ATTACHMENT E - QASP MATRIX.xlsx
XLSX spreadsheet 23 KB Posted
- Attached to
- VA Loan Servicing
- Solicitation number
- 36C10X27R0002
About this file
This file is a Quality Assurance Surveillance Plan (QASP) Matrix for VA Loan Servicing that establishes measurable performance standards and audit procedures for a loan servicing contractor. The matrix details performance requirements across eight primary service categories: Boarding (7-day requirement for processing tVAP, Vendee, NADL, Partial Claims, and Repurchased loans), Non-Default Servicing (payment collection, partial payment acceptance, borrower communication documentation, loan status systems, tax services within 30 days, escrow management, and hazard/flood insurance administration), Default Servicing (collections pursuit, loan modifications, low-balance/matured loan servicing, forbearance consideration for disabled veterans, NADL default notification, attorney referrals, foreclosure management, bankruptcy handling, and coordination with VA Regional Counsel), Foreclosure (adherence to VA timeframes, attorney referral completion, judicial foreclosure referral to NPG or DOJ, event timeline tracking, liquidation expense payment, appraisal ordering and review, net value computation and bidding, and property inspection documentation), Loan Termination (foreclosure sale notification within 5 days, conveyance data upload, veteran entitlement notification, expense disbursement, title package delivery, and defect correction), Loan Sale Assistance (optional task involving pool data provision and file coordination), Loan Accounting (financial reporting by cohort/fund, Credit Reform Act compliance, cash reconciliation, IRS reporting, and suspense account management), and Invoicing Process (expense advancement, electronic invoice submission, documentation support, and monthly fee calculation based on loan performance status).
The QASP Matrix specifies audit methodologies including Desk Review, Invoice review, and On-Site Visit procedures, with most requirements subject to monthly frequency audits using random sampling or 100% review depending on loan volume and risk level. Data sources include Loan Set-Up Sheets, Monthly Vendee Fund-Cohort Reports, Daily Cash Transactions, VA National Collection Reporting, Insurance Loss Pending Reports, Summary/Detail Loan Status Reports, VA Foreclosure Monthly Reports, Reimbursables documentation, and contractor self-certifications for certain compliance areas. The matrix indicates specific measurable performance indicators and defines the universe of loans subject to each requirement, with selection sizes ranging from 100% review for limited-volume activities to random sampling for high-volume operations. This QASP establishes the foundation for monitoring contractor compliance with VA loan servicing standards throughout contract performance.
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Other files
| File | Type | Posted |
|---|---|---|
| ATTACHMENT A - PAST PERFORMANCE REFERENCES.pdf | ||
| ATTACHMENT D - PRICING PROPOSAL SPREADSHEET.xlsx | XLSX spreadsheet | |
| 36C10X27R0002 DRAFT SOLICITATION.docx | DOCX document | |
| ATTACHMENT B - PAST PERFORMANCE QUESTIONNAIRE.docx | DOCX document | |
| ATTACHMENT C - LIMITATION ON SUBCONTACTING - CERTIFICATE OF COMPLIANCE FOR SERVICES.docx | DOCX document |
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QASP MATRIX
| VA Loan Servicing QASP Matrix | ||||||||||||
| Section | Title | Sub-Section | Contract Text | Yes /No Measurable | Audit Type | Yes/No Incentives | Selection Universe | Data Source for Selection | Selection Size | On Site Visit (O), Invoice (I) or Desk Review (D) | Frequency | |
| 5.5.3 | Boarding | The Contractor must board all tVAP, Vendee, NADL, Partial Claims, and Repurchased loans within seven calendar days after receiving loan information from VA. The loan information includes the following fields: Vendee loan number, VA identification number, buyer's name, loan amount, down payment amount, interest rate, loan term, monthly principal and interest (P&I), monthly taxes and insurance (T&I), initial escrow deposit, interest amount collected at closing, Vendee cohort year, Vendee fund, closing date, date processed in VA system and date sent to the Contractor. | Yes | Loan Boarding/Desk | No | All newly boarded Refunded, Repurchased, Vendee, NADL loans during review month | Loan Set-up Sheets/Monthly Vendee Fund-Cohort Report | 100% review due to limited number of loans boarded monthly. Population average 10 per month | D | Monthly | ||
