Monday May 21, 2012
Late Start 7:20am
Intro by Joy
DFS - Chris Malbeko Sr Counsel, Nancy Ruskin Deputy Director of Consumer Fraud
GMAC/Ally/Rescap, American Home Mortgage Servicing Inc
Bernie Burnbaum Legal Aid Society & Consumer Advocates
Steven Masy, EVP & Michael Scolanti, GMAC Swear In
AHMSI – Questions raised in public hearing. Responsibility is to insure adequately against loss
Majority choose own insurance. Sometimes borrower forgets premium or chooses not to do so or changes insurers and forgets to advice AHMSI (blame the borrower, what about escrow????)
Borrower fails, but no charge as long as Dec page is shared.
Our goal is to make our placement of insurance the last resort for insuring the property. For example, if payment on an escrow loan are insufficient for voluntary and policy has not cancelled, we will advance from our own funds (actually from escrow…borrower funds…not yours) to avoid expensive policy.
We take many steps for 60 days notice before being charged. The goal is to engage borrowers and remind them of their obligation and encourage contact to avoid coverage. If borrower provides uninterrupted coverage, AHMSI will not charge any premium. If placed, but the borrower or insurer at any time provides that evidence with no interruption, we provide full refund.
AHMSI entered voluntary agreement with DFS to be a leader in the mortgage servicing agreement.
GMAC – SVP in charge of customer operations which includes loss mitigation, HAMP, etc.
Homeowners face challenges because of us, us, and the economy. We have pride and commitment through loan mods to avoid foreclosure for our best interest. LPI is a last resort. We communicate effectively. For escrow, if we don’t receive a renewal 15 days prior to expiration, we call insurance carrier/agent for premium (not to pay). GMAC seeks info regarding insurance coverage before placing lender placed policy (they have access to prior insurance info, so not blindly insuring as previously stated by BAC & Chase).
We process refunds within 14 business days. We strongly prefer borrowers don’t fail, but we advance our own funds (borrower escrow funds). We don’t receive payments in any form for LPI and recoup costs to keep borrowers current. GMAC has no involvement in rates, no reinsurance and no financial interest or affiliation. We rely on QBE First.
GMAC continuously reviews for fairness for investors and borrowers. We remain open to better serve NY consumers.
DFS: One thing we’ve been talking about are the various incentives or considerations that the insurers provide to the servicers in connection to LPI. I’d like to start with that. Did AHMSI ever receive a lump sum payment or bonus from QBE predecessor ZC Sterling?
DFS: Was that in excess of $9 million?
DFS: What was the point of that payment?
AHMSI: It was in Aug 2008, so I’m aware it exists but I don’t know why it is that amount. I understand at its face it’s for additional up front compensation for references and sit on advisory boards (but not for premiums). I tell them where they excel. I’ve sat with the president and discussed their industry (but not rates or premiums).
DFS: The letter that you reference refers to marketing efforts? Explain
AHMSI: I don’t know intent or interpretation except what I said…to assist them in developing their program. They wanted to expand. Having us as a client would help them, whether with language of letters, website, etc. I’ve been a part of it all.
DFS: Do you think homeowners or investors should be required to absorb these marketing costs in premiums?
AHMSI: Ummm…I don’t…I don’t know that they absorb that. They pay a premium that gets assessed to the borrower. No one is requiring the borrower to place LPI premiums. They have the option to maintain their own coverage and it’s our preference they do.
DFS: My point is the filing and expenses, do you think that servicer marketing for a force placed insurer to promote their product is an appropriate expense should be included in the rate?
AHMSI: I don’t know. I don’t develop rates (but you sit on their board with their president). We rely on QBE. QBE QBE QBE
DFS: Does AHSMI receive commissions from QBE First?
AHMSI: We do
DFS: How much?
AHMSI: A relatively standard 15% of net written premiums. Refunds of LPI are deducted from any premiums written and no commission can be earned on a cancelled premium. Borrower’s fault, even if we assess premium
DFS: Since when have they received 15%
AHMSI: Since the inception of the agreement, July 2008.
DFS: How much are you paid monthly in commissions?
AHMSI: That depends. It’s on Net Written Premium. It’s on the borrower. A Million to 2 million I suppose.
DFS: do you know how much you’ve received since 2008 total?
AHMSI: I do not know.
DFS: What was provided to us was more than $60 million. Do you dispute?
