Au revoir Allonhill: OCC Finally Pulls The Plug
I first wrote about massively conflicted OCC foreclosure review firm Allonhill on nakedcapitalism, here:
http://www.nakedcapitalism.com/2011/12/michael-olenick-the-administration-likes-foxes-in-charge-of-henhouses-%E2%80%93-proof-that-occ-foreclosure-reviews-are-a-sham.html
Gretchen Morgenson picked it up for the NYT, here:
http://www.nytimes.com/2011/12/25/business/foreclosure-relief-dont-hold-your-breath-fair-game.html
Took a few months but now the OCC has reacted; Allonhill’s finished:
http://www.occ.treas.gov/news-issuances/news-releases/2012/nr-occ-2012-74.html
Sue, meet David J. Stern. He can tell you what happened to his sham company DJSP after I showed his investors he was grossly misleading them.
To Sue Allon, and all those out there like her:
http://www.youtube.com/watch?v=rY0WxgSXdEE&feature=relmfu
Updated: That last part where the OCC arrogantly proclaims “The decision does not reflect on the quality of work performed to date by Allonhill” is bunk. Of course it does. Every Aurora/Allonhill file needs to be reviewed by a genuinely independent auditor. Send the bill for the re-reviews to Sue Allon, to John Walsh who signed off on allowing Sue Allon to review her own work, or to Aurora who thought they’d get away with their latest sleazy trick. Whoever .. as long as it isn’t US taxpayers. But obviously they need to start from scratch.
This not-so-independent review was supposed to be the wronged-homeowners’ last resort, especially those who cannot afford to pursue Justice in courts. But we knew, thanks to heroes like you who exposed it from the start, it was sham. Now the proof is here. Our only hope is you: Michael Olineck, Yves Smith, Abegail Field, Gretchen Morgenson, Adam Levitten, David Dayen to re-assert your points and call the President on it.
Wow, so much tripe. This is like blaming an automobile designer because you drove it into a tree. There is almost nothing in here that has anything to do with what really happend in the melt down. If anything it shows an AMAZING misunderstanding of the industry and what the consent order means. Next you will be yelling “Fire” in a crowded movie theatre.
So ordinary American’s were driving, huh? Given that Lloyd Blankfein’s been on a PR push lately based on the notion that most people didn’t know who GS is, much less what they do, I think the notion that regular people were somehow in charge is disingenuous at best. As for the consent order as one of the key people who helped w/ the data that caused it to be written I very much know what it means, and the OCC’s involuntary termination of Allonhill speaks for itself. I am yelling fire in a crowded theater that is very much on fire but where management does not want to return the ticket prices.
I agree Racemile.Sure, there were a few mistakes made. When you consider the millions of foreclosures and the law of averages it is inevitable some were foreclosed in error.
Most errors were irrelevant ie: using black ink when they should have used blue ink.The one thing theses millions of people have in common is they signed a promissory note and did not fullfill their end of the bargain. The Deed of trust or mortgage they signed spells it out-if you don’t make your payments we will take the house back.
The problem is only exacerbated by over zealous people like Olenick who try to make mountains out of molehills. He should use his intelligence on trying to be the solution-not the problem.
A loss of confidence in originators, servicers, ratings agencies, and to a lesser extent investment banks goes to the heart of the problem. Until confidence is restored at the investor level, and until borrowers feel they can trust their banks, the underlying economic issues will continue to fester and every banker knows that.
But-for the TARP and related programs those loans would have been liquidated, sold to investors for pennies on the dollar, and those new investors would have had a lot of room to renegotiate. Borrowers could have even purchased their loans from pools at auction rates: at one point many people could have purchased a $500,000 note for under $50,000, leaving them free to use the excess capital for more productive uses than paying back bubble-era mortgages.
Arguing what color pen somebody signed with ignores the core problem that the foreclosures are moving forward because of massive, entirely one-sided government intervention. There are very few borrowers that signed up to face the financial might of the UST and Federal Reserve, only VA, FHA, and a few smaller programs. Fannie and Freddie were private, and so by definition was every private trust.
