Mon Nov 10 16:17:58 EST 2025
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The Great Consolidation: How the MCS Sale to Stewart Signals a New Era of Institutional Control Over Mortgage Field Services

When MCS announced on November 7, 2025, that it would sell its mortgage services division—home to its property preservation and inspection operations—to Stewart Information Services Corporation (SISC), the news barely rippled across the national media. Yet within the insular world of mortgage field services, this was no ordinary transaction. It represented the culmination of a decade-long pattern in which institutional investors and title conglomerates absorbed nearly every major independent preservation firm. For Field Service Technicians and Inspectors, the deal signaled something far more ominous: the near-total disappearance of any remaining independent contracting ecosystem that once provided the backbone of the industry’s labor force.

For nearly forty years, MCS built its brand as a dominant service provider to mortgage servicers, offering everything from winterizations to occupancy inspections. Its sprawling network of subcontractors—tens of thousands of laborers who cut lawns, boarded windows, and documented blight—was the invisible infrastructure of foreclosure. Yet, as private equity and venture capital money poured into the housing supply chain, firms like MCS were quietly transformed from operational partners into tradable financial assets. The purchase of Mortgage Specialists Inc. (MSI) and Five Brothers Asset Management was not about service quality but market share. With those acquisitions, MCS effectively cornered multiple geographic markets, and the sale to Stewart only deepens the monopolistic tendency. Where once a dozen regional firms competed, there will now be one vertically integrated conglomerate controlling both title insurance and property preservation data under a single corporate roof. Sold off three times, once because of a default in nearly half a billion dollars in loans during COVID, it is fair to question whether or not MCS is safe to work for under its new management.

The irony, of course, lies in Stewart’s own history. For over a century, Stewart was synonymous with title insurance and closing services, not with boarded windows or property preservation lockboxes. By acquiring MCS’s mortgage services division, Stewart is not simply expanding its product line; it is extending institutional ownership into a space historically defined by blue-collar labor and small business enterprise. Field Service Technicians and Inspectors, who already contend with wafer-thin profit margins and burdensome compliance mandates, now face the prospect of operating under a corporate structure optimized for shareholder returns rather than equitable pay or fair working conditions. Inspectors, whose reports are used to justify the very work orders that technicians later complete, will likely see their rates subjected to the same downward pressure that private equity firms have long imposed on the preservation side.

The same dynamic was evident when Black Dome Financial acquired A2Z Field Services. This was a financial maneuver disguised as an operational pivot. A2Z had already been a legacy preservation vendor, and the Black Dome purchase was not about field innovation—it was about data aggregation and contract capture. Each successive merger removed one more layer of localized control, transferring power from regional operators who understood their communities to investment managers whose spreadsheets defined productivity solely by margin efficiency. For Labor, this consolidation represents an existential crisis. The institutionalization of mortgage field services has turned technicians and inspectors into interchangeable cost units, and the sale of MCS’s mortgage division to Stewart only institutionalizes that process under the guise of “strategic growth.”

MCS’s press release described the sale as a mutually beneficial partnership, suggesting that Stewart’s acquisition would “elevate mortgage service standards.” But for those in the field, these words ring hollow. The rhetoric of synergy and alignment has long served as camouflage for the gutting of independent labor networks. The same press materials that praise MCS’s “exceptional property preservation services” are silent on the fact that many of those services were executed by subcontractors earning below minimum wage equivalents once expenses were deducted. The executives touting “technology-driven solutions” neglect to mention that these platforms are designed primarily for vendor compliance tracking—not worker safety or wage transparency.

From a macroeconomic standpoint, the acquisition consolidates control of the nation’s foreclosure infrastructure into a handful of corporate hands. Stewart’s existing dominance in title insurance, combined with its new access to preservation and inspection data, creates a vertically integrated pipeline extending from origination to post-default disposition. For regulators, this raises antitrust red flags similar to those that surfaced during MCS’s prior acquisitions of MSI and Five Brothers. Yet the federal government has shown little appetite for intervening in what it perceives as a niche sector, even though these mergers directly impact the condition and disposition of federally insured properties. The irony is that while agencies like HUD and FHA outsource oversight to these very firms, they remain oblivious to how consolidation erodes quality control at the street level let alone prices paid to Labor.