| 5.5.4 | Non-Default Servicing | The Contractor must: | ||||||||||
| 1 | Collect and properly apply all payments | Yes | Desk Review | No | All Batched) Payments | Daily Cash Transactions/VA National Collection Reporting Active Loans | Random Sample. | D | Monthly | |||
| 2 | Accept partial payments in accordance with 38 CFR 36.4316 | Yes | Finance/ALAC/Desk Review | No | All Batched Payments | Daily Cash Transactions/VA National Collection Reporting Active Loans | Random Sample. | D | Monthly | |||
| 3 | Document all actions and communications with borrowers in a searchable, electronic record format | Yes | Desk Review | No | All actions and communications with borrowers during review period | Vendor - VA Quarterly Correspondence Report | Random Sample. | D | Monthly | |||
| 4 | Provide systems that enable borrowers to check loan status | Yes | Desk Review | No | On Line System | Lender Could Self-Certify they have the systems for borrowers to check their loans | N/A. Lender would show how their systems work to Vendor Loan Servicing | D | Annually | |||
| 5 | Perform a full tax service and a complete tax search within 30 calendar days of assignment to ensure that | |||||||||||
| a | Property taxes are paid to date and that no penalties or interest accrue or duplicate payments are made. | Yes | Invoice | No | All taxes paid by vendor in the invoice month | Invoice | Random Sample. | I | Monthly | |||
| b | All available discounts are utilized | Yes | Invoice | No | All taxes with available discounts in the invoice month | Invoice | Random Sample. | I | Monthly | |||
| 6 | Advance any escrow shortage to pay for taxes when necessary and seek reimbursement from the borrower | Yes | Invoice | No | All cases with advances for escrow shortages during review period | Invoice | Random Sample. | I | Monthly | |||
| 7 | The Contractor must pay all hazard and flood insurance, except for servicing partial claims, to include: | |||||||||||
| a | Providing transferable “life of loan” flood service contracts. These contracts must be obtained on all new tVAP, repurchased, and direct loans within 45 calendar days of assignment. This includes NADLs, and loans repurchased under VAR 4600 and, if appropriate, from American Housing Trust (AHT) or Vendee Mortgage Trust (VMT). In the event the Contractor requires additional information from VA in order to obtain the flood service contract, the number of days taken by the VA office to provide the required information must be added to the Contractor's total time allowed for that loan. | Yes | Loan Boarding/Desk | No | All new loans with flood determination shown on Loan Set-Up Sheets | Loan Set-Up Sheets/Vendee Fund-Cohort Monthly Report | 100% review | D | Monthly | |||
| b | Maintaining flood status of the portfolio loans in accordance with National Flood Insurance Reform Act of 1994, Pub. L. 103-325, 108 Stat. 2255 (codified as amended in scattered section sof 12 and 42 U.S.C.) | No | Desk Review | No | N/A | Self Certification by Lender they are following the National Flood Act | NA | D | Annually | |||
| c | Monitoring and reporting disbursement of loss settlements | Yes | Insurance/Desk | No | All Pending Insurance Loss Settlements in report month. | Insurance Loss Pending Report | Random Sample. | D | Monthly | |||
| d | Ensuring timely payment of premiums to avoid lapse of coverage and non-covered losses | Yes | Desk Review | No | All loans where insurance was paid during the review period | Ad Hoc Reports from Servicer's records for onsite | Random Sample | D | Annually | |||
| e | Obtaining force-placed insurance when necessary to avoid lapses in coverage | Yes | Desk Review | No | All loans where force-placed insurance was necessary during the review period | Ad Hoc Reports from Servicer's records for onsite | Random Sample | D | Annually | |||
| f | Advancing any escrow shortage to pay for insurance premiums when necessary and seeking reimbursement from the borrower | Yes | Desk Review | No | All loans where funds were advanced to pay for insurance premiums | Ad Hoc Reports from Servicer's records for onsite | Random Sample | D | Annually | |||
| 8 | Provide document custodian services in accordance with industry's best practices | No | Desk Review | No | NA | Self Certification by Lender stating they provide document custodian services | NA | D | Annually | |||
| 5.5.5 | Default Servicing | The Contractor must: | ||||||||||
