Making Home Affordable

Program Performance Report Through March 2011

Report Highlights Inside:

Over 670,000 Homeowners Granted Permanent Modifications

• More than 36,000 new permanent modifications were reported in March; some began in 

prior months and were recently entered into the HAMP system of record.

• Homeowners granted permanent modifications realize aggregate reductions in monthly 

mortgage payments of nearly $5.9 billion, program to date. 

• Additionally, servicers continue to start trial modifications at a steady pace, averaging 

about 29,000 new trial modifications for the last six months.

• More than 1.5 million homeowners have entered trial modifications since program 

inception. 

Permanent Modifications Perform Well Over Time;

Larger Payment Reductions Exhibit Stronger Performance

• Homeowners whose housing payment was cut by more than 50% through a HAMP 

permanent modification performed significantly better than those with payment 

reductions of 20% or less. After one year, fewer than 12% of borrowers with a payment 

reduction greater than 50% were 60+ days delinquent.

• At 12 months, more than 84% of homeowners remain in HAMP permanent modifications. 

The remaining 16% have been disqualified from the program for missing three 

consecutive payments.

• HAMP permanent modifications continue to be sustained at better rates than 

industry modifications.

Inside: Improved Report Format

• Revamped presentation includes program-level data first, followed by servicer-specific 

performance data.

• Expanded chart sizes for easier readability.

SUMMARY RESULTS:

Snapshot of MHA Programs

Characteristics of First Lien Modifications

Performance of Permanent Modifications

HAMP Activity by State

HAMP Activity by MSA/

Homeowner Outreach

Aged Trials

2

3

4-5

6

7

8

SERVICER RESULTS:

Modification Activity by Servicer

Trial Length

Conversion Rate

Disposition of Homeowners Not in HAMP

Homeowner Experience

Modifications by Investor Type

9

10

11

12-13

14

15

APPENDICES:

Participants in MHA Programs

Definitions of Compliance Activities

Areas of Compliance Emphasis

16-17

18

19
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

The Treasury FHA-HAMP program provides assistance to eligible 

homeowners with FHA-insured mortgages.

All Second Lien Modifications Started 21,298

HAMP Activity: First Lien Modifications

Total

HAMP Eligibility 

(As of Feb. 28, 2011)

Eligible Delinquent Loans1 2,813,406

Eligible Delinquent Borrowers2 1,341,857

Trial

Modifications

Trial Plan Offers Extended (Cumulative)3 1,820,372

All Trials Started 1,559,023

Trials Reported Since February 2011 

Report4 36,827

Trial Modifications Canceled (Cumulative) 751,474

Active Trials 137,363

Permanent 

Modifications

All Permanent Modifications Started 670,186

Permanent Modifications Reported Since 

February 2011 Report 36,432

Permanent Modifications Canceled 

(Cumulative)5 83,270

Active Permanent Modifications 586,916

1 Estimated eligible 60+ day delinquent loans as reported by servicers as of February 28, 2011, include conventional loans: 

 in foreclosure and bankruptcy.

 with a current unpaid principal balance less than $729,750 on a one-unit property, $934,200 on a two-unit property, 

$1,129,250 on a three-unit property and $1,403,400 on a four-unit property.

 on a property that was owner-occupied at origination.

 originated on or before January 1, 2009.

Estimated eligible 60+ day delinquent loans exclude: 

 FHA and VA loans.

 loans that are current or less than 60 days delinquent, which may be eligible for HAMP if a borrower is in imminent 

default. 2 The estimated eligible 60+ day delinquent borrowers are those in HAMP-eligible loans, minus estimated exclusions of 

loans on vacant properties, loans with borrower debt-to-income ratio below 31%, loans that fail the NPV test, 

properties no longer owner-occupied, manufactured housing loans with title/chattel issues that exclude them from 

HAMP, and loans where the investor pooling and servicing agreements preclude modification. Exclusions for DTI and 

NPV results are estimated using market analytics. 3 As reported in the weekly servicer survey of large SPA servicers through March 31, 2011.

4 Servicers may enter new trial modifications into the HAMP system of record at anytime. 5 A permanent modification is canceled when the borrower has missed three consecutive monthly payments. Includes 

1,126 loans paid off.

Second Lien Modification Program (2MP) Activity 

All Treasury FHA-HAMP Trial Modifications Started 3,860

Treasury FHA-HAMP Permanent Modifications Started 2,414

HAMP is designed to lower monthly mortgage payments to help struggling 

homeowners stay in their homes and prevent avoidable foreclosure. 

The Second Lien Modification Program (2MP) provides assistance to 

homeowners in a first lien permanent modification who have an eligible 

second lien with a participating servicer.

Treasury FHA-HAMP Modification Activity

All HAFA Agreements Started1 12,266

HAFA Transactions Completed 5,447

Home Affordable Foreclosure Alternatives (HAFA) Activity

The Home Affordable Foreclosure Alternatives Program (HAFA) offers 

incentives for homeowners looking to exit their homes through a short sale or 

deed in lieu of foreclosure.

Note: Number of modifications is net of cancellations, which are primarily due to servicer data corrections.

1 Servicer agreement with homeowner for terms of potential short sale, which lasts at least 120 days; or 

agreement for a deed-in-lieu transaction. A short sale requires a third-party purchaser and cooperation of 

junior lienholders and mortgage insurers to complete the transaction. All HAFA Agreements Started include 

HAFA Transactions Completed.

See Appendix A2 on Page 17 for servicer participants in additional 

Making Home Affordable programs. 

Note: Unless specified, exhibits in this report refer to HAMP first lien modification activity. 

2
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

• The primary hardship reasons for homeowners in active permanent 

modifications are:

• 61.0% experienced loss of income (curtailment of income or 

unemployment)

• 11.5% reported excessive obligation

• 2.8% reported an illness of the principal borrower

Homeowner Benefits and Modification Characteristics

Loan Characteristic

Before 

Modification

After 

Modification

Median 

Decrease

Front-End Debt-to-Income Ratio1 45.3% 31.0% -14.3 pct pts

Back-End Debt-to-Income Ratio2 79.3% 62.5% -14.8 pct pts

Median Monthly Housing 

Payment3 $1,430.76 $833.03 -$525.94

1 Ratio of housing expenses (principal, interest, taxes, insurance and homeowners association and/or condo 

fees) to monthly gross income. 