The implications for Labor extend far beyond immediate pay rates. As these corporations merge, their data infrastructures merge as well, allowing them to centralize vendor performance metrics across multiple contract vehicles. This has created a labor surveillance apparatus of unprecedented scope. Field Service Technicians now operate under digital panopticons where missed geotags or out-of-focus photos can trigger scorecard downgrades and work order freezes. Inspectors face similar scrutiny, as their occupancy reports are algorithmically cross-checked against GPS data and time stamps. The promise of “efficiency” has become a euphemism for total behavioral control, reducing the workforce to mere nodes in a predictive analytics system designed to maximize corporate returns.

To those who remember the early years of mortgage field services, the transformation is staggering. The first generations of preservation contractors were family operations—mom-and-pop shops with pickup trucks and local crews who knew the neighborhoods they served. They were not perfect, but they were accountable to their communities. Today, those crews report to venture capitalists whose primary interest lies in quarterly yield. The sale of MCS’s mortgage division to Stewart completes this cycle of corporatization. It is the logical endpoint of decades of financialization in which every human activity—whether cutting a lawn or checking an occupancy—becomes an entry in a balance sheet.

The ethical implications are profound. When property preservation becomes a commodity controlled by financial institutions, the people performing that work are no longer seen as skilled tradesmen but as expendable logistics components. Their livelihoods hinge on opaque vendor portals and compliance dashboards. Each acquisition pushes them further from the decision-making processes that shape their work. The institutionalization of the industry thus mirrors the broader decline of labor autonomy in the American economy, where ownership and accountability are abstracted into boardrooms far removed from the homes being secured or inspected.

Whether this consolidation is sustainable remains to be seen. Stewart’s foray into mortgage services may deliver short-term profit through cross-sector synergies, but it will inherit the same structural weaknesses that have plagued every large preservation firm: chronic labor shortages, vendor attrition, and the impossible economics of low-bid contracting. No algorithm or acquisition can repair an industry whose foundation is built on the underpayment of its most essential workers. The question is not whether Stewart can integrate MCS’s systems but whether it can sustain an operational model that has already consumed its predecessors. For Labor, the answer is painfully familiar—when the capital shifts, the work remains the same, only the names on the paychecks change.

If the past decade of consolidation has proven anything, it is that institutional ownership does not elevate the mortgage field services industry; it extracts from it. Each acquisition—from Black Dome’s A2Z rebranding to Stewart’s takeover of MCS’s mortgage arm—reduces the space in which independent contractors can survive. The industry that once provided a path to self-employment for tens of thousands has been repackaged as a service-as-a-subsidiary model under the control of investment capital. For Field Service Technicians and Inspectors, the message is clear: the fight for fair pay, recognition, and autonomy will no longer be waged against a single company, but against an entire financial architecture that has turned their labor into an asset class.

We reached out to SISC, Stewart’s parent company, for comment. None was forthcoming at the time of this publication.

MCS Sold Yet Again to a Publicly Traded Firm as Investigations Crank Up

The mortgage-field-services industry is rarely discussed outside boardrooms and vendor portals, yet its effects ripple through neighborhoods, shuttered homes, and the livelihoods of those who carry leaf-blowers, inspect boarded windows, and document blight for a living. At the center of the storm today is the recent acquisition by Stewart Information Services Corporation (through its SISCO subsidiary) of Mortgage Contracting Services (“MCS”) for approximately $330 million. But that sum barely scratches the surface of what labor on the ground is paying for — the consolidation, the shrinking competition, the shifting margins, and the pressures on the Field Service Technicians and Inspectors who do the real work behind property preservation. This article traces how that deal reflects decades of acquisitions by MCS, examines the economic and legal implications for labor and competition, and asks whether this is simply the next step in a quietly cartelized industry.

