Comments to the Federal Housing Finance Agency (FHFA) re: Alternative Mortgage Servicing Compensation Discussion Paper,
The National Consumer Law Center (NCLC) submitted these comments on behalf of its low-income clients and on behalf of the National Association of Consumer Advocates. NCLC believes that the existing model for servicer compensation is broken. Current servicer compensation is byzantine. The barriers to entry are high. And servicers are rewarded for bad behavior: servicers…