Federal Agencies LPS Consent Order Allows for SERVICER Restitution

Posted by L

I’m compiling the time line and came across part 2(f)(v) on page 11 of the LPS consent order here.

(v) measures to reimburse the Examined Servicer or borrower, as
appropriate, for financial injury from the document execution services provided by LPS;

Here’s the reconstructed time line

13-Apr-11 LPS Consent Order
12-Jun-11 Due Date Written Oversight Plan pg 6
28-May-11 Due Date Retain Independent Consultant to peform an Independent Review & Prepare Report on Document Execution Processes pg 9
2-Jun-11 Due Date Submit Engagement Letter for approval of Document Review Methodology pg 12
10-Oct-11 Due Date Document Execution Review, development of the
Remediation Plan, and completion of the Document Execution Report
pg 12
24-Nov-11 Due Date for Remediation Plan (“Remediate documents & reimbuse Servicers” or borrowers for financial injury) pg 11
12-Jun-11 Due Date Written Compliance Program pg 13
23-Apr-11 Due Date Retain Independent Consultant to Perform Independent Review & Prepare Report Comprehensive Assessment of Risks; operational, compliance, legal, reputational pg 14
12-Jul-11 Due Date Report on Risk Assessment
28-Apr-11 Due Date Submit Engagement Letter for approval of Comprehensive Risk Assessment Review pg 15
10-Sep-11 Due Date Submit Comprehensive Risk Management Program pg 15
12-Jun-11 Due Date Submit Written Plan for Internal Audit Program pg 17
10 days after each due date Agency approval or rejection of all written plans, programs, and/or engagement letters pg18
30 days after each calendar quarter Submit Written Progress Reports pg18

Notice how it says “Servicers OR Borrowers”

Which one you think they’re gonna pick?