AHMSI: I don’t know
DFS: Doesn’t AHMSI have a servicing agreement with QBE First under which QBE provided outsourced services?
AHMSI: Uh, Tracking Services. The agreement is for tracking insurance, not for placement per se.
DFS: So QBE First is responsible for tracking when borrowers have coverage? Aren’t they responsible for letters to customers as well?
AHMSI: Yes that’s correct
DFS: Aren’t they also responsible for issuing LPI?
DFS: Isn’t QBE First responsible for responding for borrower inquiries?
DFS: Do they manage Escrow Services?
AHMSI: Yes (Chase & BAC said no)
DFS: So because QBE First has all power, doesn’t AHMSI provide minimal service for our commissions?
Can you describe AHMSI services performed?
DFS: So let’s talk about I guess business in general. AHMSI has a duty to ensure coverage, but we’re not an insurance company, we service mortgages. We hired QBE First for that. They have technologies we don’t have (based on Windows 98) or afford. They can receive a voluntary policy and scan those documents in and their OCR tech can determine the policy and recognize the policy. We don’t have that (Windows 98) technology. We don’t do our own printing either. It’s not unusual for these relationships.
Specific to your question to what we do: a lot. Today we service 400k + loans. If I spread those out linearly, that means 33k loans are apt to have their insurance expire in any particular month. The end result is placement of LPI. In the administration of mortgage servicing, there are literally perpetual transactions every day. Uh, in that course, for example, for an ARM change, his payment inadvertently gets processed using pre-ARM adjustment (AHMSI error). We reverse and reapply.
Blah blah blah…we made a mistake, QBE First has to react, the borrower did nothing….and that happens a lot.
Additionally you took exception, but we audit QBE First (how? You don’t know insurance) We developed everything (you just said you didn’t) and make sure they administrate the loans in according to our instructions. So insurance agents (which I said we don’t have) check for evidence. We look at cancelled LPI to make sure borrower was cancelled correctly. We do a lot of auditing day by day (but you’re not an insurance agency by your own admission…how are you qualified to audit work you don’t even have the technology to perform?)
If your escrow is short because you’re late with your bill. AHMSI advances those dollars (actually QBE advances it…out of the borrower’s escrow). We borrow the money (from the borrower) to pay millions and millions and millions in interest supporting failed borrowers. That’s what our commission is for.
DFS: You reference the audit function. Do you think auditing your vendor for LPI is appropriate and should be passed on to the homeowners?
AHMSI: I don’t know if it’s included in the rate, that’s the insurance company.
DFS: You’re receiving a commission.
AHMSI: All of our borrowers to make sure we do a good job, I know as a consumer I do. If I know I have a relationship, I would hope they would spend money on compliance so yeah, that’s fine.
DFS: The issue is that the cost for LPI far exceeds the cost of voluntary insurance so when commissions and other payments are added to the cost, ultimately those premiums may not be appropriate when the homeowner receives less coverage than before.
AHMSI: (stunned silence) I’m sorry is that a question? But Umm…..yes I think there are a couple of facts I’ll repeat: Borrowers can avoid LPI. It’s in their control (not based on what you said a few minutes ago). Also the insurers need to set correct rates.
DFS: Do you know your LPI loss ratios for your portfolio?
DFS: Do you know QBE’s Loss Ratios across the board?
DFS: We heard under 30% for 3 years. Doesn’t that indicate high premiums?
AHMSI: (silence) I don’t, I don’t know that it does. I’m not in the insurance business (but you personally audit them). I’ll conject that maybe QBE also purchase stop loss coverage to help administrate risk and pays for reinsurance for catastrophe. I don’t know if 26-30% is fair and equitable considering all other factors or not. As a citizen, I guess, I would question how many years of a 30% loss ratio it takes to offset a Katrina year. I don’t know. I’m sorry. I’m opinionating. I think the right response is the dept and industry has a mechanics in place to review loss ratios and set rates. Each year, your carriers are required to submit to you 100’s of pages of stats about loss ratios, casualty, etc. I would think the dept would sum total all of that info they receive annually from the carriers would have all the info necessary to determine premium viability.
As a businessman with a duty and obligation to both our borrower and investor, I want to look to the state and the industry (we’ll do what we’re required to do).