2 Ratio of total monthly debt payments (including mortgage principal and interest, taxes, insurance, homeowners 

association and/or condo fees, plus payments on installment debts, junior liens, alimony, car lease payments and 

investment property payments) to monthly gross income. Borrowers who have a back-end debt-to-income ratio of 

greater than 55% are required to seek housing counseling under program guidelines.

3 Principal and interest payment. 

Select Median Characteristics of Active Permanent Modifications

HAMP Trials Started

956

1,051

1,138

1,209

1,257 1,283 1,305 1,330 1,353 1,384 1,414 1,444 1,478 1,506

1,537 1,559

0

50

100

150

200

400

800

1,200

1,600

Dec '09 Jan '10 Feb Mar Apr May June July Aug Sep Oct Nov Dec Jan '11 Feb Mar

New Trials Started (000s)

All Trials Started (000s)

Cumulative Trial Starts (Left Axis)

Monthly Trial Starts (Right Axis)

Source: HAMP system of record. Servicers may enter new trial modifications into the HAMP system of record at any 

time. For example, 36,827 trials have entered the HAMP system of record since the prior report; of those, 22,002 were 

trials with a first payment recorded in March 2011. 

Permanent Modifications Started (Cumulative)

67

117

170

231

299

347

398

435

468

496

520

550

580

608 634

670

0

100

200

300

400

500

600

700

Dec '09Jan '10 Feb Mar Apr May June July Aug Sep Oct Nov Dec Jan '11 Feb Mar

All Permanent Modifications Started (000s)

Source: HAMP system of record.

• Of trial modifications started, 78% of homeowners were at least 60 

days delinquent at trial start. The rest were up to 59 days delinquent 

or in imminent default. 

3

• Aggregate savings to homeowners who received HAMP first lien 

permanent modifications are estimated to total nearly $5.9 

billion, program to date, compared with unmodified mortgage 

obligations.

• The median monthly savings for borrowers in active permanent 

first lien modifications is $525.94, or 37% of the median monthly 

payment before modification. 

• Active permanent modifications feature the following modification steps:

• 100% feature interest rate reductions

• 59.5% offer term extension

• 30.5% include principal forbearance
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

Performance of Permanent Modifications (As of February 28, 2011)

Modification 

Became 

Permanent in:

Delinquency: Months After Conversion to Permanent

3 6 9 12

# 60+ 

Days

90+ 

Days # 60+ Days

90+ 

Days # 60+ Days

90+ 

Days # 60+ Days

90+ 

Days

Q3 2009 3,584 9.8% 3.5% 4,457 14.9% 9.8% 4,713 19.6% 14.9% 4,701 25.4% 20.6%

Q4 2009 44,375 5.3% 1.4% 48,241 9.6% 5.7% 51,105 15.3% 10.6% 52,291 19.9% 15.3%

Q1 2010 125,805 3.7% 1.0% 152,605 9.7% 5.3% 160,638 16.0% 11.1% 164,881 20.2% 16.0%

Q2 2010 150,535 5.0% 1.4% 160,335 11.8% 7.0% 171,461 16.9% 12.4%

Q3 2010 86,928 4.7% 1.4% 97,052 10.8% 6.7%

Q4 2010 58,592 4.3% 1.5%

ALL 469,819 4.6% 1.3% 462,690 10.7% 6.3% 387,917 16.4% 11.7% 221,873 20.3% 15.9%

• For permanent loans aged at least 3 months as of Feb. 28, 2011, as reported by servicers through March 17, 2011. 

• The table stratifies the data by the quarter in which the permanent modification became effective and provides two separate performance metrics: 

• 60+ days delinquent: All loans that have missed two or more consecutive monthly payments, including 90+ days delinquent loans.

• 90+ days delinquent: All loans that have missed three or more consecutive monthly payments.

• Loan payment status is not reported by servicers after program disqualification (90+ days delinquent). Therefore, 90+ days delinquent loans are included in each of the 60+ days 

delinquent and 90+ days delinquent metrics for all future reporting periods, even though some loans may have cured or paid off following program disqualification.

• This table reflects a total of 63,807 disqualified loans that have aged 3, 6, 9, or 12 months through the February activity period as reported by servicers through March 17, 2011. 

• Servicers are required to report monthly payment information on HAMP modifications in the form of an Official Monthly Report (OMR). If a servicer does not report an OMR for a 

loan in a given month, the performance of that loan is not included in the table for that month. This table reflects improved servicer OMR reporting as the modification ages, 

causing the total loan count for each quarter in months 6 and beyond to be higher than the count in month 3. Reported loan counts may shift from prior reports due to servicer 

data corrections.

• Once a loan is paid off, it is no longer reflected in future periods. 

• Beyond 12 months, performance will be noted in 6-month increments, beginning next quarter. This table will be published quarterly.

This table shows the performance of permanent HAMP modifications at 3, 6, 9, and 12 months of age and includes 

modifications that have aged at least 3, 6, 9, or 12 months, as applicable. For example: 

Of loans that became permanent in the 3rd quarter of 2010, 10.8% were 60+ days delinquent at six months’ seasoning. 

4
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

Performance of Permanent Modifications by Homeowner Payment Reduction (As of February 28, 2011)

Decrease From

BeforeModification 

Principal + Interest 

Payment:

Delinquency: Months After Conversion to Permanent

3 6 9 12

# 60+ 

Days

90+ 

Days # 60+ Days

90+ 

Days # 60+ Days

90+ 

Days # 60+ Days

90+ 

Days

≤20% Decrease 91,083 7.9% 2.4% 89,511 18.1% 11.1% 75,272 26.7% 19.7% 41,780 32.1% 26.0%

(20%-30%] Decrease 73,787 5.7% 1.7% 72,587 13.4% 7.9% 60,756 20.3% 14.7% 34,805 25.0% 20.0%

(30%-40%] Decrease 83,334 4.4% 1.2% 82,038 10.5% 6.2% 68,907 16.3% 11.6% 40,158 20.7% 16.1%

(40%-50%] Decrease 86,001 3.5% 0.9% 84,464 8.5% 4.8% 70,558 13.3% 9.2% 41,047 17.1% 13.1%

>50% Decrease 135,614 2.6% 0.6% 134,090 5.9% 3.1% 112,424 9.2% 6.2% 64,083 11.7% 8.8%

ALL 469,819 4.6% 1.3% 462,690 10.7% 6.3% 387,917 16.4% 11.7% 221,873 20.3% 15.9%

Note: For permanent loans aged at least 3 months as of Feb. 28, 2011, as reported by servicers through March 17, 2011. See previous page for technical notes.