Given that the foreclosures are possible only because of one-sided government intervention agents who are the recipients of that intervention, especially servicers, have an obligation to be held to the highest standards of ethics and honesty. But we know that did not happen or there would be no consent decrees, no AG settlement, no robo-gate .. none of this would or should have happened. Pretending like it would have any way because borrowers “did not fulfill their end of the bargain” ignores that the market itself stepped in to change the fundamental rules of that bargain to the borrowers disadvantage. Once that happens there is no more bargain. You can’t have half a free market any more than you can be a little bit pregnant: it’s all for both parties or none for either. Once the first bailout dollar flew the bargain was broken, the free market eroded.
Why didn’t the OCC simply call, use technology like my findthefraud program, then ferret out and fix the problems first at the reviewer level then at the loan level? Because it’s now clear that the reviews were rigged; the OCC clearly didn’t even perform basic due diligence on whom they were hiring much less tell them to aggressively dig in. Simple and inexpensive methods could have been used, specifically appointing a preferably hostile auditor to oversee the auditors then sending random file between auditors and the auditor of auditors to make sure reviews yielded complete and accurate findings. This would have cost very little (much less than the total cost of a redo will be) and, by definition, with so many auditing firms working asking them to audit one another would likely have yielded strong results and maybe kept everybody honest.
As for fixing the problem my latest data project will go a long way towards enabling the return of the private secondary market which, we all know, is the most important element needed to genuinely move on. I talk to a lot of bankers, and many disagree with me, but they all seem to privately grouse that a secondary marketed entirely controlled by the agencies — especially in their current condition — is neither healthy nor helpful.
All great points Michael. I am still unclear on where your animosity lies. I can understand if it is with the government but why blast a great company that is trying to be the solution to the problem and who understands the issues at hand. Based on your solution:” Why didn’t the OCC simply call, use technology like my findthefraud program, then ferret out and fix the problems” ….just sounds like sour grapes to me…Meanwhile 200 honest, hard working people
who were a part of the solution are now without jobs. Perhaps your new project can use their skills and expertise.
My animosity comes from the fact that there was clearly a breakdown at the OCC, leading to yet another breakdown in trust, delaying a recovery even longer. As the files sit waiting to be re-reviewed who is going to pay the increased investor losses, the increased servicer advances, and what is going to be done to try to restore confidence to borrowers so they might actually try to mitigate a breach and move on? How many neighborhoods are going to sit with empty houses that are a crime magnet because they are tied up in perma-foreclosure?
All of that is annoying and, when it comes to choosing and reviewing files for fraud, borrowers had literally nothing to do with it despite that some commentators here seem to imply otherwise.
This breakdown in quality control during the selection phase is indicative of everything else we’ve seen before, during, and after the meltdown. Either Allonhill fully disclosed the scope of the prior work at Murrayhill, and the OCC did not think it mattered until it came under the public microscope, or the conflict was not disclosed. Either way there is a serious ethics breach on either the part of either Allonhill or the OCC, one that does nothing to help heal the market, restore confidence and trust, and move forward.
If Allonhill disclosed the prior work they should be livid at the OCC and demand that, say, a similar volume of work be transferred from another auditor, who would then take the Aurora work, leaving the cost to fix the conflict as neutral. But if the conflicts were not disclosed then Sue Allon should admit to her staff that she blew it. Given how quickly I was able to find the conflict that strongly suggests the OCC did virtually no due-diligence work when hiring the reviewers; most auditing firms probably spent more time vetting their employees than the OCC spent vetting the firms themselves.
On sour grapes I’m a data person, a life-long techie w/ a law-degree that focuses on managing large, complex, and oftentimes sensitive volumes of data. I don’t think Allonhill was a tech company, though I don’t know what their other business lines are. That is, I probably compete with whomever Allonhill hired for technology work but there wasn’t competition w/ Allonhill; in different circumstances the businesses probably would have complimented one another.
Finally, to the Allonhill employees, the palpable anger towards borrowers or me is misplaced: look inward.
I worked at Allonhill from 7/2011 to (last Friday) as a Senior Analyst. The integrity of analysis, reporting, and intent during the Allonhill review you criticize as corrupty was unquesitonably sound and undeniably independent. This coming from a guy who just got fired because the OCC somehow suddenly noticed that a due diligence company performed due diligence on loans that they were already told had due diligence performed on them when Allonhill was granted the review. Bravo OCC, Bravo. Way to actually read the disclosure that was submitted to you.
Allonhill’s proprietary review program is worldclass. I assure you, Michael Olenick, you are nowhere near the level of I.T. personnel that work there seeing how the I.T. Directors are NASA system architect alumni.