DFS: One reason for hearings is expenses, commissions, etc in rates weren’t transparent. We’re exploring these rates. One point I’d like to make since you spend some time saying your obligation is to investors to the extent the homeowner can’t pay, ultimately it’s the investor that bears the cost. I’d ask whether you, as AHMSI, would better serve your obligations to investors/homeowners by asking QBE for lower rates.
AHMSI: That’s a complicated request. I don’t know that it’s our position to step in front. I’ll leave that to you, but relative to the borrower/investor, the intent is in tune. Borrowers want to replace a burned down house. Just relative to the investor alone, I think they’re looking for viable loss mitigation. They’re aware there’s a cost, but they look at us to collect payments due and assist borrowers actively to ensure they stay in their houses. I think we lead the industry in taking care of borrowers. I do think again if the borrower is delinquent and working to bring themselves current, if their carrier (not borrower) delivers to me a bill, AHMSI dips into our (borrrower’s escrow) pocket and pays it.
LPI is arduous to keep tabs and process, checking, auditing, funding, it’s expensive. I don’t like LPI, but it’s our obligation, and borrower’s actions or lack of forces us to have to take action.
DFS: The dept doesn’t dispute LPI is appropriate in certain circumstances (service, not product, they’re procuring insurance for you). What about previous homeowner testimony?
AHMSI: FEMA changed determination of her property to required flood coverage. We notified her and she contested her flood plain with an elevation certificate. We explained if it was certified and approved by FEMA to opt out, we honor those. There’s a process (like he said, a long, arduous one) when FEMA changes designation. Ultimately she chose not to, and got her voluntary carrier to issue coverage with a gap for a small amount, unacceptable.
We advised her it was too low, and ultimately several months later, her Gap policy was cancelled (a Gap policy isn’t for a time gap. A flood gap policy is for the gap between what you acquired and the $250k max).
DFS: When you talk about auditing, do you look into branding problems?
AHMSI: I’m not familiar with that. I’ve hired QBE First to perform insurance tracking and respond to customers. Umm…I expect QBE First to be AHMSI. They have our Policies and Procedures (also Bank of America, GMAC, etc). I have an expectation that QBE is AHMSI when they communicate to our customers. I would venture to say my services rep with QBE First would probably be able to recite to you my mantra to them. Blah blah blah.
They know my expectation, AHMSI’s expectation. It shouldn’t be confusing. If they said QBE First, the borrower may be confused. If the borrower asks, I would expect them to provide the truth (nope…that’s not in the P&P’s you provided). I don’t know specifics. She can call in and talk with AHMSI’s customer care or call QBE First from the letter who is AHMSI in those endeavors. She can talk to either or both. We share a servicing system (BAC said there’s no shared systems).
DFS: I think you said about commissions that one of the roles you fill is auditing QBE First. Their interactions with customers, phone calls, and
AHMSI: We calibrate phone calls and make site visits to QBE, both for tax tracking, escrow administration, and Loss Drafts Administration (claims).
DFS: Customers get the runaround, being referred back and forth between QBE First and AHMSI with no connect between info given. Can you explain how you make sure QBE First has that info since you are required to provide a SPOC?
AHMSI: (closes eyes to think) we’re human beings administrating services and tracking. I’m sure mistakes do get made. When they’re made, I apologize to any of our borrowers. That’s not our intent. Our intent is excellent service, as I’ve said. We want to be a leader and serve our customers and borrowers.
If human beings being involved and can’t quickly use systems (they can all access the same systems, you bullshitter). There is a servicing system with an escrow workstation. All info is in AHMSI’s system. QBE First info is boarded into system. The info is there for the borrower to be serviced. The borrower gets a letter, and QBE First has access to our Servicing System (not what BAC said).
SPOC was designed to help servicing distressed borrowers, not related to insurance. We try to centralize the SPOC service as broadly as we can. It’s naïve to except 1 individual to know loss mitigation, bankruptcy, tax implications, insurance implications, escrow administration, there’s an awful lot of info. There’s only so much 1 individual can do, so we break it into components.
DFS: Question about the servicing agreement. It requires AHMSI to take steps to continue or reestablish voluntary. Since entering the agreement have you changed your practices?
