Your Subservicer's Calls Become Your Exam Findings: Overseeing a Mortgage Subservicer When You Can Review Every Call and Letter
A bank or IMB that owns servicing rights and outsources the work keeps the regulatory liability, and most oversight programs still run on the subservicer's own scorecard, an annual audit and a sampled call file. What changes when the owner can score every call and every letter against Regulation X, Regulation F, UDAAP and its own procedures, what the contract has to say first, and what we learned codifying hundreds of SOP documents for a lender's call review.