Opinion
The ranking of Bank of America Mortgage, an operating department of Bank of America N.A., which is a wholly owned subsidiary of Bank of America Corp., is raised to STRONG from ABOVE AVERAGE as a residential loan servicer. The ranking reflects the company's excellent management depth, extensive training regimen, well-drafted policies and procedures, and capable internal controls. Management has successfully integrated most of the earlier practices of the previously two distinct mortgage banking entities, resulting in a more cohesive and uniform mortgage servicing operation. The delinquency levels, along with the company's cost-to-service and loans-serviced-per-servicing employee statistics, continue to remain significantly better than industry averages. This is attributable to management's effective use of technology and capable internal controls. Though the company closed one of its four servicing platforms, and consolidated the loans among its remaining locales, it does not appear that there were any detrimental effects to the company's overall servicing performance. Over the last year, the company has continued to refine its internal audit practices, policies and procedures, and training programs, with a focus on adopting the most favorable practices of the formerly separate entities. This has resulted in refinements to several areas of the operation, thus enabling the company to leverage productivity and efficiency throughout the mortgage division.
Outlook
Stable. Management plans to continue implementing technological improvements at the company to further improve servicing levels. Standard & Poor's believes Bank of America Mortgage will remain a highly competent loan servicer in the residential marketplace, but will continue to monitor the status of the company as further developments arise.
Key Statistics
2000*
1999
1998
Loan Administration Loan Portfolio Total
Volume (mil. $)
280,187
268,449
225,348
Loans (#)
2,542,761
2,497,291
2,295,453
Delinquency (% of loans)
Total
2.86
3.23
3.89
30-day
1.93
2.13
2.53
60-day
0.40
0.47
0.58
90-plus day
0.53
0.63
0.78
Foreclosure
0.47
0.60
1.05
Bankruptcy¶
0.74
0.77
0.84
REO (#)§
835
1,030
1,403
*Statistics as of June 30. ¶Bankruptcy data included in the 30-, 60-, and 90-plus-day categories as applicable. §Bank-owned REOs only.
Profile
NationsBanc Mortgage Corp. and BankAmerica Mortgage Corp. combined to become Bank of America Mortgage on April 1, 1999. The former holding companies, NationsBank Corp. and BankAmerica Corp., previously merged in September 1998 to form Bank of America Corp. The company is the largest servicer of conventional mortgage loans in the United States as of June 30, 2000, according to National Mortgage News. There are now three servicing platforms, located in Louisville, Ky., Buffalo, N.Y., and Richmond, Va., due to the closing of the Cypress, Calif. operation earlier in the year. Management's main focus over the last 12 months was on integrating the practices of the two previously separate entities into a unified mortgage banking approach. There are no further plans to acquire other financial entities as the company will rely on its retail, wholesale and correspondent channels for portfolio growth, which is expected to be minimal for 2000. Bank of America Mortgage is an approved seller/servicer for the VA, FHA, FNMA, FHLMC, and various private investors.
Management and Staff Recruitment, Development and Training
Bank of America Mortgage has an exceedingly experienced management team that is able to freely recruit qualified applicants due to the favorable geographic location of its servicing sites.
Senior managers average 20 years of industry experience and have been with the company for approximately 14 years.
Company turnover averages an acceptable 23%, and senior and middle management turnover is less than 10%.
Bank of America Mortgage's extensive training program uses the services of both corporate and dedicated mortgage company personnel to properly educate the staff in their respective job responsibilities. Consisting of multiple training tools, with particular emphasis on customer service and default functions, the curriculum encompasses the following highlights:
New hires undergo an introductory orientation in mortgage banking, loan servicing, and the corporation.
Most instruction is conducted in a classroom environment using on-site training facilities.
Function specific training modules exist for all areas of loan servicing.
The education process also involves new employees handling active accounts in a supervised forum, which more fully acclimates them to the mortgage servicing function.
Depending on the position, training can last up to eight weeks and includes testing on the materials.
Interpersonal and system-related courses are offered to refine personal expertise and further career advancement.
Supplementary programs are available in computer-based, video, and hard copy format as a self-paced study mechanism.
