Operational Enhancements. It shall be the objective of the Board to encourage future additional cooperation among Member Agencies. The Executive Director, with the advice and assistance of the Technical Advisory Committees, shall actively consider and evaluate opportunities that would enhance the operational effectiveness of public health and safety communications, to the benefit of the taxpayers and residents of the areas served. The Excutive Director’s and/or Technical Advisory Committees’ recommendations and proposed actions shall be presented to the Board and, when the Board so recommends, to participating Member Agencies.
Operational Enhancements. The Company implemented a number of operational enhancements to address the LMA Practices. In particular, the Company has: - as of September 7, 2014, ceased the practice of sending solicitation letters for Streamlined Loan Modifications to Borrowers in a Bankruptcy Case; - enhanced its practices to ensure that only fees and costs properly noticed in accordance with Bankruptcy Rules 3001, 3002 and 3002.1, or allowed by court order, will be assessed and/or capitalized into Loan Modifications that occur during Bankruptcy Cases. These enhanced processes and procedures also ensure that all accounts are reviewed at certain milestones such as following the implementation of the Loan Modification and discharge for any unnoticed capitalized fees or costs; - appointed a designated bankruptcy liaison to coordinate loss mitigation efforts for bankruptcy accounts and facilitate communication between the loss mitigation and bankruptcy departments regarding bankruptcy Loan Modification issues; and - enhanced its policies and procedures for the preparation and filing of Bankruptcy Documents related to Loan Modifications, including a more robust reporting mechanism so that the reports make clear that, at a minimum: (i) Motions for Approval, PCNs, and/or APOCs are appropriately and timely filed in Bankruptcy Cases in which the Company enters into a Loan Modification with a Borrower as may be required by a particular jurisdiction;2 and (ii) there is a process for escalating and resolving issues about a proposed pleading to management as necessary. The operational enhancements described above were implemented by the Company on or before the third quarter of 2017.
Operational Enhancements. The Company has implemented a number of operational enhancements to address the Escrow Practices. In particular, the Company has: - established a requirement that escrow analyses be run annually for Mortgage Loans in Bankruptcy Cases unless an exception applies; - established a requirement for PCNs to be filed for such escrow analyses; - established control processes and reporting mechanisms to identify any Mortgage Loans in Bankruptcy Cases with an Escrow Account that have not had an escrow analysis run for each Escrow Cycle, and to complete analyses for such Mortgage Loans unless an exception applies; and - implemented various technological enhancements to further enhance its escrow process. The operational enhancements described above were implemented by the Company on or before the fourth quarter of 2016.
Operational Enhancements. The Company has implemented a number of operational enhancements to address the Advances Practices. In particular, the Company has: - established a team within the bankruptcy department with the responsibility of preparing, reviewing, and filing NPFCs; - adopted or enhanced checklists to assist in the preparation of and quality control review of NPFCs as they relate to Advances in order to ensure compliance with the requirements of the Bankruptcy Code and Bankruptcy Rules; - established a procedure by which, when performing a Reconciliation of an account for a Borrower in a Bankruptcy Case, all Unnoticed Advances will be waived from the Borrower’s account in accordance with the Bankruptcy Rules; and - established a procedure by which, when preparing a POC, bankruptcy representatives will review the Mortgage Loan for Unnoticed Advances from a previous, discharged Bankruptcy Case that remain on the account or were previously paid, and will waive or credit, as appropriate, any such Unnoticed Advances before a POC is filed in a subsequent Bankruptcy Case. The operational enhancements described above were implemented by the Company on or before fourth quarter of 2016.
