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Foreclosure management for CUs covered in NCUA letter
ALEXANDRIA, Va. (1/24/11)--Pending National Credit Union Administration (NCUA) examination standards will address the need for appropriate due diligence when dealing with outside vendors, quality control reviews on foreclosure processes, and stress event analysis and reporting, the NCUA said in a recent letter to credit unions. The NCUA in that letter also urged federal credit union directors to perform their own in-depth reviews of their mortgage documentation and foreclosure management processes. Specifically, credit unions should be aware of issues related to the Mortgage Electronic Registration System (MERS), missing or defective loan documents, and documentation deficiencies related to so-called “robo-signing.” Credit unions should also monitor for contractual buy-back risks associated with serviced mortgages, the NCUA said. To properly deal with these and other mortgage-related issues, credit unions should ensure that their credit union has established appropriate policies and procedures for all aspects of the foreclosure process. A credit union’s staff should be qualified to properly handle foreclosures, and its internal controls should be able to adequately deal with the foreclosure process. Credit unions should also ensure that their oversight, due diligence, and controls related to third-party servicers that perform foreclosures on behalf of the credit union are adequate. Any foreclosure action should be accompanied by the required legal documentation, and information on the number and volume of foreclosure actions, as well as the financial impact of those foreclosure actions, should be disclosed to a credit union’s board of directors, the NCUA added. For the full NCUA letter, use the resource link.
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