0%

10%

20%

30%

40%

3 6 9 12

60+ Day Delinquency Rate

Months After Conversion to Permanent Modification

60+ Day Delinquency Rate by Payment Reduction

Decreased by 20% or less

Decreased above 20% up to 

and including 30%

Decreased above 30% up to 

and including 40%

Decreased above 40% up to 

and including 50%

Decreased by more than 

50%

This chart and the table that follows show the performance of permanent HAMP modifications at 3, 6, 9, and 12 months of age as related to homeowner payment 

reduction. For example: Of loans that featured a payment reduction between 40% and 50%, 8.5% were 60+ days delinquent at six months’ seasoning. 

5
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

6

Note: Includes active trial and permanent 

modifications from the official HAMP system of 

record.

Source: 4th Quarter 2010 

National Delinquency 

Survey, Mortgage 

Bankers Association.

State

Active 

Trials

Permanent 

Modifications Total

% of 

Total State

Active 

Trials

Permanent 

Modifications Total

% of 

Total 

AK 54 251 305 0.0% MT 175 649 824 0.1%

AL 868 3,393 4,261 0.6% NC 2,338 10,910 13,248 1.8%

AR 302 1,285 1,587 0.2% ND 24 101 125 0.0%

AZ 5,157 27,926 33,083 4.6% NE 201 794 995 0.1%

CA 33,459 139,269 172,72

8 23.8% NH 590 2,737 3,327 0.5%

CO 1,597 8,222 9,819 1.4% NJ 4,413 18,935 23,348 3.2%

CT 1,585 7,464 9,049 1.2% NM 481 1,864 2,345 0.3%

DC 231 999 1,230 0.2% NV 3,389 15,296 18,685 2.6%

DE 429 1,817 2,246 0.3% NY 6,610 26,378 32,988 4.6%

FL 17,866 69,194 87,060 12.0% OH 3,140 13,176 16,316 2.3%

GA 5,075 21,408 26,483 3.7% OK 384 1,338 1,722 0.2%

HI 531 2,249 2,780 0.4% OR 1,439 6,421 7,860 1.1%

IA 366 1,483 1,849 0.3% PA 2,838 12,245 15,083 2.1%

ID 541 2,244 2,785 0.4% RI 674 3,079 3,753 0.5%

IL 7,188 31,727 38,915 5.4% SC 1,268 5,580 6,848 0.9%

IN 1,371 5,770 7,141 1.0% SD 52 226 278 0.0%

KS 359 1,378 1,737 0.2% TN 1,516 6,030 7,546 1.0%

KY 550 2,238 2,788 0.4% TX 4,048 15,027 19,075 2.6%

LA 933 3,106 4,039 0.6% UT 1,191 5,540 6,731 0.9%

MA 3,172 14,738 17,910 2.5% VA 2,923 14,513 17,436 2.4%

MD 4,102 19,016 23,118 3.2% VT 119 484 603 0.1%

ME 386 1,636 2,022 0.3% WA 2,879 11,470 14,349 2.0%

MI 4,165 19,652 23,817 3.3% WI 1,408 5,785 7,193 1.0%

MN 2,038 10,595 12,633 1.7% WV 178 903 1,081 0.1%

MO 1,476 6,208 7,684 1.1% WY 63 308 371 0.1%

MS 493 2,281 2,774 0.4% Other* 728 1,578 2,306 0.3%

*Includes Guam, Puerto Rico and the U.S. Virgin Islands.

Note: Total reflects active trials and active permanent modifications.

60+ Day Delinquency Rate

5.0% and lower 10.01% - 15.0% 20.01%

5.01% - 10.0% 15.01% - 20.0% and higher

HAMP Modifications

5,000 and lower 20,001 – 35,000

5,001 – 10,000 35,001 and higher

10,001 – 20,000 

HAMP Activity by State Modification Activity by State

Mortgage Delinquency Rates by State
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

Homeowner Outreach Events Hosted Nationally by 

Treasury and Partners (cumulative) 52

Homeowners Attending Treasury-Sponsored Events 

(cumulative) 52,229

Servicer Solicitation of Borrowers (cumulative)1 7,356,933

Page views on MakingHomeAffordable.gov

(March 2011) 2,458,228

Page views on MakingHomeAffordable.gov (cumulative) 115,426,330

1 Source: Survey data provided by SPA servicers. Servicers are encouraged by HAMP to solicit information from 

borrowers 60+ days delinquent, regardless of eligibility for a HAMP modification. 

Program to 

Date March

Total Number of Calls Taken at 

1-888-995-HOPE 2,136,421 81,379

Borrowers Receiving Free Housing 

Counseling Assistance Through the 

Homeowner’s HOPETM Hotline

1,020,770 39,290

Selected Homeowner Outreach Measures

Call Center Volume

Source: Homeowner’s HOPETM Hotline.

A complete list of HAMP activity for all metropolitan areas is available at

http://www.treasury.gov/initiatives/financial-stability/results/MHA-Reports/

7

Metropolitan Statistical Area

Active

Trials

Permanent

Modifications

Total 

HAMP 

Activity

% of All 

HAMP 

Activity

Los Angeles-Long Beach-Santa 

Ana, CA 9,874 40,538 50,412 7.0%

New York-Northern New JerseyLong Island, NY-NJ-PA 8,513 35,938 44,451 6.1%

Riverside-San Bernardino-Ontario, 

CA 6,716 31,053 37,769 5.2%

Chicago-Joliet-Naperville, IL-IN-WI 6,913 30,686 37,599 5.2%

Miami-Fort Lauderdale-Pompano 

Beach, FL 7,610 27,445 35,055 4.8%

Phoenix-Mesa-Glendale, AZ 4,084 22,992 27,076 3.7%

Washington-Arlington-Alexandria, 

DC-VA-MD-WV 4,037 20,433 24,470 3.4%

Atlanta-Sandy Springs-Marietta, GA 4,058 17,306 21,364 2.9%

Las Vegas-Paradise, NV 2,840 12,540 15,380 2.1%

Detroit-Warren-Livonia, MI 2,537 11,870 14,407 2.0%

Orlando-Kissimmee-Sanford, FL 2,621 11,075 13,696 1.9%

San Francisco-Oakland-Fremont,

CA 2,991 10,638 13,629 1.9%

Boston-Cambridge-Quincy, 

MA-NH 2,204 10,576 12,780 1.8%

Sacramento-Arden-ArcadeRoseville, CA 2,385 9,948 12,333 1.7%

San Diego-Carlsbad-San Marcos, 

CA 2,267 9,971 12,238 1.7%

15 Metropolitan Areas With Highest HAMP Activity

Note: Total reflects active trials and active permanent modifications.
Making Home Affordable: Summary Results

