On May 16, 2022, the Consumer Financial Protection Bureau (CFPB) published its second metrics report as part of its ongoing supervisory monitoring of mortgage servicers’ COVID-19 pandemic response. The data collected is part of the Bureau’s metrics requests to sixteen servicers representing “a broad cross-section of the mortgage servicing industry.” The first report, published in August 2021, covered the period from December 2020 through April 2021.
The CFPB’s latest metrics report analyzes data obtained from the same sixteen servicers for the period from May through December 2021 on key data points, including servicing portfolio, call metrics, COVID-19 hardship forbearance enrollments and exits, delinquency, and borrower profiles.
- Servicing Portfolio. The metrics report is based on data provided by servicers for approximately 21 million loans of which 17.6 million (84%) are federally backed loans and 3.4 million (16%) are private loans.
- Call Metrics. The total monthly call volume for all servicers was between 3.32 and 3.64 million inquires for this reporting period, which is a decrease from the last reporting period for the first metrics report (December 2020 through April 2021) when it exceeded 4 million calls per month. The CFPB also analyzed call metrics based on average speed to answer, abandonment rates, and average handle time. While most servicers reported stable call metrics, a few servicers reported “relatively high average hold times exceeding ten minutes and call abandonment rates exceeding 30%.”
- COVID-19 hardship forbearance enrollments and exits. COVID-19 hardship forbearance enrollments are trending down while forbearance exits are trending up. Forbearance enrollments decreased from 163,000 in May 2021 to 68,000 in December 2021 for federally backed loans and 42,000 in May 2021 to 17,000 in December 2021 for private loans. Forbearance exits increased from approximately 60,000 to 84,000 per month for federally backed loans and ranged from approximately 10,000-19,000 for private loans.
- Delinquency. The CFPB found that over 330,000 borrowers exited COVID-19 hardship forbearance with no loss mitigation solution in place, putting those borrowers at heightened risk of foreclosure. Delinquency rates were higher for private loans—between 25% and 39%—than for federally backed loans—between 11% and 17%. Based on this data, 15% of loans exited forbearance in delinquent status.
- Borrower Profiles. The CFPB sought data on borrower demographics, including race, ethnicity, and language preference to analyze whether minority groups have equal access to obtaining forbearances and accessing post-forbearance loss mitigation. The data is limited, but it shows a trend that borrowers with limited English proficiency (LEP) may face greater challenges in obtaining information about how to access post-forbearance loss mitigation options. The CFPB “encourages servicers to ensure that LEP borrowers in need of loss mitigation after exiting forbearance are served in a manner commensurate with service provided to all other borrowers” because the failure to do so could amount to Equal Credit Opportunity Act violations.
Aside from the statistical analysis, the CFPB’s metrics report effectively places mortgage servicers on notice about providing equal access to all borrowers who seek post-forbearance loss mitigation options. This is consistent with our reporting that the CFPB is focused on addressing housing discrimination under CFPB Director Rohit Chopra. Mortgage servicers should take steps to ensure they provide adequate telephonic assistance for all borrowers, including in-language information for LEP borrowers.