| 1 | Actively pursue and document all collections, loss mitigation, and related servicing efforts through termination (or redemption) of the loan | Yes | Desk Review | No | All delinquent loans 3 months and older | Summary/Detail Loan Status Report | Random Sample. | D | Monthly | |||
| 2 **** | Make recommendations to modify delinquent loans in the portfolio pursuant to VA standards as provided in the attachments | Yes | Desk Review | No | All Loan recommendation submitted by servicer | Ad Hoc Reports from servicer's records (Need a modification report) | 100% review with sample size TBD | D | Monthly | |||
| 3 ***** | Service low balance or matured loans pursuant to VA standards as provided in the attachments | Yes | Desk Review | No | All loans with either low UP Balance or has matured | Low Balance/Matured Loan Report | 100% review with sample size TBD | D | Monthly | |||
| 4 | Provide additional forbearance consideration to disabled Veterans with refunded loans, Native American Direct Loans (NADL), and Specially Adapted Housing (SAH) loans | NA | Case by Case | No | Case by Case | NADL Report | Case by Case | D | Ad hoc | |||
| 5 | Notify VA in the event of default on every NADL loan. VA coordinates all loss mitigation, foreclosure, etc., activities for NADL loans | NA | Case by Case | NA | All NADL loans in default during review period | NADL report | Case by Case | D | Ad hoc | |||
| 6 | Refer the loan to the Contractor's fee attorney upon recognition of insolubility | Yes | Desk Review | No | All loans referred for foreclosure during review period | VA Foremonthly Report | 100% review | D | Monthly | |||
| 7 | Initiate and manage termination of non-judicial and judicial foreclosures processed by Contractor's fee attorney, VA Regional Counsel or Department of Justice (DOJ) (e.g. NADLs) | Yes | Desk Review | No | All loans referred for foreclosure during review period | VA Fore Monthly Report | 100% review | D | Monthly | |||
| 8 | File "Proof of Claim" upon notice of bankruptcy and monitor bankruptcy progress, track and reconcile trustee payments, and report bankruptcy event timeline progress on all bankruptcies, as appropriate. Requests for dismissal of Chapter 13 bankruptcies shall be made with prejudice in cases of multiple filings. Fullly document all actions taken | Yes | Desk Review | No | All new and current active bankruptcy cases | Summary/Detail Loan Status Report | 100% review with sample size TBD | D | Monthly | |||
| 9 | Report to and coordinate with VA Regional Counsel or the DOJ in contested cases such as, but not limited to, foreclosure or bankruptcies for appropriate action (e.g., court appearance, file relief from stay, any appealed or contested cases where VA is listed as a defendant) | Yes | Desk Review | No | All contested cases | Summary/Detail Loan Status Report | 100% review with sample size TBD | D | Monthly | |||
| 10 | Brief COR, or Authorized Designee, on contested cases monthly | Yes | Desk/Management | No | All contested cases | Litigation Report | 100% review due to limited number of litigated cases. | D | Monthly | |||
| 11 | Pay mortgage interest mandated by bankruptcy trustee or court to VA with loan level supporting documentation | Yes | Invoice | No | All bankruptcy cases with trustee interest payment | Reimbursable Report | Random Sample | D | Monthly | |||
| 5.5.6 | Foreclosure | The Contractor must: | ||||||||||
| 1 | Adhere to the time frames provided by VA guidelines. | NA | Desk Review | No | NA | Lender Could Self-Certify they adhere to Fannie Mae foreclosure timeframes | NA | D | Annually | |||
| 2 | Complete referral and termination of non-judicial and judicial foreclosures to the appropriate Contractor’s fee attorney. When reviewing loans, VA will reimburse attorney fees in accordance with the VA guidelines. Additional fees require justification and prior VA approval. | Yes | Desk | No | All completed foreclosures during review period | VA Foreclosure Monthly Report | 100% review | D | Monthly | |||
| 3 | Complete referral of judicial foreclosures in certain jurisdictions to NPG or DOJ, as appropriate. | Yes | Desk | No | All foreclosure cases referred to VA NPG or DOJ | VA Foreclosure Monthly Report | 100% review. | D | Monthly | |||
| 4 | Track and report event timeline progress on judicial and non-judicial foreclosures, including cases handled by NPG and DOJ. | Yes | Desk | No | All cases referred for foreclosure during month | VA Foreclosure Monthly Report | 100% review. | D | Monthly | |||
