Mr. Maurice Crowley:

I do not believe so. Any regulated entity would have a very clear set of service level agreements and expectations with the initial servicer. If that contract ends, either at the end of the specified period or during it if the servicer were not meeting the key performance indicators for service levels, there would be a relatively simple shift of responsibility from the first to the second servicer, although it would probably not be as simple as it sounds. I am assuming the second servicer is also a regulated entity, so the same approach and provisions would apply. As regulated entities, banks will outsource only in circumstances in which they are absolutely happy with the service provided and that the processes and procedures comply with the codes. If the bank has a problem with a servicer, it will shift to another servicer only if it is absolutely comfortable that the same compliance applies. Our members are very keen that the services be regulated because it gives them an extra lever over the servicer to which they have outsourced.