To fault a firm like Allonhill, who may previously made sure files were underwritten to any number of investment guidelines only to later review those same loans once they entered foreclosure due to possible servicing malpractice on the part of Wells Fargo or Aurora Loan Services, is truly a short sighted, poor, ignorant and inflammatory line of commentary to pursue. Shame on you for being such a large ignoramus to feeding the fire of the corruption that you claim to rebel against. For claiming to know what goes on behind the 9 inch thick secure steel doors of a company like Allonhill. Allonhill’s review was an answer to the corruption you claim they embody. And you, UNDOUBTEDLY, have played a small part in preventing them from doing the important work that they were a full year into completing. For the cause that you claim to fight for, that you are actually stabbing in the heart.
What a fool you are. Plain and simple. Can’t wait for you reply full of stats and names and evidence refuting what I know to be the simple truth.
Murrayhill did not “[make] sure files were underwritten to any number of investment guidelines.” Well, maybe they did. But, more to the point, they also wrote the foreclosure procedures and processes, then assumed responsibility for ensuring compliance to those procedures and processes, as described in various trust prospectuses.
So there: no stats needed. You worked there and apparently didn’t even know the nature of the work Murrayhill had done. It’s laid out, in EDGAR, literally in black and white.
I don’t know why NASA engineers would be qualified to create document review systems. Allonhill wasn’t launching rockets (I presume): they were reviewing documents. Unlike the work Murrayhill did for Aurora, and the work Allonhill was supposed to be doing for Aurora, these are entirely different engineering disciplines. I am a software engineer but I wouldn’t try to architect a house; same concept applies.
All this does still leaves open the question of whether Allonhill disclosed the nature of that work to the OCC. Jury’s still out on that one but hopefully the OCC will release the complete bid packets for both Allonhill and all the other reviewers.
Now I get the reason for your unfounded tirade against Allonhill. You have an agenda, your own “find the fraud program”. I was a little stupified to read your initial article in December, now the reason is clear to me. You really have no idea, and apparently don’t care that Murrayhill and the work they did for Aurora is totally unrelated to Allonhill. Murrayhill was sold several years ago, although Sue Allon did stay on for a while with the company after it was sold, that company now is as related to Allonhill as you are. And although you are interpreting the language in the engagement letter as Murrayhill having something to do with the servicing policies of Aurora Loan Services, you are wrong again. The investors of the loans Aurora services, and Aurora’s own policies determine the servicing of their loan pool. Foreclosure law determines servicing loans in default, and although they did make mistakes, as did every servicer, probably most were due to the inability to handle the unprecedented number of loans that were in foreclosure, rather than a willful misconduct. And Sue Allon did disclose this previous relationship BEFORE she was engaged to perform this review. I can guarantee you that all work done as part of this foreclosure review by Allonhill was totally independent. Although Aurora loan services paid the bill, as required by the OCC, they had no say in how the loans were reviewed. They were not allowed to speak to anyone doing the review, and no one who had ever worked with Aurora was allowed to work on this project in order to ensure that we were not influenced in any way. We were constantly told that the review was being done to ‘the benefit of the borrower’ and that is exactly how the review process proceeded.
Finally, your comment to the Allonhill employees to look inward is just a little crazy. Every one of us, to a person, performed our jobs with so much integrity, all believing in the mission that we were charged with, to perform a fully independent review of foreclosures and to help the borrowers who may have been harmed by a wrongful foreclosure. We had nothing to do with the project being closed down. It’s too bad that people like you who have a platform would use it for your own purposes to harm others and benefit yourself. This type of yellow journalism is disgusting, it’s misleading and you have little concern for the consequences of your actions. I hope whomever reads your “articles” will see them for what they are, self promotion at the expense of others. Perhaps next time you will do a little fact checking before you write such slop. Probably not.
The OCC’s actions, the Aurora prospectuses that clearly spelled out Murrayhill’s role, and the contempt for borrowers from what seems to be former Allonhill employees are self-evident. Findthefraud is free; click, click, click and everything is added up, entirely transparent: no check from the banks who’s records are being clicked needed.
It is the PSA that determines “the servicing of the loan pool,” and the PSA of at least some of the Aurora trusts specifies the policies and procedures for default processing are promulgated by Sue Allon’s Murrayhill. Read the story: there is no ambiguity whatsoever.
