Independent Foreclosure Review: Borrower Outreach Mailing and Response Data
The Independent Foreclosure Review (IFR) was required by the enforcement actions issued by federal banking regulators--the Board of Governors of the Federal Reserve System (Federal Reserve) and the Office of the Comptroller of the Currency (OCC)--in April 2011. These actions were issued against 14 banking organizations for deficient practices in residential mortgage loan servicing and foreclosure processing. Under these actions, servicers were required to retain independent consultants to conduct a comprehensive review of foreclosure activity to identify whether borrowers whose homes were in the foreclosure process during 2009 or 2010 suffered financial injury due to servicer errors, misrepresentations, or other deficiencies.1
Borrowers who believed they were financially harmed during the mortgage foreclosure process by the errors of one of these 14 mortgage servicers could request an independent review if a foreclosure action was initiated, pending, or completed during 2009 or 2010 on a mortgage loan on their primary residence.2 Borrowers had until December 31, 2012 to submit a form requesting an independent review.
Broad outreach by mail and mass media was used to raise awareness of the IFR. Outreach efforts were launched on November 1, 2011, when the servicers mailed letters about the IFR to over 4 million borrowers who were identified as potentially eligible for an independent review. Outreach was expanded in 2012 to include more targeted approaches to reaching borrowers.
The Federal Reserve and the OCC are releasing the IFR mailing and response data received as of December 31, 2012 by geographic location to provide information about the IFR. A downloadable file containing each state's count totals can be searched by county, parish, or independent city, along with the uniquely identifying Federal Information Processing Standard (FIPS) code.3 Additionally, mailings and responses are searchable by county, parish, or independent city within a state, using the accompanying search function.
The data released reflect the number of borrowers meeting the initial eligibility criteria (mailings) and submitting Request for Review forms (responses) by geographic location. The figures for mailings and responses do not represent the total number of financially harmed or remediated borrowers; rather, they offer a local snapshot of borrower outreach and responses using property addresses. The data was collected by the IFR's third party central intake administrator, and reflect all requests for review received as of the December 31, 2012 deadline.
Request for Review Form mailings were concentrated in areas that were hardest hit by the housing crisis.4 These areas were identified by the U.S. Department of the Treasury, beginning in February 2010, either because their unemployment rates were at or above the national average or house prices had fallen more than 20 percent since the housing market downturn. For example, counties in California, Arizona, Nevada, and Florida received a sizeable share of the mailings.
1. In January 2013, 11 of the 14 mortgage servicing companies subject to April 2011 enforcement actions for deficient practices in mortgage loan servicing and foreclosure processing reached an agreement with the OCC and the Federal Reserve to provide more than $9.3 billion in cash payments and other assistance to help borrowers. For those servicers participating in the payment agreement, the IFR has stopped. Although not part of the IFR, Goldman Sachs and Morgan Stanley were also subject to foreclosure related enforcement actions and participated in the agreement. The data released here covers the 14 servicers that were part of the IFR, but not Goldman Sachs or Morgan Stanley. More information regarding the payment agreement is available at http://www.federalreserve.gov/consumerinfo/independent-foreclosure-review-payment-agreement.htm. Return to text
2. More information about the enforcement actions, payment agreement, and resources for borrowers and housing counselors is available at http://www.federalreserve.gov/consumerinfo/independent-foreclosure-review.htm. Return to text
3. A FIPS code is a five-digit number assigned to a place for information processing. The code begins with a two-digit state number, followed by a unique three-digit place code. For example, California's state code is 06, and the county code for Los Angeles is 037. Therefore, the FIPS code for the county of Los Angeles is 06037. Return to text
4. For the list of Hardest Hit Fund states, see the U.S. Department of the Treasury's website at http://www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/hhf/Pages/default.aspx. Return to text