Program Performance Report Through March 2011

Aged Trials1

190,412

165,543

117,574

94,269

76,502

69,418

49,229

39,753 36,184 32,017 26,362

0

50,000

100,000

150,000

200,000

May 2010 June July Aug Sept Oct Nov Dec Jan 2011 Feb March 

Trials Lasting 6 Months or Longer At End of Month

1 Active trials initiated at least six months ago. See page 9 for servicer volume of aged-trials. These figures include trial modifications that have been 

converted to permanent modifications by the servicer and are pending reporting to the HAMP system of record. 

The volume of trials lasting 6 months or longer has fallen to below 26,400.

Program guidance directs servicers to cancel or convert trial modifications after 

three or four monthly payments, depending on circumstances.

8
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

As of 

Feb. 28, 2011 Cumulative As of March 31, 2011

Servicer 

Estimated 

Eligible 60+ 

Day 

Delinquent

Borrowers1 

Trial Plan 

Offers 

Extended2

All HAMP 

Trials 

Started3

All HAMP 

Permanent 

Modifications

Started3

Trial 

Modifications 

Reported Since 

February 2011

Report3

Active Trial 

Modifications3

Active Trial 

Modifications 

Lasting 6

Months or 

Longer4

Active 

Permanent 

Modifications3

American Home Mortgage Servicing 

Inc. 49,370 34,748 31,597 23,472 1,670 4,035 1,085 20,762

Aurora Loan Services, LLC 27,673 50,633 39,722 15,319 315 1,908 195 13,619

Bank of America, NA5 383,154 509,907 378,584 123,296 12,622 43,439 9,364 107,010

CitiMortgage, Inc. 93,451 174,885 129,545 49,886 1,140 6,032 1,740 44,736

GMAC Mortgage, LLC 14,093 71,699 59,477 41,688 1,385 3,761 75 36,650

Green Tree Servicing LLC 5,975 8,274 9,854 5,606 98 678 170 5,175

J.P. Morgan Chase Bank, NA6 199,075 299,987 241,843 90,782 8,190 24,688 2,315 75,973

Litton Loan Servicing LP 40,265 41,072 36,111 10,767 227 1,874 200 8,924

Nationstar Mortgage LLC 31,566 31,173 54,355 26,191 651 2,501 552 23,629

Ocwen Loan Services LLC 40,796 46,364 43,242 32,136 723 4,816 940 26,058

OneWest Bank 40,289 67,493 50,533 26,438 698 3,250 453 23,879

PNC Mortgage7 12,557 24,310 19,332 5,782 105 707 38 5,244

Saxon Mortgage Services, Inc. 21,022 43,010 37,959 15,061 191 1,057 312 13,473

Select Portfolio Servicing 16,813 66,986 41,197 21,193 217 1,441 145 18,254

US Bank NA 13,617 16,254 16,569 11,148 449 2,546 699 9,888

Wells Fargo Bank, NA8 153,401 307,687 223,052 89,134 3,628 15,536 1,709 80,111

Other SPA Servicers9 18,822 25,890 24,502 15,220 872 1,995 472 13,244

Other GSE Servicers10 179,918 NA 121,549 67,067 3,646 17,099 5,898 60,287

Total 1,341,857 1,820,372 1,559,023 670,186 36,827 137,363 26,362 586,916

1 Estimated eligible 60+ day delinquent borrowers as reported by servicers 

as of February 28, 2011, include those in conventional loans: 

 in foreclosure and bankruptcy.

 with a current unpaid principal balance less than $729,750 on a oneunit property, $934,200 on a two-unit property, $1,129,250 on a 

three-unit property and $1,403,400 on a four-unit property.

 on a property that was owner-occupied at origination.

 originated prior to January 1, 2009.

Estimated eligible 60+ day delinquent borrowers excludes: 

 Those in FHA and VA loans.

 Those in loans that are current or less than 60 days delinquent, 

which may be eligible for HAMP if a borrower is in imminent default.

 Those borrowers with debt-to-income ratios less than 31% or a 

negative NPV test.

 Owners of vacant properties or properties otherwise excluded.

Exclusions for DTI and NPV are estimated using market analytics. 2 As reported in the weekly servicer survey of large SPA servicers through 

March 31, 2011. 3 As reported into the HAMP system of record by servicers. Excludes 

FHA-HAMP modifications. Subject to adjustment based on servicer 

reconciliation of historic loan files. Totals reflect impact of servicing 

transfers. Servicers may enter new trial modifications into the HAMP 

system of record at any time. 4 These figures include trial modifications that have been converted to 

permanent modifications by the servicer and are pending reporting to 

the HAMP system of record.

5 Bank of America, NA includes Bank of America, NA, BAC Home Loans 

Servicing LP, Home Loan Services and Wilshire Credit Corporation. 6 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation.

7 Formerly National City Bank.

8 Wells Fargo Bank, NA includes all loans previously reported under 

Wachovia Mortgage, FSB. 9 Other SPA servicers are entities with less than 5,000 estimated eligible 

60+ day delinquent borrowers as of February 28, 2011, that have 

signed participation agreements with Treasury and Fannie Mae. A full 

list of participating servicers is in Appendix A. 10 Includes servicers of loans owned or guaranteed by Fannie Mae and 

Freddie Mac. Includes GSE loans transferred from SPA servicers.

HAMP Modification Activity by Servicer

9
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

Length of Trial Upon Conversion1

1 For all permanent modifications started. 

3.0

4.2

4.6

6.3

3.3

3.6

7.6

3.3

4.9

3.1

4.4

3.2

6.3

3.6

3.9

4.4

3.7 3.6

0

1

2

3

4

5

6

7

8

Am. Home 

Servicing

Aurora Bank of 

America

CitiMortgage GMAC Green Tree JP Morgan 

Chase

Litton Nationstar Ocwen OneWest PNC 

Mortgage

Saxon SPS US Bank Wells Fargo Other GSE 

servicers

Other SPA 

Servicers

Months

Program Average: 

4.8 Months

Servicers are directed to cancel or convert trial 

modifications after three or four monthly payments, 

depending on circumstances. 