What is disgusting is to see Allonhill employees repeatedly ignore the conflict of interest, self-righteously attack anybody but themselves, attack borrowers, defend servicer mistakes, and entirely ignore that real people were injured.
Allonhill employees seem to worry a great deal about being out of a job when it affects themselves. Except to pay lip service seem to worry very little that borrowers were unfairly thrown out of their homes — their children thrown into homelessness — oftentimes as a result of egregious fraud.
Every reviewer should watch the following as part of their orientation, and then keep in mind that they are assuming the role of deciphering whether this should have happened, and that they are doing this as private employees performing albeit under the auspices of the US government:
http://www.cbsnews.com/video/watch/?id=7389750n
Two things. First- The OCC is not some flippant fickle group that makes rash decisions. Thery are overly cautious. If they found wrongdoing on the part of Allonhill, they no doubt thoroughly vetted it before terminating Allonhill. Allonhill should admit it od’d on its own Kool Ade and went from a company that prided itself on protecting investors to protecting the interests of the borrowers who those very same investors whose interests the borrowers are in conflict with. That’s uncontrovertible, simply understood and that’s why there is a conflict. It really does not have to do with Murrayhill which I am sure Allonhill disclosed. It has to do with loans that Allonhill looked at that were coming around a second time in the foreclosure reviews.
The second point is that the OCC and FRB really have screwed up this foreclsoure review to a fairly well. Instead of taking the time to deveop a blueprint for how reviews are to be conducted they merely went through 14 individual processes selecting consultants and issued some guidance. What this means is that borrowers serviced by different institutions will not necessarily be treated the same way. While I’m sure the OCC has tried to fix this by issuing more guidance, the reality is that this makes the process more complex and expensive without necessarily producing any more benefit to consumers who were wrongly foreclosed.
Let’s review the OCC press release:
“The OCC took this action after Allonhill reported work for third parties that the OCC determined to be inconsistent with the independence requirements for independent consultants, prescribed by the OCC. The work at issue involved prior review for third parties of loans that are part of the same pool of loans that Allonhill was reviewing as part of the Independent Foreclosure Review.”
I don’t think that there is much ambiguity re what they saw as the source of the conflict.
I don’t know if the interests of investors and borrowers are in conflict, and they’re definitely not in conflict when it comes to whether short-sales should be quickly processed. Most borrowers I speak to, and I speak to a lot of them, just want to either modify their mortgage or move out and move on. Since either costs less than foreclosing, with the 100%+ loss severities I keep seeing, the real conflict is probably more between servicers and borrowers/investors. Servicers want the higher servicing fees, FPI, inspection fees, and all the rest whereas the other two just want the servicer to mitigate the breach for as little money as possible.
Assuming Allonhill wants to show they’re the real deal here’s an offer; I’ll give you a copy of the findthefraud software, a mountain of imaged court filings to pick through, and you can publish a master list of robosigners tied to specific documents.
I am not attacking borrower’s, I am very sympathetic to the borrower’s. I also lost my home to foreclosure and my children were homeless, I will never forget that, and have great compassion for everyone who has gone through that. I am not defending the servicers either, they made mistakes for certain. I said that, didn’t I? What I am saying is that you absolutely do not know what you are talking about, you were not a part of any of the review, did not see how it took place, and is taking place. It is not a perfect process but I can assure you it is not a sham. We took a deep look at the actions of the servicer leading up to foreclosure. Inevitably, the servicer did not provide adequate documentation to us in order to make a determination and we conditioned the servicer to provide the documentation needed. Sometimes they fought us, we fought back and had to let the OCC know that the servicer would not provide what was requested. We were of course finding many instances of robosigning, it’s not a fairytale, everyone knows it was happening, and that is all being reported. I read the letters that the borrower’s wrote to the servicer explaining their hardship, and I sometimes cried when I read them. I didn’t forget that when I reviewed their loan, and tried my best to detail exactly what had happened to them during the foreclosure process so that when the compensation part of this review is figured out, they might get some recompense. I did the same for every single file I reviewed, never forgetting that there were real people involved. Now these files will need to be re-reviewed, and the process drags on for longer with no resolution. I know that losing your job doesn’t rate up there with losing your home, (remember, I’ve experienced both) but why no compassion for those of us who were doing a good job and have lost our means to support our families? Why are we being villanized?
