Mortgage servicers are plagued by their nebulous relationships with the borrowers who discharge their personal liability in bankruptcy. Issues arise when the borrower whose debt has been discharged continues to engage with the mortgage servicer. These activities include making monthly payments and requesting and participating in loss mitigation. There are few, if any, bright line rules regarding this common scenario. Instead, courts generally employ an “I know it when I see it” approach to evaluate whether such activity violates the discharge injunction and/or the Fair Debt Collection Practices Act.
The following is a link to four posts by attorneys at Bradley Arant Boult Cummings, LLP.
Part 1. Mortgage servicers are plagued by their nebulous relationships with the borrowers who discharge their personal liability in bankruptcy. Issues arise when the borrower whose debt has been discharged continues to engage with the mortgage servicer. These activities include making monthly payments and requesting and participating in loss mitigation. There are few, if any, bright line rules regarding this common scenario. Instead, courts generally employ an “I know it when I see it” approach to evaluate whether such activity violates the discharge injunction and/or the Fair Debt Collection Practices Act.
Part II. The only way to fully eliminate the risk of violating the bankruptcy discharge injunction is to cease all communications to borrowers who received a discharge of the debt. However, this drastic change in practice is not realistic. First, the discharge only eliminates the borrower’s personal liability – the servicer’s lien, and its right to foreclose on the collateral, still exists. A discharge of this personal liability does not preclude servicers from communicating information to the borrower that may be relevant to possible foreclosure or how to avoid foreclosure, and does not absolve the servicer of any existing requirement to send such notices.
Part III. This part will discuss modifying a borrower’s loan after a discharge. Discharge of personal liability does not preclude the borrower from making payments voluntarily. Neither does that discharge preclude the delinquent borrower from seeking a loan modification. Some practitioners insist that post-discharge loans cannot be modified because there is no note, only a security instrument, and therefore there is no loan to modify. This relationship can be more accurately described as one where the borrower must pay to remain in the house, and where the note has become non-recourse as to the borrower. The enforceability of that relationship is now anchored only in the property itself. The Department of the Treasury, through its directive regarding HAMP modifications, has explicitly said that this relationship can be modified. Fannie Mae and Freddie Mac have, in turn, suggested language to be used in agreements with these borrowers. All three of those entities have encouraged a servicer that modifies a loan after the borrower has discharged his personal liability to use a disclaimer that all payments are voluntary, and an acknowledgement that the servicer cannot seek to collect against the borrower personally.