Management also sends its employees to industry conferences and periodically invites its vendors or investors to conduct seminars in pertinent mortgage servicing topics. Overall, Standard & Poor's believes Bank of America Mortgage has a well-structured training regimen that provides the appropriate level of knowledge to its personnel.
Organizational Structure
Bank of America Mortgage divides loan servicing activities among its three loan servicing sites according to product specialty. The Buffalo facility handles bulk servicing acquisitions, while the Louisville office is responsible for 30-year conforming and biweekly fixed-rate mortgages. The remaining product types are serviced by the Richmond platform. The three division managers report to the national loan administration director, who ultimately reports to the president of the mortgage company. Each of the division managers serve as a focal point for introducing and reviewing any strategic initiatives pertaining to an assigned function, although all concerned parties must agree to any proposition. This helps promote consensus and consistency within the servicing organization.
Technology
The company operates in a very well automated environment, with excellent systems that help Bank of America Mortgage to maximize and to maintain a high degree of productivity. Personnel may access several different software applications, including:
ALLTEL Inc.'s mortgage servicing package for most loan functions;
DAISY, a management reporting system developed by First American Corp., that assists in generating customized default reports to ensure compliance with investor and/or company requirements;
The Hogan and LenStar system for timely tracking of bankruptcy filings and foreclosure referral/communication with attorneys;
Additional technology, such as a VRU, ACD, and scoring models, which assists in customer service and collection functions;
Detailed disaster recovery and business resumption plans, with a telephone calling tree, which is tested semi-annually. The company uses existing servicing locations as a hot sites in case of a business interruption;
Sufficient systems capacity to support any significant increase in business; and
Daily tape back-ups stored at an off-site facility
Management intends to explore other web-based applications that will assist in enhancing service levels over the next year. Standard & Poor's believes Bank of America Mortgage has an effective systems environment.
Internal Controls
The company's policies and procedures properly address all investor and company requirements, including suitable controls over suggested revisions. General features are as follows:
Manuals are written in a concise and thorough manner, in many instances including specific matrices regarding statutory and/or investor requirements, which greatly aid in the training process.
Changes to the servicing policies require unanimous agreement among the servicing sites, the consent of the national servicing manager, and, in certain instances, legal counsel.
Generic company servicing policies may be accessed on the company Intranet.
Not all servicing manuals are available in electronic format. This is primarily due to the company's prior emphasis on consolidating the policies and procedures of the formerly separate entities through the use of a 'best practices' approach. Management plans on establishing an on-line version of the policies sometime next year. Standard & Poor's strongly believes that electronic access to policy and procedure guidelines results in a more knowledgeable staff that applies servicing practices in a uniform manner, and thus, encourages the company to expedite this process.
Bank of America's inclusive audit program utilizes the review services of two different departments to ensure appropriate adherence to company guidelines. The risk assessment and methodology processes exhibit solid controls, consisting of the following:
Both corporate audit personnel and a separate quality assurance unit review all areas of loan servicing at least annually. Quality assurance reviews are based on HUD requirements for FHA loans and a risk-based audit of remaining loan types.
The risk assessment plan is reviewed each year to incorporate needed revisions to the plan based on prior audit findings.
On-site quality assurance personnel at each servicing center average over 10 years of industry experience, 3.5 of which are in compliance-related matters.
The audit methodology details response timeframes, and includes issuance of monthly reports to departmental managers.
Summary quarterly reports are forwarded to senior management to assist in identifying trends and/or areas requiring improvement.
Corporate staff retest previous audit results referenced by quality assurance to ensure objectivity and to verify that corrective actions are being maintained in the department.
Standard & Poor's review of previous audit reports reflected no substantial discrepancies, and noted that any findings received a response in a timely manner. Overall, Bank of America Mortgage has a stringent audit process that provides extensive oversight over loan administration functions.
Loan Administration
The ranking for Loan Administration is raised to STRONG from ABOVE AVERAGE.