Unless you are Sue Allon you’re not being villanized. But under various securities laws Sue Allon, as CEO of Murrayhill, could have faced personal liability if the default processes and practices her company promulgated then monitored at Murrayhill were not followed to the detriment of investors.
Like I’ve written investors and borrowers tend to be tied together more than either wants to admit meaning the borrower reviews also open liability to investors, because a botched or prolonged foreclosure, or failure to mitigate a breach by delaying a short-sale or DIL decision, dramatically increases the cost of the breach.
So if Allonhill went on to find there were substantive problems w/ the processes and procedures that Sue Allon was monitoring at Murrayhill under SOX and other securities laws she would have to essentially bust herself. That’s obviously a problem, and goes to the heart the conflict.
Reviewers may have been accurately and carefully reviewing files but you don’t know if those reviews were being reported to the OCC or scrubbed first if they reflected problems at Murrayhill. Due to a lack of transparency we don’t know what is happening at Allonhill or any of the other reviewers.
Some safeguards could and should have been put into place but I can see from these emails they weren’t. Every reviewer should have been using web-based software maintained by the OCC that leaves an audit trail of everything every done to a file, every mark, every comment, every change. Deletions should have been literally impossible; reviewers could only add another line item saying that on further review a former mark was found to be incorrect. But that didn’t happen; Allonhill maintained its own software and, I’m guessing, so does every other reviewer.
Accurate and full public disclosure has been the best policing force for the banking industry, and one they seem to resist the most. Everything that happened at Allonhill, and every other reviewer — every standard, every mark, the level of staffing and files .. literally everything — should have been reported to the public in almost real time. Instead, like somebody else noted, it was behind a six-inch steel door, literally happening in a cave. Especially after the meltdown “trust us” doesn’t, and shouldn’t, work anymore. Like the old saying goes, “fool me once, shame on you, fool me twice, shame on me.”
Sorry, I thought you said Allonhill employees had contempt for the borrower’s, ignored the conflict of interest, attacked borrower’s, defended servicer mistakes, ignored that real people had been injured and only worry about being out of a job and only paid lip service to the fact that people had unfairly been thrown out of their homes. My mistake.
We were finding that servicers had foreclosed on people who were under bankruptcy protection, under protection of SCRA, had already worked out a loss mitigation plan or had been wrongfully denied loss mitigation, not to mention the robo-signing debacle-all of those things happened. We were reporting those findings to the OCC. They directed our process, we reviewed as they directed us to. We didn’t invent the process!The process to determine the financial compensation for the borrower’s by the OCC is just beginning. The foreclosed- on victims of the servicer we were reviewing will have to wait longer for redress now, since their process has to begin again with someone else. I am sure they will not report different findings than we did.
I’m not sure what’s up your butt regarding Sue Allon, I’d advise therapy or medication.
Quotes like this show contempt for borrowers: “Most errors were irrelevant ie: using black ink when they should have used blue ink.The one thing theses millions of people have in common is they signed a promissory note and did not fullfill their end of the bargain. The Deed of trust or mortgage they signed spells it out-if you don’t make your payments we will take the house back.”
Unless Allonhill was staffed with lawyers that have a strong background in foreclosure defense and bankruptcy the opinion of the reviewers to what is legally relevant is itself irrelevant.
Sue Allon repeatedly wrote on her website and giving interviews that she was an independent reviewer and a reformer, without mentioning anywhere outside the prospectuses that she was involved in default policies, procedures, and management for Aurora, the same bank being reviewed by Allonhill. Those types of conflicts make life harder for genuine reformers, in that people believe we’re all conflicted (especially when baseless ad-hominem attacks is the modus operandi for those who prefer the status quo).
The word on the street is that Allonhill failed to disclose work they had done recently reviewing Aurora loans for one of the GSE’s and that those loans were being re reviewed in the audit. The fact that Sue Aloon was CEO of Murrayhill until severn years ago is irrelevant, and no doubt was disclosed to the OCC. You pontificate as though you actually think you know the facts or understand securities law and admittedly you are a skilled writer, but you don’t really have command of the facts in this case; and the facts matter. And you can bet they mattered to the OCC when they did thier preliminary review and disqualified many potential consultants and law firms from participating in the foreclosure review process. I don’t know Sue Allon personally, but when you describe her potential liability you are simply wrong and should not mislead people with farcical legal conclusions.
