Not all predatory practices occur during loan origination: several subprime servicers have entered settlement agreements with regulators for predatory servicing practices, including:

• Failure to post on-time borrower payments
• Charging excessive and unwarranted fees
• Prematurely referring accounts to collections
• Forcing homeowners into default to generate fee income

Two of the biggest subprime servicers, Fairbanks Capital and Ocwen were the subject of regulatory actions, as well as significant private litigation relating to predatory servicing practices. Settlement actions were pursued by the FTC, HUD and the Office of Thrift Supervision.

In 2002, Fairbanks Capital was the number three subprime servicer in the United States and Ocwen number four. Together they serviced 12 percent of the subprime market that year.

Source: Center for Responsible Lending