a larger SPOC team. Usually the SPOC team will include 10 to 12 SPOC 

representatives, one or two underwriters, and a manager.

Soft Skills Training: Training that focuses on improving an individual’s interactions with customers. 

System Transfer: A method of assigning a SPOC to a homeowner. A collections agent or customer service 

representative informs the homeowner that a SPOC will be assigned and will return his or her call within a set 

timeframe. A system will assign the SPOC and notify them of all new assignments.

Trial Modification: Under HAMP, the temporary plan (generally, three months) governing payment of a 

homeowner’s loan into which a qualified homeowner is placed. If the homeowner successfully completes the 

Trial Period Plan, the homeowner will be placed into a permanent modification of his or her loan. 

Trial Modification Offer: A letter that outlines the terms and amount of a homeowner’s mortgage payment as 

part of a Trial Period Plan to receive a permanent HAMP modification. 
 B-4

Underwriting: The process of examining all relevant information related to a homeowner’s property and 

income to determine whether the mortgage modification should be issued. The person who does this is called 

an underwriter. 

Warm Transfer: A method of assigning a SPOC to a homeowner. While the homeowner is still on the phone 

with the collections agent, the collections agent will contact an available SPOC and initiate a conference call 

between the homeowner, collections agent, and the SPOC. 

Web Portal: A web site that allows users to deliver or receive information in a secure, controlled manner. 

Weighted Average: An average in which each quantity to be averaged is assigned a weight. These weightings 

determine the relative importance of each quantity on the average. 
 C-1

Appendix C: Excerpt from Q2 2012 Servicer Assessments
MHA Servicer Assessment 

Overview

C-2

MHA Compliance Results, Loan File Review: Second Look % Disagree, 4th Quarter 20101-2nd Quarter 2012

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

4Q10 1Q11 2Q11 3Q11 4Q11 1Q12 2Q12

Bank of America CitMortgage GMAC Homeward Residential

JPMorgan Chase Litton Ocwen One West

Select Porfolio Servicing Wells Fargo Average

Second Look % Disagree: Percentage of loans reviewed where MHA-C did not concur with the servicer’s MHA determination. Treasury’s 

benchmark is that the second look % disagree must be less than 4%. The first servicer assessment results published by Treasury covered the 

first quarter of 2011. The chart shows the change in performance from the quarter preceding the first published assessments (fourth quarter of 

2010) through the most recent assessment.

Benchmark: 4%

1 The first servicer assessment covered the first quarter of 2011. The 
MHA Servicer Assessment 

Overview

C-3

MHA Compliance Results, Loan File Review: Second Look % Unable to Determine, 4th Quarter 2010-2nd Quarter 2012

0%

5%

10%

15%

20%

25%

30%

4Q10 1Q11 2Q11 3Q11 4Q11 1Q12 2Q 2012

Bank of America CitMortgage GMAC Homeward Residential

JPMorgan Chase Litton Ocwen One West

Select Porfolio Servicing Wells Fargo Average

Second Look % Unable to Determine: Percentage of loans reviewed where MHA-C was not able to conclude on the servicer’s MHA determination. 

Treasury’s benchmark is that the second look % unable to determine must be less than 10%. The first servicer assessment results published by 

Treasury covered the first quarter of 2011. The chart shows the change in performance from the quarter preceding the first published assessments 

(fourth quarter of 2010) through the most recent assessment.

Benchmark: 10%
MHA Servicer Assessment 

Overview

C-4

MHA Compliance Results, Loan File Review: Income Calculation Error %, 4th Quarter 2010-2nd Quarter 2012

0%

5%

10%

15%

20%

25%

30%

35%

4Q10 1Q11 2Q11 3Q11 4Q11 1Q12 2Q12

Bank of America CitMortgage GMAC Homeward Residential

JPMorgan Chase Litton Ocwen One West

Select Porfolio Servicing Wells Fargo Average

Income Calculation Error %: Percentage of loans for which MHA-C’s income calculation differs from the servicer’s by more than 5%. Treasury’s 

benchmark is that the income calculation error % must be less than 5%. Correctly calculating homeowner monthly income is a critical component of 

evaluating eligibility for MHA, as well as establishing an accurate modification payment. The first servicer assessment results published by Treasury 

covered the first quarter of 2011. The chart shows the change in performance from the quarter preceding the first published assessments (fourth 

quarter of 2010) through the most recent assessment.

