We received some questions from a few readers who wanted to know what the Office of the Comptroller of the Currency is really after, in terms of an announcement Monday that it would require nine of the largest banks to provide loan-level information on every loan serviced to the Federal regulator. While we can't confirm whether or not Comptroller of the Currency John Dugan is, indeed, off on a power trip or not, we can offer two more reasonable reasons why the OCC would want this data:
  1. The agency is going to share the data with state agencies; more than a few states are coming after servicers with their own reporting requirements, and we think this could a move by the OCC to preempt that sort of trend. You know, perhaps after a closed-door session with some industry participants concerned about meeting 50 different reporting requirement standards?
  2. We think it's possible that the OCC is prepping for an expanded effort to address servicing activities within the context of broader bank stability. With so much consolidation in the offing for mortgage banking, and a return to the banking aspect of mortgage finance, I think the OCC wants to get a handle on – for example – what a BofA/Countrywide servicing operation is going to mean for the bank itself. We'll bet that, right now, they have no clue.
(Of course, it's going to complicate things when the OCC learns that no two servicers tend to record or report data alike. But we'll let them figure that out on their own.)