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February

6
2026
Strategy

Moving Toward Data-Driven Debt Settlement

In the traditional collections waterfall, debt settlement is often viewed as a "passive" channel—a volume of accounts that resolves itself through third-party intervention with little direct oversight from the lender. Consequently, many institutions lack the granular benchmarking necessary to measure the true performance of their settlement workflows.

As delinquency rates rise and recovery budgets tighten, operational leads must transition from anecdotal success to a data-driven framework. Benchmarking the debt settlement lifecycle requires moving beyond simple "net recovery" figures and looking into the mechanics of the resolution funnel.

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February

6
2026
Industry News

Ninth Circuit Upholds Administrator’s Denial of Residential Mental Health Benefits Under ERISA

In an unpublished memorandum decision, the Ninth Circuit in R.R. v. California Physicians’ Service d/b/a Blue Shield of California, affirmed the insurer and administrator’s denial of benefits for a dependent’s residential mental health treatment under an ERISA‑governed plan. The court applied abuse‑of‑discretion review and concluded that the denial was supported by the plan’s medical‑necessity criteria and the administrative record. The dissent, however, argued that the majority failed to meaningfully account for a structural conflict of interest and for the administrator’s handling of treating‑provider evidence and prior failed lower levels of care.

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February

6
2026
Industry News

HUD Revised Foreclosure Bidding Process for FHA Loans

The U.S. Department of Housing and Urban Development (HUD) recently revised the requirements for bidding at a foreclosure sale and for utilizing Claims Without Conveyance of Title (CWCOT), including Post-Foreclosure Sales Efforts through the issuance of Mortgagee Letter 2026-03. The changes apply to all single-family forward mortgages under the Title II program, except for Hawaiian Home Lands Mortgages and Insured Mortgages on Indian Land. The changes may be implemented immediately, but must be implemented for foreclosure sales scheduled on or after April 29, 2026.

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February

5
2026
Industry News

Colorado Files Opposition to Plaintiffs’ Rehearing Petition in Opt-Out Litigation

As we reported previously, a petition for rehearing en banc was filed by the plaintiff bank trade associations in National Association of Industrial Bankers v. Weiser. In that case, the panel’s 2-1 decision held that a loan is “made” for purposes of the opt-out provision in Section 525 of DIDMCA in both the state where the bank is located and the borrower’s state, meaning that Colorado interest rate limits will apply to loans made to Colorado residents by out-of-state state-chartered depository institutions.

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February

5
2026
Industry News

FDIC Issues List of Banks Examined for CRA Compliance

The Federal Deposit Insurance Corporation (FDIC) today issued its list of state nonmember banks recently evaluated for compliance with the Community Reinvestment Act (CRA). The list covers evaluation ratings that the FDIC assigned to institutions in November 2025.

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