Gary Bettin, National Servicing Director, oversees the three loan servicing platforms. As of June 30, 2000, Bank of America Mortgage serviced an approximate $281 billion portfolio, representing over 2.5 million loans. The company has a geographically diverse portfolio, thus reducing risk of loss due to regional economic downturns. The top five states, ranked by number of loans serviced, are California (17%), Texas (7%), Florida (7%), Virginia (4%) and Illinois (4%). Bank of America Mortgage's cost-to-service per loan of $45.50 and loans-serviced-per-servicing employee statistic of 1,650 are significantly better than the Mortgage Bankers Association of America (MBA) industry averages of $86.00 and 1,150, respectively, for a comparably sized servicer. This can be attributed to the company's cost efficiencies achieved through the consolidation of the Cypress platform and its effective use of technology.
Standard & Poor's reviewed all areas of loan servicing, including new loan set-up, escrow analysis, partial releases, adjustable-rate loan analysis, payoff tracking, balloon mortgages, assumptions and modifications. Overall, these areas were found to be satisfactory. Key areas of risk will be discussed below in more detail.
Cash Management and Investor Accounting
Bank of America Mortgage exhibits effective controls in its payment processing area. The company operates a total of five lockbox locations, which have been consolidated to one vendor, an improvement over the previous practice of maintaining multiple relationships with third-party providers. Currently, there is a 24-hour delay in applying branch payments, necessitating input of a system code that prevents assessment of late charges when applicable. Management, however, expects to establish an automated interface between the branch and servicing system within the next 90 days, which will further improve efficiencies in the department. Identified controls include:
Commendable combined lockbox capture and ACH capture rates of 88%, thus reducing the possibility of input errors resulting from manually posting heavy payment volume;
A solid lockbox reject rate of approximately 3%;
The retention of unprocessed checks in a fireproof safe and periodic desk checks to ensure timely processing of funds; and
Dedicated separate personnel to address extraneous payment issues, such as misapplied or missing payments, resulting in less than 1% of payments being held over one day.
The company recently introduced e-bill presentment and payment applications to certain borrowers, and plans to offer this option to all its customers over the next year. If a check requires further research, personnel forward the item to the respective department for review. Although there is appropriate oversight over the process, including dual review upon receipt of the checks, Standard & Poor's strongly prefers that the department send only copies of the item to reduce the risk of lost or misappropriated funds.
Bank of America Mortgage's well-organized investor reporting department displays an appropriate segregation of duties and controls that ensure timely reporting, remitting, and reconciliation processes. The policy and procedure attributes in place comprise:
The company's ranking as a Tier One performer by FHLMC;
A FNMA assignment of either a 'good' or 'excellent' peak performance scorecard rating;
An agency and private investor group, and further assignment according to investor, to foster expertise. The department, however, crosstrains personnel to handle other clients;
The completion of the vast majority of reports in electronic format. No information is manipulated manually, reducing possible errors resulting from human input of data;
The maintenance of on-line access to the custodial bank statements, which allows for timelier balancing of accounts;
Managerial review and approval of all reports, reconciliations, and remittances; and
No late reporting or remittance penalties in the last 12 months.
Overall, the company exhibits sound oversight over its payment processing and investor accounting area, which properly safeguards investor interests.
Customer Relations
Bank of America Mortgage provides an adept level of customer service to its borrower base using different technologies to enhance and to monitor the process. Key areas of merit include:
A laudable VRU capture rate of almost 47%;
A VRU with Spanish language capabilities, with a recent enhancement feature that automatically transfers the call to a Spanish-speaking representative if necessary;
An acceptable abandonment rate averaging 4.5%;
Broad oversight of customer service employees through telephone monitoring and recording, as well as quarterly testing, designed to identify performance and training issues;
Differentiated service via a separate telephone number for branch personnel seeking to immediately address inquiries from customers;
An executive group that handles escalated calls; and
A customer service support group to assist during times of high call volume;
Several technology projects are scheduled for completion early in 2001, which will further increase the company's service levels, such as introduction of a customer service website for borrower information, borrower surveys, and an automatic call-back feature for the VRU. Standard & Poor's believes the company has a well-controlled customer service department.
Escrow Administration
The company's well-managed escrow department benefits from its capable oversight over its third-party providers that demonstrate competency in tax and insurance processing. Management successfully consolidated its four insurance vendors, and now uses just two companies, resulting in cost savings and more valuable use of existing resources. The following mechanisms are in place:
Complete outsourcing of tax and insurance functions, with quarterly meetings to review expectations and to leverage the existing relationship to improve performance.
