Is this just for specific banks?

OCC to Require Data from Large Bank Mortgage Servicers

WASHINGTON — The Office of the Comptroller of the Currency is requiring large national banks that service mortgages to provide comprehensive mortgage data on a monthly basis. The required data will build upon the efforts of the HOPE NOW alliance, a cooperative effort between investors, lenders and counselors that is intended to help distressed homeowners.

In a letter to nine large national banks that account for the overwhelming majority of national bank mortgage servicing, Comptroller of the Currency John C. Dugan said the OCC is requiring the 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.”

Mr. Dugan noted that the data collection effort was discussed at a meeting with the banks on February 7 and said the agency “was very pleased with the level of cooperation evidenced at the meeting and the recognition of the importance of prompt provision of data to us.”

With record numbers of foreclosures, the data is expected to give the OCC and other regulators a more complete view of the market, which will aid in the agency’s supervisory work as well as help in preventing unnecessary foreclosures. Metrics developed from the data on subprime lending will be available to state agencies through the HOPE NOW alliance, and should provide a robust and comprehensive overview of subprime mortgage lending.

While the HOPE NOW alliance is collecting data on subprime mortgages, the OCC is seeking a broader data set that includes information on all mortgages. The OCC is also planning to collect data on home equity loans as well, later this year.

The OCC has had an effort underway for some time now to develop data that would provide key metrics on the mortgage lending industry, and share the agency’s proposed metrics, data definitions and reporting schedules with HOPE NOW. HOPE NOW has revised and expanded its subprime mortgage metrics to be more consistent with the enhanced metrics to be used by the OCC, and the OCC has made some revisions to its metrics and definitions so they would be compatible with the HOPE NOW data set.

As a result, national banks can satisfy the OCC reporting requirements either by sending mortgage data directly to the OCC, or the OCC will accept mortgage data prepared on behalf of national banks from the HOPE NOW alliance data aggregator.

“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 tackle the foreclosure crisis,” Mr. Dugan said.

Related Links:

Letter to Large Banks on Mortgage Data Requirements (http://www.occ.gov/ftp/release/2008-24a.pdf)
Comptroller of the Currency John C. Dugan (http://www.occ.gov/dugan.htm)
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Looks like just the large banks that are members of the HOPE NOW Alliance. A list a participants can be found here:

http://www.fsround.org/media/pdfs/AllianceStatement.pdf

we supply the data and have a pretty good story to tell

Thanks. They throw terms like "large bank" around and it means a dozen different things depending on the context.

I saw NeighborWorks America on the list. I wonder if the fact we buy loans from them and have another partnership with them on NHSA loans will require any reporting from us.

So if we are not on this participant list then we are not currently required to report is that correct?

That's the way I read it.