AHMSI: Specifically I don’t know. Again, I can tell you that it is AHMSI’s intention to attempt to keep coverage in place whenever we’re allowed. I gave an example where a borrower cancels their coverage. AHMSI can’t negotiate that policy, the borrower cancelled it. AHMSI is dependent on the borrower. The Geico lizard or Allstate or Flo. (more bullshit). Every night our borrowers are being pounded on by the insurance industry saying “come to us. Come to us.” I don’t mean to sound glib, but they may change. AHMSI is reliant on the borrower if they change. Long winded answer, we make every attempt possible.
DFS: Who would know?
AHMSI: I don’t know who would be able to respond. I don’t know that
DFS: Is there someone at AHMSI in charge of the agreement?
AHMSI: Me. Umm…our compliance and legal are perpetually reviewing how to serve our customers. Can anyone say we read our own agreement? Change is perpetual, etc. We probably have changed it, but I don’t know that anyone’s sat down and reviewed the agreement.
DFS: How many employees to you have for LPI?
AHMSI: 5 of the 6.
DFS: Does that include IT?
AHMSI: IT, Human Resources, Accounting, etc are administrated by AHMSI as a whole. In our customer care group, they calibrate calls and audit conversations…ummm..ummm…when we do our site visits, it’s a different element of an audit (more bullshit. I used to give those site visit tours through operations. They see nothing and get some great food out of it).
There’s more AHMI that has nothing to do with me audits (once again, not what BAC says). Multiple auditing tiers to meet our obligations as a servicer.
DFS: How many people go?
AHMSI: It depends from a couple to a lot. It depends. Always a couple. A pair. 2. (who go in groups with other vendors, such as GMAC, Chase, etc, so there’s usually a dozen total in each tour.)
DFS: You reference that ZC. Sterling issued warrants to AHMSI shareholders. Comment?
AHMSI: Comment? (awkwardness)
DFS: Did that play a role in selecting ZC Sterling?
AHMSI: I have no idea. That was between ZC Sterling and a completely different entity. I don’t know.
DFS: Did Assurant offer any warrants?
AHMSI: I have absolutely no idea. I don’t know. I can ask.
DFS: I’d like to know whether the 2008. Is it fair to say financial terms were a prime consideration in considering QBE First?
AHMSI: Again, I’ll take exception to prime because I don’t know what it means and I don’t know if it was comparable to any other arrangement, then not if it’s equal. Yeah yeah yeah, but I I I I I I do know, I was aware of ZC Sterling. One of the considerations was the reputation through osmis (really?) probably a significant consideration. Being organic (in money laundering) and dialogue (or money laundering) and listening to me, and I apologize. I can shag a dog. They listen to my concerns. We get great response. It’s comprehensive and organic.
With a snag for claims administration, we get on the phone and almost always QBE will defer to us, and if we want this claim paid, here’s what I understand and you don’t make sense, they’re flexible with us (the servicers) in the placement of the product (performance of service).
DFS: do you know what percentage of claims submitted are paid?
AHMSI: No, I will try to get it.
DFS: You said AHMSI oversees filing of nonborrower claims. What type of oversight is done on vacant properties?
AHMSI: I don’t know (QBE FIRST DOES THAT). There’s a process in the servicing arena that isn’t our responsibility. We receive inspection reports and BPO’s through different business units (of QBE First) then outsource the claims administration to 2 vendors not QBE. This company pursues claims on behalf of AHMSI (to QBE…these bankster idiots are reading my notes…fucking cheaters…).
AHMSI: Dimont out of Atlanta and Quality Claims out of San Diego
DFS: What about duplicate coverage? Approximately 60% may have duplicate coverage and refunds are automatic (no they’re not…QBE First’s Premium Administration and Data Integrity departments do this, under Steve Ramsthel, DaleAnn States, Rhonda Meyers, Peggy Johnson, etc from the Anonymous leak last March)
AHMSI: The minority of our borrowers. The vast vast majority fulfill their obligations. We reach out 15 days prior to and attempt to discuss renewal with their agent or insurance company to make sure there’s no duplicate coverage (QBE does all of this…not AHMSI).
I would like to turn our self-insurance woes onto the Insurance companies and drag them under the bus with us. (QBE’s website was IHaveInsurance.com…when did it become updatemyinsurance.com????)
It’s not intended to be complicated, blah blah blah. If they call us to discuss insurance, they’re transferred to QBE First. Sometimes it’s the wrong info or to the wrong fax number (all done by QBE First, not you).
It’s not intended to be complicated, blah blah blah. If they call us to discuss insurance, they’re transferred to QBE First. Sometimes it’s the wrong info or to the wrong fax number (all done by QBE First, not you).
