Hi All,
My institution is going to a new customer portal for mortgage servicing, and I am a little concerned about the payment functionality.
The one-time payment function allows the use of a payment account in the name of one of the borrowers OR a third party. Since this is a one-time rather than recurring payment, Reg E doesn't really address whether a borrower can authorize a debit to a third party's account.
From a common sense perspective I would think not, but when I checked the site of my own mortgage servicer (Dovenmuehle) they also allowed the use of a third party payment account. However, they also allowed a third party account for autopay, which I think is pretty clearly not allowed with online setup (since you are neither getting authorization from the payment accountholder not are you providing them with a copy of the authorization).
I could use some input from my fellow BOLers.
1. If you service loans, does your online servicing system allow borrowers to use a third party account to fund a one-time payment?
2. Are you aware of any regulation or guidance that addresses authorization of a one-time payment?
3. Do any of you use the FiServ LoanLink servicing interface? If so, please send me a private message.

Thanks!

BX