Countrywide FC to REO roll rate error. How do we fix this?!

In our February 8th, 2017 Commentary, we documented a reporting error apparently made by either the Bank of New York Mellon, the master servicer or the servicer/sub-servicer for the 530 deals involved in the BNY Countrywide RMBS Settlement. Immediately after the settlement payout, the foreclosure to REO transition rate had practically dropped to 0%. The excerpt from the spreadsheet below clearly shows the change starting in July 2016. Some thought it was a change in servicing practices but the recorded documents we discovered point to a data reporting error. Once we obtained the Certificate of Title from various county register of deeds, we knew the property had been sold to the trustee for the Certificateholders of the Trust, therefore transitioning from FC to REO. Unfortunately, the remittance report and the loan level data provided by the trustee shows the transition incorrectly going from FC to 90+ DQ.

The problem seems to be isolated to deals subject to sub-servicing, except for SLS. As we do not own any RMBS bonds, the trustee will not discuss this situation with us. If you own any of the 530 Countrywide bonds included in the settlement, please contact BNY Mellon (the contact information is located on the top left corner of each remittance). This error has now been occurring for 10 months and needs to be fixed.

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