| 5 | Complete payments of all liquidation expenses on all foreclosures handled by the Contractor and submit voucher for reimbursement on invoice after foreclosure is completed | Yes | Invoice | No | All completed foreclosure reimbursables for review period | Invoice | Random Sample | D | Monthly | |||
| 6 | Ensure liquidation appraisals are ordered from an appraiser on the VA fee panel using WebLGY for all loans, including loans with Installment contracts, in time to determine proper net value and bid amount for the foreclosure sale | Yes | Desk/Foreclosure | No | All appraisals ordered on loans in foreclosure during review period | VA Foreclosure Monthly Report | 100% review | D | Monthly | |||
| 7 | Ensure all liquidation appraisals are reviewed by individuals approved by VA under the general guidelines established for Staff Appraisal Reviewers (SAR) in VA Pamphlet 26-7, Lenders' Handbook, Chapter 15 | No | Desk Review | No | All completed appraisals during review period | Lender Could Self-Certify that all appraisals are reviewed by SAR as well as provide list of SARS. | NA | D | Annually | |||
| 8 | Compute the net value of the property and enter a bid at the foreclosure sale on behalf of the Secretary in the amount of the net value of the property or the total indebtedness outstanding on the loan, whichever amount is less. In those jurisdictions where state or local laws dictate other bid requirements (e.g., a minimum bid, a certain percentage of the liguidation or other appraisal amount), the Contractor shall enter an appropriate bid that will protect VA's interest while complying with state or local requirements | Yes | Desk/Report | No | All loans foreclosed during review period | VA Foreclosure Monthly Report | 100% review | D | Monthly | |||
| 9 | For this purpose, net value is defined as the "as-is" value of the security property as determined by a VA liquidation appraisal, minus an amount representing the costs that the Secretary estimates would be incurred by VA in acquiring and disposing of the property | Yes | Desk/Report | No | All loans foreclosed during review period | VA Foreclosure Monthly Report | 100% review | D | Monthly | |||
| 10 | Conduct and fully document property inspections and preservation actions taken to protect the VA's interest up to loan termination | Yes | Invoice | No | All loans with property inspections and preservation expenses occurred during review period | Reimbursables | Random Sample | I | Monthly | |||
| 5.5.7 | Loan Termination | After portfolio loan foreclosure/termination, the Contractor must: | ||||||||||
| 1 | Advise the VA of the results of each sale within five calendar days of each completed foreclosure sale, expiration of a ratification period, or other final loan termination action required by local or state jurisdiction. The Contractor must reimburse VA for any expenses related to erroneous notices of conveyance. | Yes | Desk | No | All completed foreclosure that occurred during the review period | VA Foreclosure Monthly Report | 100% review | D | Monthly | |||
| 2 | Upload conveyance data to VA within five calendar days of final termination. The conveyance period is subject to the official terminating event in the state for which the property is located be it foreclosure, ratification or confirmation. REO expenses shall not begin until after conveyance. | Yes | Desk | No | All completed foreclosure cases during review period | Vendor Report | 100% review | D | Monthly | |||
| 3 | Notify the COR, or Authorized Designee, and VA's eligibility center of loan terminations and loss amounts on loans involving Veterans' entitlement benefits/eligibility on a monthly basis | Yes | Foreclosure Report/Desk | No | All completed foreclosure cases during review period | VA Foreclosure Monthly Report | NA | D | Monthly | |||
| 4 | Disburse, properly apply, document and report all foreclosure expenses and sale proceeds | Yes | Invoice | No | All completed foreclosure cases during review period | Invoice (Reimbursables) | Random Sample | I | Monthly | |||
| 5 | Provide VA with a complete title package (as determined by 38 CFR 36.4323 and each local VA NPG) within the established VA timelines after the foreclosure sale date, redemption date, or other determinant that finalizes loan termination unless otherwise directed by VA | Yes | Desk | No | All loans with title packages sent to VA NPG | Vendor Report | 100% Review | D | Monthly | |||
