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Tag: default servicing

1 article tagged “default servicing”
Servicing

When the Loan Is FHA or VA, the Waterfall Is the Investor's, Not the CFPB's: Government Default Servicing With AI After the 2025-2026 Overhaul

Most default-servicing AI is built to the CFPB Reg X rules and stops there. FHA and VA loans layer their own loss-mitigation waterfalls on top, and both changed hard in the last year: FHA sunset its COVID options and its HAMP on September 30, 2025 under Mortgagee Letter 2025-12, and VA replaced VASP with a new Partial Claim program that opened June 15, 2026. An agent that recommends a retired option on a government loan is not a small bug. Here is how we version the waterfall by investor and effective date, what the agent computes, and the determination a human still signs.

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