I think the borrowers if they fail to respond and get to letter cycle, I think they say oops and send the Dec page, it gets scanned by QBE First, coverage goes away, everything’s good (Wrong again, kid).
DFS: there’s a real disconnect between the homeowners, advocates, and legal counsel and the servicers. We’re not suggesting anyone’s not being truthful, but we need to look at the processes.
AHSMI: From my perspective, having an active conversation. I’ll try to add it to things, from the fax number to attaching a step by step list, etc (all borrower’s fault). We’re always open.
DFS: Let’s talk about the letters.
AHSMI: They go out under separate cover. My personal concern with nesting is they may think it’s additional info they don’t need (as opposed to a blank envelope?!?!?!? You’ve gotta be kidding me by now).
We, again, our goal is to be direct and forthright so the borrower, the borrower, the borrower. Between our brethren in mortgage servicing. If we think putting it on hot pink paper is better, we’ll do that (yeah, asshole…bright pink paper and car wash coupons will help.)
DFS: single/dual interest
AHMSI: Dual interest. The borrower is issued a certificate. That certificate is dual interest (until REO).
DFS: What is done to explain to the borrower when they see the servicer as a policyholder. What do you do to tell them they can file a claim?
AHMSI: I don’t….I would question whether borrowers are thinking it’s insurance. It’s insurance. Borrowers would think that’s their insurance policy. If they’re confused, they can contact us (no they can’t) they can hit insurance and go to QBE First. They can talk to my group (of 8...servicing 33k per month transactions).
DFS: there’s confusion with low Loss Ratios compared to traditional insurance at 65%. We’re trying to get to the bottom of that.
When you’re seeking proof of voluntary coverage, do you allow payment options like the force placed insurance?
AHMSI: If they’re escrowed, we pay monthly and disburse annually from their account (but earlier you said that was out of your pocket).
Non escrow there needs to be an annual policy written. How a borrower facilitates payment (AHMSI sets up an escrow account for LPI) AHMSI doesn’t know that. That’s QBE (who we audit).
I don’t know that we have any policy for anything. Umm…I think the concern about monthly pay is that the insurance company themselves can be automated. The borrower’s check doesn’t get there until 3 days after the month, I’m likely to get a cancellation notice from that carrier due to non payment.
If they receive repeated notice, I would think it would be a very disciplined borrower unless they set themselves up on ACH. That’s the carriers.
DFS: GMAC, we’ve been ignoring you. Who is Homecomings?
GMAC: Homecomings Financial was another GM owned mortgage company. I’m GMAC mortgage, and that was a servicer for another company owned by GM. We had no responsibility with them until 2007.
DFS: Are you aware with Assurant and Homecomings 2004 agreement for being sole force placed insurer? When did you convert?
GMAC: May 1, 2007
DFS: That was still during Assurant’s agreement. Why was a switch made?
GMAC: QBE was operationally stronger, so we consolidated. It was a better operation. It was double the work.
DFS: I believe there was a year left.
GMAC: I wanna say it was a year. We had to provide notice prior to that of cancellation. We did not pay any penalty.
DFS: In 2007, when Homecomings switched to Balboa…can you tell us who Newport is?
GMAC: It’s the tracking arm of Balboa. I’m not versed. Balboa for all intensive purposes.
DFS: $4.2 million in conversion costs for Homecomings. Do you know how much was actually paid to GMAC?
GMAC: I will get that. We’ve been trying to find out.
DFS: what for?
GMAC: Unrelated to Force Placed Insurance. Technology changes. Scripting changes, QC, Loss Draft Processes, Insurance Claims, Increased Customer Phone calls, REO insurance monthly process (only for hazard REO. Flood REO is still annual).
That was based on Balboa’s tracking services.
DFS: Did Homecomings pay Assurant?
GMAC: I don’t know. I didn’t manage it.
DFS: I can tell you that homeowners paid Assurant on a per loan basis. Does GMAC currently pay QBE First for tracking services?
GMAC: No we do not. We do not share in the expenses or revenue. We wholly outsource to QBE. You would have to ask QBE. I don’t have their financial info.
DFS: are you aware other servicers pay for tracking services? Would you view this where GMAC does not have insurance agency taking commissions, in lieu the consideration that might be given is not having to pay for tracking services?
