April 1, 2022: Fair Servicing and Quality Monitoring Impacts

As we all know, customers are the most important part of Fairway!


This is our Fairway culture and each of us take pride in that every day.  We do our best to go above and beyond for our customers.  Within our industry, the event of COVID-19 and increased levels of customers impacted by the pandemic, it has emphasized the important role which Servicing plays in mortgage banking. 


Industry groups, the Consumer Financial Protection Bureau (CFPB) and States are focusing on meeting customer needs consistently and equitably, which means there is a strong focus on Fair Servicing and enhancing our policies and procedures to better document the behaviors that have always been an important part of our Fairway culture.  



What does the term Fair Servicing mean?
 
The Equal Credit Opportunity Act (ECOA) and Regulation B make it unlawful to discriminate against any borrower in any aspect of a credit transaction, including loan servicing, on the basis of any of the criteria referenced below:


  • Race
  • Color
  • Religion
  • National origin
  • Sex or marital status
  • Age (provided the borrower has the capacity to enter a contract) 
  • All or part of the borrower’s income is derived from any public assistance program
  • Borrower has in good faith exercised any right under the Consumer Credit Protection Act



How does this impact Customer Experience and Servicing911?
 
It’s business as usual.  Our goal is to provide a premier and the top-level of service for every customer and loan officer we communicate with each day.


It’s being mindful of the words we use, the tone we use with those words, and the way we respond through actions and levels of urgency.  


It is about asking ourselves and self-correcting if we are making any judgement about a customer based on the manner in which they speak (or write), or if they are challenged with the English language or if we are making any judgements based on how they communicate. 


Make sure our customers and loan officers receive the best service experience while being treated with respect, with fairness, and with equity.



Quality Assurance Monitoring Impacts

A category will be added to the quality monitoring scorecard which will result in an automatic fail if discriminatory or biased treatment is identified.        


Beginning April 1, 2022 Quality Assurance (QA) will incorporate a review of this information to ensure this level of fair, accurate and equal treatment is provided for all customers and loan officers who interact with our Customer Experience and Servicing911 teams.  Feedback will be provided to supervisors and managers for coaching opportunities.


QA scoring for this category becomes effective with the May 2022 scorecard calendar.