Recently the CFPB issued a proposed directive to servicers requiring the development of a rating system that would indicate to consumers how efficiently and effectively the servicer addresses complaints. They had suggested a five-star rating system which could be published and available to anyone interested. The response from servicers was quick and extremely negative. This idea to them was an anathema. However, before the issue came to a head, the current administration declared that any new regulations were to be withdrawn.
However, one must wonder why mortgage servicers were so vehemently opposed to this idea. Was it because they have failed to address complaints appropriately in the past? Did they believe that this requirement would force them to expose negligent or unsatisfactory actions? Were they concerned that by allowing this information to be given out they would somehow diminish the value of their organization? Or is it because they still don’t recognize borrowers as their customer, believing instead that their sole purpose is to serve investors rather than consumers?
The idea of a consumer rating system is not new. J.D. Powers is well known for its rating programs and awards given to companies who score well on these programs. The fact that a company has received such as award is frequently a central part of their marketing campaigns. Quicken Loans continuously brags about the number and frequency of their J.D. Powers awards as does Delta Airlines and winners from other industries. What is so abhorrent about such a system for servicers?
One reason has been the lack of a standardized approach to evaluating responses to consumer complaints and/or inquiries. Unfortunately, developing a taxonomy that would grade responses cannot be developed until there is some standard acceptance of what should happen and in what time frame. After all, the Chinese say “Any road will take you there if you don’t know where you are going.” Right now, there appears to a consistent lack of understanding and/or agreement of what constitutes ‘doing it right”. Once that is determined, levels of performance can be developed. For example, if it is agreed that satisfactory performance is responding to the consumer within the required timeframe with an answer to a question posed or information provided, then actions that are better and worse can be described and a positive or negative assigned.
Another statement that keeps popping up is the fact that consumers are not going to like what the servicer did or the answer to their question. Since this is bound to happen, the servicer will appear to provide unsatisfactory service when in fact they were just complying to the required servicing standards. Of course, every company expects this to happen. Delta hasn’t flown every airplane on time and without incident and there are ways to deal with one off issues when analyzing the results.
Recognizing that the benefits far outweigh the negatives must happen before any of this can get started. Having data on which consumer activities are beneficial and positive would allow servicers to determine how to duplicate this same approach on those that appear to be a problem. Living in a world where management is blind to the positives and negatives of their organization is ridiculous when an industry devised and properly managed consumer evaluation program can win loyal customers and maybe even impress investors as well as regulators.
About The Author
rjbWalzak Consulting, Inc. was founded and is led by Rebecca Walzak, a leader in operational risk management programs in all areas of the consumer lending industry. In addition to consulting experience in mortgage banking, student lending and other types of consumer lending, she has hands on practical experience in these organizations as well as having held numerous positions from top to bottom of the consumer lending industry over the past 25 years.