| 6 | Correct any defects in title that are the result of failure to properly terminate the loan. (This does not apply if the foreclosure was completed by NPG or the DOJ.) | Yes | Desk | No | All loans with title defects | Vendor Report | 100% Review | D | Monthly | |||
| 7 | For servicing of partial claims ONLY, the Contractor must complete a close out for each partial claim either paid off or eliminated through a cash out refinance. Note: this bullet is only applicable to servicing of partial claims, and no other part of this PWS. | No | ||||||||||
| 5.5.8 | Loan Sale Assistance (Optional Task) | The Contractor at a minimum shall: | ||||||||||
| 1 | Provide all data, information, and loan files required to successfully process and complete VA trust sales in accordance with VA instructions and prior to th eend of the month of the loan sale. This information includes, but is not limited to, loan-level reporting and proposed pool-level reporting | Unknown | ||||||||||
| 2 | Provide loan assignment and shipping of files to VMT document custodian in accordance with the Pooling and Servicing Agreement (PSA) | Unknown | ||||||||||
| 3 | Abide by the published processing schedule prior to each deal | Unknown | ||||||||||
| 4 | Abide by the established VA eligibility criteria | Unknown | ||||||||||
| 5 | Coordinate with the underwriting syndicate to ensure all documentation, including disclosures, opinion, and data is accurate | Unknown | ||||||||||
| 6 | Report on and provide static pool analysis on the existing portfolio | Unknown | ||||||||||
| 5.5.9 | Loan Accounting | The Contractor must provide all loans accounting information in a timely and accurate manner as prescribed by the VA and must: | ||||||||||
| 1 | For Loan Sales | |||||||||||
| a | Segregate loans by cohort years and funds symbol | Unknown | ||||||||||
| b | Provide financial records in a format that fully complies with the Credit Reform Act. Loan modifications must be recorded in property fund/cohort year with interfund reimbursements as required. Provide financial records and reports that facilitate billings, reports and audits | Unknown | ||||||||||
| c | Provide timely reports to VA for reconciling cash and for accounting purposes, e.g., aging Treasury Report on Receivables (TROR) (delinquency), application of cash to principal and interest, cash suspense, and loan sale reports. Reporting shall be consistent with data transmitted to VA | Unknown | ||||||||||
| 2 | Provide, for all loans in foreclosure, all information required by VA to determine its liabilities and contingent liabilities | Unknown | Finance | |||||||||
| 3 | Comply with all VA information requirements for Internal Revenue Service (IRS) reporting (e.g., 1098, 1099) | Unknown | Desk | No | NA | Lender should Self-Certify all requirements for IRS is being followed | NA | D | Annually | |||
| 4 | Reconcile cash received and apply to portfolio as interest and/or principal with changes in portfolio status | Yes | Desk/Finance | No | All Batched Payments | Daily Cash Transactions/VA National Collection Reporting Active Loans | Random Sample. | D | Annually | |||
| 5 | Generate detailed electronic entries in VA's accounting and/or subsidiary systems to record activity in a manner prescribed by VA. These entries shall include, but are not limited to, loan interest and late charge collections as well as accurate, loan establishments, and foreclosures. | Unknown | Desk/Finance/ALAC | D | ||||||||
| 6 | Maintain suspense accounts as required and take active clearance action | Yes | Desk/Finance | No | All active suspense accounts during review period | Suspense Report | Random Sample | D | Monthly | |||
| 7 | On a daily basis, identify monies collected on behalf of VA and deposit such monies into the corporate account, and wire the equivalent amount of the daily receipts to the U. S. Treasury. The Contractor must comply with all Federal requirements for depositing cash (e.g., 31 U.S.C. § 3302(b) (cash deposits) and 1 TFM 6-8030). Escrow monies must not be wired to the Treasury but maintained in a separate Contractor bank account and not comingled with escrow monies from other client accounts. Unapplied monies at the loan level shall not be remitted to the VA until the funds are applied to collection with obligation to VA. Remittances made for non-sufficient funds shall be reimbursed back to the servicer as a reversal of collection. NSF fees to the borrower are deducted from future remittance to the VA. VA will refund any monies within 7 days to the Servicer that were incorrectly applied and not an obligation to VA. VA will have the capability of receiving float income related to funds that are collected and held until remitted to VA. | Yes | Desk/Finance | No | All batched payments | Daily Cash Transactions/VA National Collection Reporting Active Loans and Lender should certify they are incompliance with all Federal regulations for depositing cash. | Random Sample | D | Annually | |||
