Independent Foreclosure Review Engagement Letters
By Daniel Edstrom
DTC Systems, Inc.
The Office of the Comptroller of the Currency has posted the following on its website (http://www.occ.gov/topics/consumer-protection/foreclosure-prevention/independent-review-foreclosure-letters.html).
Below are links to engagement letters submitted by the independent consultants, retained by servicers regulated by the OCC, who will be conducting foreclosure reviews pursuant to the requirements of the April 13, 2011 consent orders. The engagement letters describe how the independent consultants will conduct their file reviews and claims processes to identify borrowers who suffered financial injury as a result of servicer deficiencies identified in the OCC’s consent orders.
Limited proprietary and personal information has been redacted from the engagement letters. Examples of information that has been redacted include, but are not limited to: names, titles and biographies of individuals; proprietary systems information; references to specific bank policy; fees and costs associated with the engagement; and specific descriptions of past work performed by the independent consultants.
Since the acceptance of the engagement letters in September of this year, the independent consultants have further refined and made adjustments to the processes, procedures, and methodologies outlined in the engagement letters in consultation with OCC supervision staff. Therefore, in many cases the review processes being implemented may differ in some respects from those described in the engagement letters because of subsequent coordination with the OCC. In particular, there were a number of changes made to integrated claims process to ensure a single, uniform process among the servicers.
Pursuant to 12 C.F.R. § 4.12(c), the disclosure of the engagement letters at the OCC’s election has no precedential significance.
- Aurora Bank: Allonhill, LLC (PDF, 4 MB)
- Bank of America: Promontory Financial Group, LLC (PDF, 3.1 MB)
- CitiBank: PricewaterhouseCoopers, LLP (PDF, 3 MB)
- EverBank: Clayton Services, LLC (PDF, 6 MB)
- HSBC: Ernst & Young, LLP (PDF, 2 MB)
- JPMorgan Chase: Deloitte & Touche, LLP (PDF, 6.1 MB)
- MetLife Bank: Ernst & Young, LLP (PDF, 3.2 MB)
- OneWest: Navigant Consulting, Inc. (PDF, 3.1 MB)
- PNC: Promontory Financial Group, LLC (PDF, 1.8 MB)
- Sovereign: Treliant Risk Advisors, LLC (PDF, 1.6 MB)
- US Bank: PricewaterhouseCoopers, LLP (PDF, 2.4 MB)
- Wells Fargo: Promontory Financial Group, LLC (PDF, 4.9 MB)