Enforcement Alert: OCC Issues Consent Order on Servicing Deficiencies

The Office of the Comptroller of the Currency published a consent order on March 19, 2026 against a national bank servicer for deficiencies in mortgage servicing operations. The order cites specific failures in loss mitigation application processing timelines, escrow analysis accuracy, and borrower communication requirements under Regulation X.

The consent order requires the institution to submit a comprehensive remediation plan within 60 days, engage an independent compliance consultant, and provide quarterly progress reports to the OCC for a minimum of 18 months. No civil money penalty was assessed in the initial order, though the OCC reserved the right to impose penalties for non-compliance with remediation milestones.

This action follows a pattern of increased supervisory attention to servicing operations throughout 2025 and into 2026. The OCC's focus on loss mitigation processing is consistent with the elevated forbearance exit volumes that have characterized the post-pandemic servicing environment. For context, CFPB complaint data shows mortgage servicing complaints rose 12% year-over-year through Q4 2025 (CFPB Complaints Database).

The enforcement posture has implications beyond the named institution. Lenders with servicing operations, particularly those processing elevated volumes of loss mitigation applications, should expect heightened examination scrutiny on Regulation X compliance, escrow administration accuracy, and borrower communication timeliness.