Summary: | The members of the Federal Financial Institutions Examination Council (FFIEC) continue to support responsible loss mitigation activities by federal- and state-regulated financial institutions that preserve homeownership. This support extends to programs designed to achieve sustainable mortgage obligations regardless of lien position. The FFIEC members recognize that entities that service first and subordinate liens on the same residential real estate property may be faced with potential conflicts of interest when making loan modification decisions. A servicer's decision to modify the first lien mortgage should not be influenced by the modification's potential impact on the subordinate lien loan and vice versa. Any ownership interest in the subordinate lien cannot be a consideration. |
Highlights:
Distribution: Suggested Routing: Note: Paper copies of FDIC financial institution letters may be obtained from the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).
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Additional Related Topics:
- Statement on Working with Mortgage Borrowers
- Statement on Loss Mitigation Strategies for Servicers of Residential Mortgages
- Supplemental Information for Loss Mitigation Strategies
- Interagency Guidance on Nontraditional Mortgage
- Statement on Subprime Mortgage Lending
FIL-45-2009