GMAC: same bullshit answer as before. It’s speculation. I don’t understand.
DFS: The servicers pay the insurance tracker. Why don’t you pay?
GMAC: same exact bullshit answer.
DFS: QBE is tracking for free?
GMAC: You’d have to ask them.
DFS: How do you analyze QBE?
GMAC: System transparency and reporting, onsite audits through business analysts.
I have a peer for call centers. He does it all (meaning I don’t know).
(it’s getting really good right now) J
RFP was late 2001/2002.
I can’t answer if premiums were considered.
DFS: Did Balboa not requiring tracking fees?
GMAC: in 2003, they did charge
DFS: Do you know how much?
GMAC: I can try
DFS: We asked about erroneous placing of force placed insurance. GMAC stated it reviews the performance on a monthly basis to review for compliance. We notify of concerns of QBE’s performance. What kinds of problems has GMAC found?
GMAC: QBE has performed well aside from clerical errors.
DFS: Do you have an error rate?
GMAC: We do not (you said you audit them)
DFS: you refunded more than retained.
GMAC: I don’t pay attention to that. I’d refer to QBE for that. My staff typically (during audits) at premium.
DFS: (whispering) do you want to just put it in the record?
Do you receive the quarterly and annual business reviews provided by Balboa? Did you review those?
GMAC: Not in 2010 (why did you bring up 2010, nervous nelly?)
DFS: Was there ever a discussion of Loss Ratios?
GMAC: Informational. I’m not familiar. We’re not involved in premiums. They’re template reports (just like I said in the FNMA regulations).
(These fuckers are going to jail…I absolutely LOVE you, Joy!)
I’m familiar with the numbers.
DFS: You know the numbers, the loss ratios were generally very low in the 20% range?
GMAC: yes, but I don’t know if that’s low or high. I don’t know insurance.
DFS: does anyone evaluate loss ratios?
GMAC: as stated earlier, we rely on the regulators (take these people down…regulate the fuck out of them).
DFS: Do you feel you have an obligation to the customers (borrowers) to price shop LPI?
GMAC: QBE QBE QBE QBE QBE QBE QBE QBE
DFS: so it’s in GMAC’s interest to maybe use it’s market power to try to encourage lower LPI rates.
GMAC: We would benefit, but I don’t know we have that power. We would refer to QBE. We would be in favor of lower rates.
DFS: Where does GMAC fall in terms of ranks in terms of servicing loans in the US?
GMAC: GSE’s top 3. We’ve ranked in the HAMP and Loss Mitigation for top 3 and generally number 1 since the program is in effect. We’re highly regarded.
DFS: that implies market power.
GMAC: We rely on state regulation.
(more stumbling…this guy reminds me of Jerry Lewis. He looks like he’s wearing those glasses with eyeballs drawn on them)
DFS: How does LPI high rate help customer?
GMAC: It doesn’t. We rely on investor and state regulations. I’m not an attorney. Talk to my attorney.
DFS: Are you familiar with homeowner letters?
GMAC: I have read them, but I’m not familiar with the envelopes.
DFS: QBE First does this under GMAC’s name?
GMAC: I believe so. They’re not included with the mortgage statement.
DFS: Do you know whether the envelope has anything ?
GMAC: I’ve never seen it, but I assume it says important info enclosed (sorry, I’m falling behind by laughing so much at this guy).
DFS: Does GMAC or QBE or a vendor on GMAC’s behalf inspect vacant properties for LPI?
GMAC: We do have tracking, but I don’t know if they’re filing claims, but I can provide you with claims on vacant properties (actually QBE will do that…through FIS system queries…what I used to do).
I assume, I assume. I’m not sure.
DFS: you manage operations?
GMAC: for problems, I do.
DFS: Have you ever heard or been part of discussion within the company about the impact of high premiums impacting customers?
GMAC: No, we rely on QBE and it’s regulators (hahaha, not it’s QBE’s regulators…smooth, son)
We like Balboa.
DFS: Minimum Loss Ratio?
GMAC: I’m not an insurance financial expert. We would support whatever you legislate.
AHMSI: That’s complicated. I think I’ve said we look to regulators.
When it comes to it, we’re mortgage servicers. We carved our reputation on keeping borrowers in their homes. Anything we can do we will.
DFS: The numbers are profitable. The loss ratios are extremely low and the profits are there. Thank you. I know it’s not easy, but we really appreciate your time.