10
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

78%

65%

54%

73%

79%

61%

57%

74%

78%

76%

67%

82%

75%

84%

55%

75%

70%

81%

0%

20%

40%

60%

80%

100%

Am. Home 

Servicing

Aurora Bank of 

America

CitiMortgage GMAC Green Tree JPMorgan 

Chase

Litton Nationstar Ocwen OneWest PNC 

Mortgage

Saxon SPS U.S. Bank Wells Fargo Other GSE

Servicers

Other SPA 

Servicers

Conversion Rate

Average of Post 6/1/10 Starts Average of Pre-6/1/10 Starts

Of Trials Started Pre-6/1/10:

41% Converted to Permanent Modification

1% Pending Processing or Decision

Of Eligible Trials Started Post-6/1/10:

68% Converted to Permanent Modification

23% Pending Processing or Decision

Conversion Rate1

Note: Per program guidelines, effective June 1, 2010 all trials must be started using verified income. Prior to June 1, some servicers initiated trials using stated income information. 

1 As measured against trials eligible to convert – those three months in trial, or four months if the borrower was at risk of imminent default at trial modification start. Permanent 

modifications transferred among servicers are credited to the originating servicer. Trial modifications transferred are reflected in the current servicer’s population.

Following the implementation of verified income documentation 

in June 2010, rates of converting trial modifications into 

permanent modifications rose for most servicers.

11
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

Disposition Path 

Homeowners in Canceled HAMP Trial Modifications

Survey Data Through February 2011 (10 Largest Servicers)

Homeowners Whose HAMP Trial Modification Was Canceled Who Are in the Process of:

Servicer

Action 

Pending1

Action Not 

Allowed –

Bankruptcy 

in Process

Borrower

Current

Alternative 

Modification

Payment 

Plan2 Loan Payoff

Short Sale/

Deed-inLieuForeclosure 

Starts

Foreclosure

Completions

Total

(As of 

February 

2011)

American Home 

Mortgage Servicing Inc. 392 36 145 1,906 17 76 171 409 50 3,202

Bank of America, NA3 39,876 5,591 24,671 77,006 1,931 3,143 23,632 26,454 5,025 207,329

CitiMortgage Inc. 17,139 3,718 5,654 29,449 1,009 1,480 1,767 9,630 2,090 71,936

GMAC Mortgage, LLC 1,628 417 1,086 5,776 220 334 790 1,766 1,231 13,248

JP Morgan Chase Bank 

NA4 8,740 795 3,809 59,416 446 4,056 5,652 22,824 9,819 115,557

Litton Loan Servicing LP 2,618 599 1,725 12,430 298 152 1,176 2,059 743 21,800

Ocwen Loan Services 

LLC 382 106 372 2,434 378 32 297 1,679 523 6,203

OneWest Bank 707 813 596 9,762 352 27 1,010 4,153 3,231 20,651

Select Portfolio 

Servicing 1,607 519 1,462 5,582 426 301 1,219 2,317 2,363 15,796

Wells Fargo Bank NA5 2,354 738 13,292 59,224 943 8,630 4,485 17,528 11,194 118,388

TOTAL 

(These 10 Largest

Servicers)

75,443

12.7%

13,332

2.2%

52,812

8.9%

262,985

44.3%

6,020

1.0%

18,231

3.1%

40,199

6.8%

88,819

14.9%

36,269

6.1%

594,110

100.0%

Note: Data is as reported by servicers for actions completed through February 28, 2011. Survey data is not subject to the same data quality checks as data uploaded into the HAMP system of record. 1 Trial loans that have been canceled, but no further action has yet been taken. 2 An arrangement with the borrower and servicer that does not involve a formal loan modification. 

3 Bank of America, NA includes Bank of America, NA, BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 4 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation.

5 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB.

Note: Excludes cancellations pending data corrections and loans otherwise removed from servicing portfolios. 

The most common causes of 

trial cancellations from all 

servicers are:

• Insufficient documentation

• Trial plan payment default 

• Ineligible borrower: 

first lien housing expense is 

already below 31% of 

household income

12
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

Disposition Path 

Homeowners Not Accepted for HAMP Trial Modifications

Survey Data Through February 2011 (10 Largest Servicers)

Homeowners Not Accepted for a HAMP Trial Modification Who Are in the Process of:

Servicer

Action 

Pending1

Action Not 

Allowed –

Bankruptcy 

in Process

Borrower

Current

Alternative 

Modification

Payment 

Plan2 Loan Payoff

Short Sale/

Deed-inLieuForeclosure 

Starts

Foreclosure

Completions

Total

(As of 

February 

2011)

American Home 

Mortgage Servicing Inc. 1,585 734 6,148 24,533 674 465 1,237 5,307 751 41,434

Bank of America, NA3 35,331 6,170 49,230 79,003 3,312 3,332 31,154 47,625 15,775 270,932

CitiMortgage Inc. 36,202 8,157 11,746 29,503 6,234 13,367 1,876 8,176 5,472 120,733

GMAC Mortgage, LLC 24,754 6,294 33,942 38,500 4,323 2,802 6,541 21,805 11,344 150,305

JP Morgan Chase Bank 

NA4 73,530 4,237 87,100 109,228 1,325 34,995 14,081 47,468 12,917 384,881

Litton Loan Servicing LP 8,576 3,748 8,006 15,884 998 613 4,422 8,439 3,495 54,181

Ocwen Loan Services 

LLC 7,647 1,886 17,805 30,597 6,935 1,488 4,988 15,653 5,899 92,898

OneWest Bank 5,665 2,985 24,722 10,318 2,198 809 2,767 13,892 6,277 69,633

Select Portfolio 

Servicing 2,741 336 2,431 3,141 342 148 606 1,732 966 12,443

Wells Fargo Bank NA5 16,130 4,139 45,151 55,183 1,758 10,542 11,613 17,993 13,629 176,138

TOTAL 

(These 10 Largest 

Servicers)

212,161

15.4%

38,686

2.8%

286,281

20.8%

395,890

28.8%

28,099

2.0%

68,561

5.0%

79,285

5.8%

188,090

13.7%

76,525

5.6%

1,373,578

100.0%

Note: Data is as reported by servicers for actions completed through February 28, 2011. Survey data is not subject to the same data quality checks as data uploaded into the HAMP system of record. 1 Homeowners who were not approved for a HAMP trial modification, but no further action has yet been taken. 2 An arrangement with the borrower and servicer that does not involve a formal loan modification. 