| 5.6 | Invoicing Process | The Government is seeking a streamlined, electronic process that allows ease of use and minimal administration for the COR/Authorized Designee to receive and approve invoices. The Contractor must: | ||||||||||
| 1 | Advance payments for taxes (including penalty and interest) and other reimbursable expenses. | Yes | Desk Review | No | All reimbursable expenses during review period | Invoice | 100% Review | D | As submitted | |||
| 2 | Submit all invoices for final disposition in a VA- approved electronic format | Yes | Desk Review | No | All reimbursable expenses during review period | Invoice | 100% Review | D | As submitted | |||
| 3 | Ensure that all invoices are substantiated by complete imaged or electronic documentation in support of allowable expenses and fees, including that which are performed by Contractor or Subcontractors for services that are not included in the flat-fee structure Section B of this solicitation. Documentation must be made available as invoices are received by the Contractor from Subcontractors. | Yes | Desk Review | No | All reimbursable expenses during review period | Invoice | 100% Review | D | As submitted | |||
| 4 | For Portfolio Loans: | |||||||||||
| a | File reimbursement invoices for appropriate expenses. If other expenses are discovered that could result in a lien against a property, the Contractor shall immediately notify VA | Yes | Invoice | No | All reimbursable expenses during review period | Reimbursables | Random Sample | I | Monthly | |||
| b | Servicing fees will be earned for each month a loan is serviced by the Contractor. | Yes | Invoice | No | All reimbursable expenses during review period | Reimbursables | Random Sample | I | Monthly | |||
| c | Servicing fees will be calculated and will accrue on a monthly basis for each loan | Yes | Invoice | No | All reimbursable expenses during review period | Reimbursables | Random Sample | I | Monthly | |||
| d | The Contractor must invoice VA for servicing fees as calculated in 4.c above in a month in which a full payment of the Principal, Interest, Taxes and Insurance (PITI) is received or upon loan termination | Yes | Invoice | No | All loans with payment applied during review period | Invoice | Random Sample | I | Monthly | |||
| e | Not invoice VA for fees, costs, or advances that may be repaid by the borrowers until after loan termination. | Yes | Invoice | No | All expenses incurred during reporting month | Invoice | Random Sample | I | Monthly | |||
| f | Invoice VA monthly for unreimbursed expenses on terminated or foreclosed loans; and | Yes | Invoice | No | All expenses incurred during reporting month | Invoice | Random Sample | I | Monthly | |||
| g | Submit invoices for all expenses or services submitted monthly, with all required cost data accounting symbols, fund, cohort year, and VA loan identification number | Yes | Invoice | No | All expenses incurred during reporting month | Invoice | Random Sample | I | Monthly | |||
| h | Upon conclusion of the contract, the Contractor will be paid a final payment for all unbilled months serviced, based upon the delinquency category of Performing or Non-performing as of the last calendar day of the month serviced as defined in 4.c., and regardless of whether a payment was received for that account. | No | ||||||||||
| i | The definitions of performing and non-performing are applicable to all loans serviced under this contract. All work associated with servicing partial claims should be invoiced monthly. Servicing activities are billed within 5-10 days of the next consecutive month based on the partial claim activity of boarding, monthly servicing, de-board, closeout, as well as the monthly right-to use license of partial claims web service. For one-time invoicing, the Contractor must invoice the government as soon as those services are rendered to the government. | Yes | Invoice | No | All expenses incurred during reporting month | Invoice | Random Sample | I | Monthly |
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