Tax penalties average $0.10 per loan, which is an excellent rate for a company of this size.
Force placed insurance policy statistics are very low, at only 1% of the portfolio.
The vendor reviews insurance carrier ratings to ensure claim-paying ability in case of a loss on the property.
The department initiates a proactive series of calls and letters beginning approximately two weeks before policy expiration to ascertain the status of the current year's invoice.
Default Management
Bank of America Mortgage's practical collection efforts allow the company to maintain very good delinquency levels. Approximately 13% of the portfolio consists of higher delinquency FHA/VA accounts. The department's experienced staff works extended day and evening hours to fully accommodate its geographically diverse borrower base. Management adheres to all applicable investor requirements when initiating mortgagor contact, and makes fine use of its technology to accentuate delinquency administration. Key characteristics of the operation include:
Maintenance of an excellent delinquency rate of 2.86%, which is much better than the MBA average of 3.72%;
An autodialer system to provide flexibility, to customize calling campaigns and to ascertain collector productivity;
A FHLMC Tier 1 rating for default processing;
Capabilities for immediate borrower remittance of payments via Western Union Quick Collect®, Easy Pay, and proprietary in-house developed software;
DAISY software, offered by First American Financial Corp., which allows management to generate numerous default reports for tracking and compliance purposes;
Management of skip tracing and other ancillary tasks by different personnel, which enables collectors to concentrate solely on resolving past due accounts; and
FHLMC's EarlyIndicator and FNMA's Risk Profiler scoring programs to identify and to focus on those loans posing a higher risk of default.
Managers perform both telephone monitoring and file reviews of collection staff, although the company's different sites have their own guidelines for these functions. Standard & Poor's recommends that the company adopt a unified approach to this process, which would include frequent monitoring of its employees at least several times a month to ensure compliance with departmental policy and FDCPA guidelines. Collectors may earn additional compensation based on established team and individual goals for the month. Although Standard & Poor's prefers that companies use non-monetary incentives, the plan is not excessive. Overall, Standard & Poor's believes Bank of America Mortgage has solid collection practices.
Loss mitigation personnel adhere to applicable investor and company specifications when commencing workout initiatives. Depending on the loan type, loss mitigation solicitations generally begin by the 50th day of delinquency. Such efforts continue while the loan is in foreclosure. This is a practical way of minimizing future losses by maintaining communication with the borrower, whose possible change in financial status may warrant reconsideration of a workout option. FNMA maintains on-site representatives at each servicing location, who assist with questions and approvals. Collectors and loss mitigation employees have certain authority to approve limited-term payment plans, although the workout department handles delinquencies of greater than three months duration. Most loss mitigation plans, however, must be presented for management review to ensure that the plan represents the greatest degree of success when curing the default. Workout rates average an efficient 46% across all sites.
Bank of America Mortgage's judicious foreclosure and bankruptcy procedures allow for timely processing of legal actions, thus minimizing future losses arising from possible REO properties. Controls in effect include:
Using FNMA and FHLMC scoring modules, management may delay foreclosure proceedings so collection and loss mitigation personnel can continue to try and resolve accounts before incurring additional legal expenses that can hinder a cure;
A formal review process before the account can be referred for legal action;
The use of DAISY, in tandem with servicing system provided data, to generate assorted customized tracking reports to ascertain vendor performance within agreed-upon timeframes;
The use of the LenStar software program by the Richmond facility for expedient referral and communication with legal counsel. LenStar also allows for electronic filing of proof-of-claim with attorneys;
The use of the Hogan system for automatic upload of bankruptcy data for updated filings and release information, which assists in filing claims with the court;
Management selection of counsel through an on-line approved list of attorneys; and
Management generation of timeline reports on its attorneys, providing both verbal and written feedback, as the company is not yet providing report cards detailing vendor performance.
The company has not yet implemented a common foreclosure referral system because management may purchase Alltel's MaxMilion default system in the near future. MaxMilion will provide the company with several of the same features as LenStar, and enhanced vendor performance mechanisms. Overall, Bank of America has a capable foreclosure and bankruptcy function that helps expedite needed legal actions.
