Point of View: Regulators Need More Loan Servicing Data.

Mr. Dugan, comptroller of the currency, heads a regulatory agency that oversees large national banks. This viewpoint is Mr. Dugan's Feb. 29 letter to nine large national banks that account for the vast majority of national bank mortgage servicing.

I am writing to follow up on the Feb. 7, 2008 meeting held by the OCC with nine large national bank mortgage servicers, including your institution, to discuss provision of comprehensive mortgage data to the OCC on a monthly basis. The OCC is requiring this comprehensive mortgage data in order to assure that we have a detailed picture of the activities of national bank servicers and the performance of loans serviced by them. We were very pleased with the level of cooperation evidenced at the meeting and the recognition of the importance of prompt provision of data to us.

In brief, the scope of the mortgage data we are requiring is not limited to subprime mortgages serviced for mortgages in securitization pools. We believe it is important to obtain key mortgage performance metrics across a broader field, and therefore, our data collection covers all mortgages held on book by national banks and their subsidiaries, and loans serviced for others. The mortgage data we are seeking uses common definitions and data elements for asset quality metrics (delinquency measures, foreclosures, etc.), loss and foreclosure mitigation actions taken, and segmentation by credit quality risk indicators (such as FICO scores). With this approach, we will have data that is consistent, comparable and reliable.

We also believe it is important to build upon, and not conflict with, the mortgage data collection efforts of the Hope Now alliance, whose members constitute a broad cross-section of industry and community organizations working to take the foreclosure crisis.

Thus, after the meeting on Feb. 7, 2008, OCC staff solicited and received feedback on OCC-proposed mortgage metrics, data definitions and reporting schedules from all large bank servicers who attended the meeting. We also shared and discussed OCC proposed metrics, data definitions, and reporting schedules with the Hope Now alliance in order to coordinate data collection efforts and minimize regulatory burden. We understand that, ...