Quick FOIA request will help clarify this: I’ll send one to the FHFA and the OCC today. It usually takes awhile for them to get back, but not always, especially on a subject like this. I’ll also ask for Allonhill’s initial disclosures; I can’t think of any applicable exemptions given what has happened.
I pontificate as if I can and have read the prospectuses relating to the role of Murrayhill.
[Update: FOIA requests submitted to both the OCC and FHFA w/ expedite requests. I'll let the public know what they release.]
Wow! As an Ex Mortgage Company Associate whose name I will not mention, I find all these comments mind boggling. As someone who has serviced home owners in distress and processed Loss Mitigation Reviews I would like to add a comment.
Let’s start with the Mortgage Company/Service Provider. Their main concern is getting their money. If you step inside the “office” of the collections arena, you will find they are more concerned about the amount of time spent on the phone then they are servicing the home owner. I myself have lost my home to foreclosure, I am fully aware of what the home owner goes through. The Mortgage Company/Service Provider I was employed by had a chart each Associate had to follow to receive a bonus; “trust me when I tell you the associate’s are more concerned about the bonus than the home owner”. Per their guideline a Collections Agent was not to be on the phone with a home owner longer than 8 minutes. During that 8 minutes an agent is expected to debt counsel, fill in all the information requested in the banking software and work up financials to see if the home owner qualifies for assistance. Any research that needs to be done with regard to missing payments, misapplied payments, mis-posted documentation, the status of the assistance program; (HAMP, Special Forebearance, Partial Claim, Short Sale, DIL, etc.) all was to be encompassed in 8 minutes. If your AHT, ( Average Handle Time ) went over, you were given a warning and of course your job is threatened along with being paid below poverty level for the job you are performing.
I have worked in an office with Associates who as soon as they walked in the door began their day, after signing in of course, spending their first hour trying to figure out where they were going to order their food for the night. Upon break, 2 or 3 of them would of course go pick up the order, show up an hour later when break is 30 minutes and distribute the food. Now the fact that they returned late is okay because they are picking up food for 2 Team Leaders, ( those responsible for making sure they comply to their schedule). Would you like me to expend on how long it took to consume the food, or take the cigarette break after? Or, how about the amount of time spent online shopping? Would you like to discuss how rude some of these associates are to home owners?
The sad part is, an associate like myself did not stand a chance because I cared about the home owners. I once had a family emergency and had to leave right after arriving to work. Spent my evening in an emergency room, showed up the next day 2 hours early with birthday fixins for another associate. Now, I must explain something, at this time I was driving 64 miles in an unairconditioned vehicle. I was showing up early daily to refresh myself from the drive in excessive heat. This day I had all the cake fixins in a cooler so the cake would not be destroyed & prepared it on my break. Now remember, I had spent the evening before in the emergency room…….that night at 5 till 10:00, quitting time, I was taken to a conference room and given a warning for the evening before because I had not produced any work. This is part of the problem with the mortgage industry. The team leads and mangers are not professional. You don’t have a chance in hell if you are not one of the favorites. This compiled on top of only being able to spend 8 minutes on a servicing call has had a huge effect on why our home owners have not been taken care of properly.
Now we will discuss Loss Mitigation Review, unless you love it, it’s boring. Myself I loved it because I believe in Compliance. However in my experience the Mortgage Company/Servicer does not handle the first review properly, too many Associates who take short cuts and do not care about the effect of the home owner. If you do care, it is guaranteed a team lead will tell you to notate it and go on. An associate like myself who actually cares, who has been there is pushed to the side because of procedure. Well, procedures need to be changed, actually Management need to be changed.
Third Party Vendors need to be sent in to walk the floors and be given permission to warn and walk associates not performing properly. Managers & team leads who care more about where their food is coming from for the evening and who they can send to retrieve it should be terminated. Associates hiding their cells phones, listening to music & taking personal calls who spend their time discussing where they are going to get their weave done and how much they will spend…..or searching out shoes…..messaging back and forth to other buddies should be terminated. No Manager or Team Lead should be informed about the Third Party Vendor without the threat of termination.
Third Party Foreclosure Reviews are necessary, however, you must realize what makes them necessary. Just like a child acts the way he is taught at home, a home owner is serviced properly or improperly by the staff of the servicing company.
When a servicing company is not willing to compensate their staff properly, they get unreliable staff, unreliable staff leads to home owners not being serviced properly.
All of the above is why these third party compliance companies are needed….it starts with the Mortgage Company/Servicer.