On November 1st, the OCC announced that the independent foreclosure review required under the agency's enforcement actions taken in April 2011 has begun. Under the enforcement actions taken in April by the OCC, the Federal Reserve Board, and the Office of Thrift Supervision, 14 large mortgage servicers were required to correct deficiencies in their servicing and foreclosure processes and to engage independent firms to review foreclosure actions that occurred in 2009 and 2010. Independent consultants are charged with evaluating whether borrowers suffered financial injury through errors, misrepresentations, or other deficiencies in foreclosure practices and determining appropriate remediation for those customers. Where a borrower suffered financial injury as a result of such practices, the consent orders require remediation to be provided. OCC Press Release. See also Federal Reserve Board Press Release.
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