3 Bank of America, NA includes Bank of America, NA, BAC Home Loans Servicing LP, Home Loan Services and Wilshire Credit Corporation. 4 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation.

5 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB.

Note: Excludes loans removed from servicing portfolios. 

The most common causes of 

trials not accepted from all 

servicers are:

• Insufficient documentation

• Ineligible borrower: 

first lien housing expense is 

already below 31% of 

household income

• Ineligible mortgage

13
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

Program to date, there have been 1,048,710 calls to the Homeowner’s 

HOPETM Hotline regarding a specific SPA servicer, of which 6.5% included 

complaints. Below shows specific complaint rates.

Source: Homeowner’s HOPETM Hotline.

Note: Complaint rate is the share of a specific servicer’s call volume that are complaints (e.g., for all calls about OneWest, 10.3% 

included complaints.)

Homeowner Experience (10 Largest Servicers)

Average Speed to Answer Homeowner Calls (February)

0

10

20

30

40

50

60

70

80

Am. Home 

Servicing

Bank of 

America

CitiMortgage GMAC JP Morgan 

Chase

Litton Ocwen OneWest SPS Wells Fargo

Seconds

Average Speed to Answer 

Calls to Homeowner’s 

HOPETM Hotline for February: 

16.6 Seconds

Call Abandon Rate (February)

0%

1%

2%

3%

4%

5%

6%

Am. Home 

Servicing

Bank of 

America

CitiMortgage GMAC JP Morgan 

Chase

Litton Ocwen OneWest SPS Wells Fargo

Homeowner’s HOPETM Hotline Average 

Call Abandon Rate for February: 3.4%

Source: Survey data through February 28, 2011 from servicers on call volume to loss mitigation lines; Homeowner’s 

HOPETM Hotline.

Source: Survey data through February 28, 2011, from servicers on call volume to loss mitigation lines; 

Homeowner’s HOPETM Hotline.

Servicer Time to Resolve Third-Party Escalations 

(Program to Date, Through March)

0

10

20

30

40

50

60

Am. Home 

Servicing

Bank of 

America

CitiMortgage GMAC JP Morgan 

Chase

Litton Ocwen OneWest SPS Wells Fargo

Resolved: 407 4,966 1,044 747 3,015 529 516 709 173 2,694

Cases (PTD) Calendar Days

Target: 30 Calendar Days

Source: HAMP Solutions Center. Target of 30 calendar days, effective Feb. 1, 2011, includes 

an estimated 5 days of processing by HAMP Solutions Center.

Servicer Complaint Rate to Homeowner’s HOPETM Hotline

(Program to Date, Through March)

Calls to 

Servicer:

3%

4%

5%

6%

7%

8%

9%

10%

11%

Am. Home 

Servicing

Bank of 

America

CitiMortgage GMAC JP Morgan 

Chase

Litton Ocwen OneWest SPS Wells Fargo

% of Calls for Specific 

Servicer

Complaints

(PTD): 1,901 22,982 5,882 2,743 13,789 1,465 1,961 224 556 9,110

Program to Date Average: 6.5% 

14
Making Home Affordable: Servicer Results

Program Performance Report Through March 2011

Servicer GSE Private Portfolio

Total Active 

Modifications

Bank of America, NA1 88,716 53,453 8,280 150,449

JP Morgan Chase NA2 46,116 36,962 17,583 100,661

Wells Fargo Bank, NA 3 47,253 13,928 34,466 95,647

CitiMortgage, Inc. 29,638 4,460 16,670 50,768

GMAC Mortgage, LLC 23,525 5,955 10,931 40,411

Ocwen Loan Services LLC 7,065 23,676 133 30,874

OneWest Bank 13,023 12,070 2,036 27,129

Nationstar Mortgage LLC 19,264 5,571 1,295 26,130

American Home Mortgage Servicing Inc. 1,317 23,477 3 24,797

Select Portfolio Servicing 510 16,713 2,472 19,695

Aurora Loan Services, LLC 7,321 7,987 219 15,527

Saxon Mortgage Services Inc. 1,505 11,299 1,726 14,530

US Bank NA 8,311 20 4,103 12,434

Litton Loan Servicing LP 92 10,694 12 10,798

PNC Mortgage4 5,157 296 498 5,951

Green Tree Servicing LLC 5,427 408 18 5,853

Other HAMP Servicers 80,209 6,636 5,780 92,625

Total 384,449 233,605 106,225 724,279

1 Bank of America, NA includes Bank of America, NA, BAC Home Loans Servicing LP, Home Loan Services and 

Wilshire Credit Corporation. 2 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation.

3 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage, FSB.

4 Formerly National City Bank.

Note: Figures reflect active trials and active permanent modifications.

Modifications by Investor Type (Large Servicers)

15
Making Home Affordable

Program Performance Report Through March 2011

Servicers participating in the HAMP First Lien Modification Program may also offer additional support for homeowners, including Home Affordable 

Foreclosure Alternatives (HAFA), a forbearance for unemployed borrowers through the Unemployment Program (UP), and Principal Reduction 

Alternative (PRA). 

Allstate Mortgage Loans & Investments, 

Inc.

American Eagle Federal Credit Union

American Home Mortgage Servicing, Inc

AMS Servicing, LLC

Aurora Loan Services, LLC

Bank of America, N.A.1

Bank United

Bay Federal Credit Union

Bayview Loan Servicing, LLC

Bramble Savings Bank

Carrington Mortgage Services, LLC

CCO Mortgage

Central Florida Educators Federal Credit 

Union

CitiMortgage, Inc.

Citizens 1st National Bank

Community Bank & Trust Company

Community Credit Union of Florida

CUC Mortgage Corporation

DuPage Credit Union

Eaton National Bank & Trust Co

Farmers State Bank

Fay Servicing, LLC

Fidelity Homestead Savings Bank

First Bank

First Financial Bank, N.A.

