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FINANCIAL REMEDIATION FRAMEWORK FOR USE IN THE INDEPENDENT FORECLOSURE REVIEW

But also important is how a recovery is measured, and how success is defined. The recent op-eds focus on GDP growth immediately following the trough (usually 4 quarters). For a normal recession, the restoration of positive growth is typically a signal event. In a v-shaped recovery, the old peak level of GDP is quickly reached, and the economy returns to trend within a year or two. In Reinhart and Rogoff (2009), we examine both levels and rates of change of per capita GDP; recovery is defined by the time it takes for per capita GDP. | Office of the Comptroller of the Currency Board of Governors of the Federal Reserve System JUNE 21 2012 FINANCIAL REMEDIATION FRAMEWORK FOR USE IN THE INDEPENDENT FORECLOSURE REVIEW In April 2011 federal banking regulators issued enforcement orders against 14 large mortgage servicers for deficient mortgage servicing and foreclosure practices. The orders required those servicers to retain independent consultants to conduct a comprehensive review of foreclosures that were in process or completed in 2009 or 2010 the Independent Foreclosure Review to identify financial injury to borrowers that resulted from errors misrepresentations and other deficiencies in the foreclosure process. The Independent Foreclosure Review also requires those servicers to provide compensation or other remediation for identified financial injury. The OCC and FRB have developed a financial remediation framework the Framework that provides examples of situations where compensation or other remediation is required for financial injury due to servicer errors misrepresentations or other deficiencies. The independent consultants will use the Framework to recommend remediation for financial injury identified during the Independent Foreclosure Review. The servicers will prepare remediation plans based on the independent consultants recommendations. The federal banking regulators must approve each servicer s remediation plan. The categories included in the Framework are not intended to be exhaustive or to cover all possible situations or remediation options for borrowers who may require compensation or other remediation for financial injury. It is important to read the Frequently Asked Questions FAQs that accompany the Framework to understand how remediation will work. OCC FRB Financial Remediation Framework Independent Foreclosure Review No. CATEGORY ERROR DESCRIPTION FORECLOSURE IN PROCESS AT TIME OF REMEDIATION FORECLOSURE COMPLETE AT TIME OF REMEDIATION Remedy Dollar Payment Remedy Dollar Payment