The Louisville servicing site oversees the disposition and marketing of REO properties. Management exhibits good supervision over the process, which includes:
Obtaining two independent valuations on the property upon vacancy;
Listing agreements of no more than three months through approved brokers;
The approval and review of list price recommendations by senior management;
Submission by brokers of monthly status reports on each property, detailing such items as open houses, and total showings;
On-line availability of the approved broker list available to facilitate Realtor management;
A company website for REO properties, commenced September 1999, which serves as an additional marketing tool;
Marketing time averaging 150 days, which is a satisfactory rate; and
Net sales to market value averaging approximately 91%, which is a good figure for the industry.
Financial Position
The ranking of STRONG is assigned for Financial Position.
Bank of America Mortgage's credit strength is based on the 'A+' long-term credit rating of the holding company, Bank of America Corp.
The ratings of Bank of America Corp. are based on its premier banking franchise that extends coast to coast, complemented by mortgage banking and capital markets businesses that operate in the national markets.
Bank of America is the most geographically dispersed banking organization in the U.S., with a highly diversified revenue stream. Ratings are tempered, however, by the volatility of its capital markets activities, moderately high exposures to emerging markets, and continuing integration risks.
Bank of America Corp. was formed in September 1998 through the mergers of the formers NationsBank Corp. and BankAmerica Corp. The combined organization has a territory that extends from the Southeastern Atlantic seaboard to the Pacific Coast and an unrivaled customer base consisting of 30 million households and 2 million businesses.
With a national loan book, Bank of America has few industry or geographic concentrations so that domestic asset quality can be expected to mirror the broad U.S. economy. The company has a sizable exposure to emerging Asian and Latin American markets where problem credits have surfaced. The corporation is selectively paring down its overseas exposure to where it should not seriously impair overall asset quality.
Coming out of the gates in third-quarter 1998, profitability was depressed due to credit and trading losses resulting from the unprecedented disruptions in the global capital markets at that time, as well as a slowdown in the investment banking business. In addition, the company took a large write-down on its investment in D.E. Shaw & Co., a trading firm. Since the beginning of 1999, earnings have rebounded as the capital markets returned to a sense of normalcy. Profitability should benefit from the $2 billion of anticipated cost savings from the integration of the formers BankAmerica and NationsBank. But, given the size and complexity of merging these two organizations, anticipated synergistic benefits may not be immediately forthcoming. A more critical challenge will be growing core revenue in the face of a shrinking net interest margin and without an undue reliance on volatile trading profits and securitization gains.
The bank's equity capital, the largest of any U.S. bank, is considered to be adequate in view of the company's risk profile. The company is again repurchasing common shares in the open market, suggesting that it intends to manage capital more aggressively than in the recent past.
Over the near term, profitability will remain below its potential until the conversion process is completed. In addition, the bank needs to formulate a definitive strategy for incorporating the Internet as an alternative delivery channel for its retail customers. Longer term, financial performance will likely tend toward the industry mean, a reflection of the company's broad diversification in terms of customers, products, and geography.
Company Profile
Bank of America Mortgage has three servicing sites, located in Louisville, Ky., Richmond, Va., and Buffalo, N.Y.
Bank of America Mortgage
J. Mark Hanson, Senior Vice President, Mortgage Servicing Director
H. Randall Chestnut, Senior Vice President, Servicing Manager
475 Crosspoint Parkway
Buffalo, N.Y. 14068
716-635-2095
Web site address: www.bankamerica.com
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Published by Standard & Poor's, a Division of The McGraw-Hill Companies, Inc. Executive offices: 1221 Avenue of the Americas, New York, NY 10020. Editorial offices: 55 Water Street, New York, NY 10041. Subscriber services: (1) 212-438-7280. Copyright 2001 by The McGraw-Hill Companies, Inc. Reproduction in whole or in part prohibited except by permission. All rights reserved. Information has been obtained by Standard & Poor's from sources believed to be reliable. However, because of the possibility of human or mechanical error by our sources, Standard & Poor's or others, Standard & Poor's does not guarantee the accuracy, adequacy, or completeness of any information and is not responsible for any errors or omissions or the result obtained from the use of such information. Ratings are statements of opinion, not statements of fact or recommendations to buy, hold, or sell any securities.