Benchmark: 5%
MHA Servicer Assessment 

Overview

Second Look % Disagree1 Second Look % Unable to Determine2 Income Calculation Error Rate3

Servicer 

Q4 

2010

Q1 

2011

Q2 

2011

Q3 

2011

Q4 

2011

Q1 

2012

Q2 

2012

Q4 

2010

Q1 

2011

Q2 

2011

Q3 

2011

Q4 

2011

Q1 

2012

Q2 

2012

Q4 

2010

Q1 

2011

Q2 

2011

Q3 

2011

Q4 

2011

Q1 

2012

Q2 

2012

Bank of America, 

NA 2.4% 1.5% 0.8% 1.0% 1.0% 2.0% 1.0% 19.6% 18.8% 8.2% 1.5% 1.0% 1.0% 0.0% 22.0% 22.0% 13.2% 6.0% 6.0% 5.0% 2.0%

CitiMortgage, Inc. 4.0% 2.0% 0.5% 1.5% 1.0% 1.0% 1.0% 12.3% 13.3% 5.5% 0.5% 1.0% 0.5% 1.0% 8.0% 10.0% 12.0% 6.0% 3.0% 4.0% 1.0%

GMAC Mortgage, 

LLC 4.0% 4.7% 1.7% 1.0% 0.5% 0.0% 0.5% 22.7% 8.3% 0.7% 0.0% 0.0% 0.0% 1.0% 29.0% 6.0% 4.2% 4.2% 6.5% 4.0% 6.0%

Homeward 

Residential 5.3% 1.0% 0.7% 0.0% 1.5% 1.0% 1.0% 29.3% 5.3% 1.0% 0.0% 0.0% 1.0% 0.5% 30.0% 14.0% 5.3% 2.0% 1.0% 2.0% 1.0%

JPMorgan Chase 

Bank, NA 3.9% 1.6% 1.2% 0.0% 0.7% 0.2% 0.0% 16.0% 11.3% 3.2% 0.9% 1.0% 0.7% 1.7% 31.0% 31.0% 20.6% 6.0% 10.0% 9.0% 0.0%

Litton Loan 

Servicing, LP4 6.0% 3.7% 3.3% 1.0% N/A N/A N/A 5.7% 6.3% 2.7% 2.0% N/A N/A N/A 6.0% 6.0% 2.0% 1.0% N/A N/A N/A

Ocwen Loan 

Servicing, LLC 6.3% 6.7% 2.7% 0.0% 0.7% 1.0% 1.0% 24.7% 10.3% 3.0% 2.4% 0.0% 0.0% 0.0% 18.0% 33.0% 2.0% 2.0% 2.0% 3.0% 3.0%

OneWest Bank 4.7% 6.7% 0.7% 0.0% 0.0% 0.0% 0.0% 12.3% 3.7% 1.0% 0.0% 0.0% 0.0% 0.0% 11.0% 11.0% 2.0% 2.0% 0.0% 3.0% 1.0%

Select Portfolio 

Servicing 2.0% 0.0% 0.0% 0.8% 0.0% 0.0% 0.5% 17.0% 2.3% 0.3% 0.8% 0.0% 3.0% 0.0% 22.0% 15.0% 10.0% 3.2% 1.0% 3.0% 2.0%

Wells Fargo Bank, 

NA8 1.7% 1.2% 0.4% 0.4% 0.0% 0.3% 1.0% 6.8% 6.0% 1.3% 1.3% 0.0% 0.0% 0.8% 27.0% 27.0% 4.4% 5.5% 4.0% 2.0% 0.0%

1 Second Look % Disagree: Percentage of loans reviewed where MHA-C did not concur with the servicer’s MHA determination.

2 Second Look % Unable to Determine: Percentage of loans reviewed where MHA-C was not able to conclude on the servicer’s MHA 

determination.

3 Income Calculation Error %: Percentage of loans for which MHA-C’s income calculation differs from the servicer’s by more than 5%. 

Correctly calculating homeowner monthly income is a critical component of evaluating eligibility for MHA, as well as establishing an 

accurate modification payment. 

4 Effective November 1, 2011 Litton Loan Servicing, LP transferred its loan portfolio to Ocwen Loan Servicing, LLC.

MHA Compliance Results, Loan File Review: 4th Quarter 2010 – 2nd Quarter 2012

C-5