First Keystone Bank

Franklin Credit Management Corporation

Franklin Savings

Fresno County Federal Credit Union

Glass City Federal Credit Union

GMAC Mortgage, LLC

Grafton Suburban Credit Union

Great Lakes Credit Union

Greater Nevada Mortgage Services

Green Tree Servicing LLC

Hartford Savings Bank

Hillsdale County National Bank

HomEq Servicing

HomeStar Bank & Financial Services

Horicon Bank

Horizon Bank, NA

Iberiabank

IBM Southeast Employees' Federal Credit 

Union

IC Federal Credit Union

Idaho Housing and Finance Association

iServe Residential Lending LLC

iServe Servicing Inc.

J.P.Morgan Chase Bank, NA2

Lake City Bank

Lake National Bank

Liberty Bank and Trust Co. 

Litton Loan Servicing

Los Alamos National Bank

Magna Bank

Marix Servicing, LLC

Midland Mortgage Company

Midwest Bank & Trust Co. 

Midwest Community Bank

Mission Federal Credit Union

MorEquity, Inc.

Mortgage Center, LLC

Nationstar Mortgage LLC

Navy Federal Credit Union

Oakland Municipal Credit Union

Ocwen Loan Services LLC

OneWest Bank

ORNL Federal Credit Union

Park View Federal Savings Bank

Pathfinder Bank

PennyMac Loan Services, LLC

PNC Bank, National Association

PNC Mortgage3

Purdue Employees Federal Credit Union

QLending, Inc.

Quantum Servicing Corporation

Residential Credit Solutions

RG Mortgage Corporation

RoundPoint Mortgage Servicing 

Corporation

Saxon Mortgage Services, Inc.

Schools Financial Credit Union

SEFCU

Select Portfolio Servicing

Servis One Inc., dba BSI Financial Services, 

Inc.

ShoreBank

Silver State Schools Credit Union

Specialized Loan Servicing, LLC

Sterling Savings Bank

Suburban Mortgage Company of New 

Mexico

Technology Credit Union

The Golden 1 Credit Union

U.S. Bank National Association

United Bank

United Bank Mortgage Corporation

Vantium Capital, Inc.

Vist Financial Corp.

Wealthbridge Mortgage Corp. 

Wells Fargo Bank, NA4

Wescom Central Credit Union

Yadkin Valley Bank

1 Bank of America, NA includes Bank of America, NA, BAC Home Loans Servicing 

LP, Home Loan Services and Wilshire Credit Corporation.

2 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation. 

3 Formerly National City Bank.

4 Wells Fargo Bank, NA includes all loans previously reported under Wachovia 

Mortgage, FSB. 

Appendix A1: Non-GSE Participants in HAMP

16
Making Home Affordable

Program Performance Report Through March 2011

Second Lien Modification Program (2MP)

Bank of America, NA1

Bayview Loan Servicing, LLC 

CitiMortgage, Inc.

Community Credit Union of Florida

GMAC Mortgage, LLC 

Green Tree Servicing LLC 

iServe Residential Lending, LLC 

iServe Servicing, Inc. 

J.P.Morgan Chase Bank, NA2

Nationstar Mortgage LLC

OneWest Bank

PennyMac Loan Services, LLC

PNC Bank, National Association

PNC Mortgage 3

Residential Credit Solutions 

Servis One Inc., dba BSI Financial Services, Inc. 

Wells Fargo Bank, NA 4

FHA First Lien Program (Treasury FHA-HAMP)

Amarillo National Bank

American Financial Resources Inc. 

Aurora Financial Group, Inc. 

Aurora Loan Services, LLC 

Banco Popular de Puerto Rico 

Bank of America, NA1

Capital International Financial, Inc. 

CitiMortgage, Inc. 

CU Mortgage Services, Inc. 

First Federal Bank of Florida 

First Mortgage Corporation 

Franklin Savings 

Gateway Mortgage Group, LLC 

GMAC Mortgage, LLC. 

Green Tree Servicing LLC 

Guaranty Bank 

iServe Residential Lending, LLC 

iServe Servicing, Inc. 

James B. Nutter & Company 

J.P.Morgan Chase Bank,NA2

M&T Bank 

Marix Servicing, LLC 

Marsh Associates, Inc. 

Midland Mortgage Company 

Nationstar Mortgage LLC 

Ocwen Loan Services LLC 

PennyMac Loan Services, LLC 

PNC Mortgage 3

RBC Bank (USA) 

Residential Credit Solutions 

Saxon Mortgage Services, Inc. 

Schmidt Mortgage Company 

Select Portfolio Servicing 

Servis One Inc., dba BSI Financial Services, Inc. 

Stockman Bank of Montana 

Wells Fargo Bank, NA 4

Weststar Mortgage, Inc. 

FHA Second Lien Program (FHA 2LP)

Bank of America, NA1

Bayview Loan Servicing, LLC 

CitiMortgage, Inc. 

Flagstar Capital Markets Corporation 

GMAC Mortgage, LLC. 

Green Tree Servicing LLC

J.P.Morgan Chase Bank, NA2

Nationstar Mortgage LLC 

PNC Bank, National Association 

PNC Mortgage 3

Residential Credit Solutions 

Saxon Mortgage Services, Inc. 

Select Portfolio Servicing 

Wells Fargo Bank, NA 4

Rural Housing Service Modification Program 

(RD-HAMP)

Banco Popular de Puerto Rico

Bank of America, N.A. 1

Horicon Bank 

J.P.Morgan Chase Bank, NA 2

Magna Bank 

Marix Servicing, LLC 

Midland Mortgage Company 

Nationstar Mortgage LLC 

Wells Fargo Bank, NA 4

1 Bank of America, NA includes Bank of America, NA, BAC Home Loans Servicing LP, Home 

Loan Services and Wilshire Credit Corporation.

2 J.P. Morgan Chase Bank, NA includes EMC Mortgage Corporation. 

3 Formerly National City Bank.

4 Wells Fargo Bank, NA includes all loans previously reported under Wachovia Mortgage FSB. 

Appendix A2: Participants in Additional Making Home Affordable Programs

17
Making Home Affordable

Program Performance Report Through March 2011

18

Note: Areas of compliance emphasis and servicer-specific 

compliance data will be updated quarterly.

Description of Compliance Activities

Freddie Mac, serving as Compliance Agent for 

Treasury’s Home Affordable Modification 

Program (HAMP), has created a separate 

division known as Making Home Affordable -

Compliance (MHA-C). Using a risk-based 

approach, MHA-C conducts a number of 

different types of compliance activities to 

assess servicer compliance with HAMP 

guidelines for those servicers that have signed 

a servicer participation agreement with 

Treasury, in their servicing of those loans for 

which Treasury pays incentives (non-GSE 

loans), as described below.

