We speak to numerous holders of mortgage portfolios and discuss how we can help them review their Third Party Suppliers (TPS) and ensure they are complying with their contractual obligations.
They are often surprised that it’s not just the Primary Servicer and Special Servicer we are referring to, but also Litigation Solicitors, Asset Managers and Debt Counsellors. A common question we are asked is ‘doesn’t the Servicer control them?’ To a certain extent that is so, but the ultimate responsibility lies with the holder of the portfolio.
We have carried out a number of TPS reviews and have often found there to be a lack of control, re-occurring errors and unnecessary costs accrued, each of these potentially resulting in borrowers not being treated fairly.
The FSA has found continued weaknesses among Third Party Administrators. They have already fined GMAC, Kensington and Redstone, and it is understood that a further four firms are being investigated – with one of the key areas of investigation being to ensure that holders have been and continue to apply sufficient oversight of their TPS.
Regular monthly reviews of TPS will improve the service, controls and management information and also give the holders of the portfolios confidence that their borrowers are being treated fairly.