On-Site Reviews: Implementation – Reviews 

to assess the servicer’s overall execution of 

HAMP. Areas covered include, but are not 

limited to, solicitation, eligibility, underwriting, 

document management, payment processing, 

reporting, and governance. MHA-C performs 

reviews of larger servicers on not less than a 

semi-annual schedule and reviews smaller 

servicers on at least an annual schedule.

On-Site Reviews: Readiness & Governance –

Reviews to assess the servicer’s preparedness 

for complying with new or future HAMP 

requirements or to research a trend or 

potential implementation risk. MHA-C 

performs such reviews as needed, determined 

by frequency of new program guidance.

NPV Reviews – Reviews to assess the 

servicer’s adherence to the HAMP NPV 

guidelines. For those servicers that have 

elected to recode the NPV model into their 

own systems (recoders), MHA-C assesses 

whether the servicer’s recoded NPV model is 

accurately calculating NPV and whether the 

servicer’s model usage is consistent with 

HAMP guidelines. Recoders are subject to 

off-site testing at least quarterly and to on-site 

reviews at least semi-annually. For servicers 

using the Treasury NPV Web Portal, MHA-C 

reviews data submissions to the Portal on a 

monthly basis, and conducts on-site reviews as 

necessary to evaluate data submission issues.

Loan File Reviews – Reviews of samples of the 

servicer’s non-performing loan portfolio 

primarily to assess whether required steps in 

the modification process have been 

documented in the loan files and whether loan 

modification decisions were appropriate. This 

includes reviews of loans that have 

successfully converted to a permanent 

modification, to ensure they meet the HAMP 

guidelines. It also includes reviews of loans 

that have not been offered HAMP 

modifications, to ensure that their exclusion 

was appropriate (“Second Look” reviews). 

MHA-C conducts these Loan File reviews on a 

statistical sample for each servicer (typically 

100 loan files per larger servicer). Larger 

servicers’ non-performing loan portfolios are 

sampled and reviewed on a monthly cycle. 

MHA-C statistically samples and reviews 

smaller servicers’ non-performing loan 

portfolios on a quarterly or semi-annual cycle.

Incentive Payment Reviews – Reviews to 

assess the accuracy and validity of Treasury 

incentive payments to borrowers and 

investors, including whether borrower 

payments are appropriately allocated to 

borrowers’ loan principal in accordance with 

HAMP guidelines. MHA-C performs such 

reviews at least annually on the largest 

servicers.

(See next page for Areas of Compliance 

Emphasis)

Appendix B1: Description of Compliance Activities
Making Home Affordable

Program Performance Report Through March 2011

19

The past two years have seen substantive change 

in MHA programs as well as in the MHA operations 

of participating servicers. As new programs have 

been implemented and guidance has matured, 

Treasury’s compliance goal first and foremost has 

been to ensure that homeowners are 

appropriately treated in accordance with MHA 

guidelines and have the opportunity to avoid 

foreclosure. 

In 2011, Treasury will focus more intently on 

ensuring that servicers are maturing their MHA 

processes, accurately and timely processing MHA 

transactions, and employing appropriate internal 

governance efforts. Treasury will accomplish this 

by conducting more targeted or focused reviews, 

assessing servicer Quality Assurance or Internal 

Audit coverage of MHA activities, and enhancing 

the level of compliance-related information 

included in the MHA monthly reports.

The following are current areas of emphasis for 

MHA-C.

Cancellations

Servicers are required to comply with HAMP 

guidance when canceling loans in HAMP trials. 

The Second Look review process conducted by 

MHA-C has, and will continue to include, a focus 

on evaluating servicers’ cancellation activities, 

especially those around servicers’ timely and 

appropriate decisioning and borrower 

communications. 

MHA-C has performed targeted reviews of the 

cancellations of aged trials and will continue these 

reviews over the course of the next several 

months. MHA-C is evaluating whether servicers 

are making appropriate cancellation decisions, 

with a specific focus on those loans where the 

cancellation reason indicates that the borrower 

had not made timely payments. Servicers are 

required to maintain documentation supporting 

cancellation decisions and evidence that borrower 

notifications are provided timely with all required 

information. 

Pre-Foreclosure Certification 

Due to recent concerns around foreclosures and 

the issuance of related guidance in June 2010, 

MHA-C is focusing on pre-foreclosure activities 

and certification requirements. Servicers may not 

refer any loan to foreclosure or conduct a 

scheduled foreclosure sale without first satisfying 

the "reasonable effort" solicitation standard and 

borrower communication requirements described 

in HAMP guidelines. In addition, within seven 

business days of a scheduled foreclosure sale, 

servicers must provide the foreclosure attorney or 

trustee with a written certification that the 

servicer has satisfied the requirements to solicit 

and evaluate eligible borrowers as defined by 

HAMP guidelines, and that all other available loss 

mitigation alternatives have been exhausted and a 

non-foreclosure outcome could not be reached. 

These reviews will include:

• Processes for satisfying the "reasonable effort" 

standard and for ensuring that consideration of 

MHA programs and borrower notifications are 

executed and appropriately documented; and

• Processes for completing consideration of 

HAMP and other foreclosure alternatives, as 

appropriate, prior to any foreclosure referral or 

foreclosure sale; and

• Processes for providing foreclosure attorneys or 

trustees with accurate and timely certifications 

prior to a scheduled foreclosure sale.

IR2 Reporting and Data Integrity

Servicers are required to submit HAMP loan-level 

data to the program’s system of record (IR2), and 

that data is required to be accurate and consistent 

with source documentation. IR2 data is used to 

monitor and report on HAMP activity levels and to 

calculate servicer, borrower, and investor 

incentive payments. As stated in prior reports, 

reporting and data integrity controls continue to 

be a focus. MHA-C conducted preliminary data 

mapping exercises with the Program 

Administrator and will be assessing servicers' 

information technology (IT) controls over IR2 

reporting over the coming months, with an 

emphasis on system interfaces and reconciliations 

of data between systems. 

MHA-C will continue testing IR2 data against 

source documentation, including loan files, with 

particular attention on the data elements used in 

the establishment of borrower payments and the 

calculation of incentives. MHA-C will also continue 

to review servicers’ calculations for accuracy and 

consistency with HAMP guidelines.

Appendix B2: Areas of Compliance Emphasis