Almost four decades since its founding, MCS has transformed from a relatively modest property-services outfit into a dominant go-to platform through a spree of acquisitions. Its 2024 public disclosure noted that through “strategic acquisitions, outstanding client service and streamlined operations,” the company’s revenue rose by more than thirty percent and EBITDA more than doubled. A closer look, though, shows that MCS acquired firms such as Mortgage Specialists International (MSI), GIS Field Services, Five Brothers Asset Management Solutions and others. These moves pulled formerly independent vendors into the orbit of a single platform, shrinking the number of viable full-service providers to mortgage servicers and lenders. For Field Service Technicians and Inspectors this has translated into fewer buyer-channels for their labor, less bargaining power, and a relentless push for efficiency—and cost-cutting.

The $330 million purchase by Stewart of MCS’s mortgage-services business is being pitched as a growth play: Stewart will acquire “all operations and the technology supporting mortgage servicers and lenders in their property preservation efforts.” The press release praises MCS as a “well-respected leader” with nearly four decades of service. What goes unspoken is that such acquisition will almost certainly lead to even greater vertical integration, less competition on price, and, potentially, even fewer marketplace checks from labor. If the market already leaned heavily toward major platforms, this kind of transaction magnifies that power. The deal is subject to closing conditions and regulatory approval under the Hart–Scott–Rodino Antitrust Improvements Act. Which raises the question: will industry regulators ask the right questions? Moreover, though, after defaulting on nearly half a billion dollars during COVID, it seems more likely that the life raft and post Littlejohn purchasing spree was more to bury debt and employee misclassification claims. It also substantiates my prediction of a fully integrated institutional environment going forward.

For those working on the front-lines, the distinction between Field Service Technicians and Inspectors matters. Technicians perform hands-on labor: mowing, securing a property, removing debris, boarding windows, clearing vegetation. Inspectors perform the assessments: occupancy checks, detailed condition reports, documenting what survival of the property looks like week after week. In an industry where a handful of large platforms dominate ordering, the economic squeeze on technicians and inspector vendors intensifies. When MCS or a rival platform places a work-order, the pay-rate to local vendors is driven by the platform’s margin strategy, often leaving the lowest-cost performer viable while margins for labor shrink. In turn, working-class technicians may find themselves competing not just on skill but on acceptably low bids to the mega-platform. Inspectors likewise face technology demands, tight turn-times, and downward-pricing pressure, as fewer platforms control more of the demand.

From a legal and ethical perspective, there is a growing body of concern about antitrust risk in this sector. Earlier articles by industry-watchers noted how MCS’s acquisitions have led to “the final consolidation” of the mortgage field services market. An industry series published by the same source labeled the consolidation as “rarely as stark” as the decade led by MCS. In effect, the fewer independent providers remain, the more those remaining platforms can dictate terms—fees paid to vendors, pricing to servicers, and the thresholds for acceptable operational performance. From a labor-first lens this is profoundly disconcerting: when the competitive field collapses, workers bear the brunt through slower growth, less flexibility, and fewer alternative buyers of their services.

The ethical implications ripple further into property preservation outcomes. When large platforms dominate, the pressure to deliver volume cheaply can affect quality. Field Service Technicians may be pushed to complete grass-cuts or debris removals faster or with fewer resources. Inspectors may rush occupancy checks or miss degraded conditions because the ordering matrix prioritizes cost and speed over thoroughness. Those outcomes ultimately affect communities: prolonged vacancy, increased vandalism, fire risk, and blight proliferation. The irony here is plain: the same entity that claims to “preserve communities nationwide” may be subjecting the workforce to productivity demands that undermine that goal.

Turning to servicers and lenders, the dominance of one or two platforms might appear superficially efficient—having a national vendor simplifies coordination—but it also means less vendor competition, fewer price-shocks against the standard rate, and potentially higher hidden costs. For servicers managing portfolios of default properties, this could reduce flexibility, increase lock-in, and sideline smaller local firms that once offered alternative models. For those smaller firms, often employing local technicians and inspectors, the consolidation means either accepting the margin squeeze or exiting the business. That threatens the diversity of vendor ecosystems and limits labor mobility—weakening bargaining positions across the board.

The federal government’s role is critical here. While the HSR filing for Stewart’s transaction is noted, there is little public evidence of rigorous review of consolidation in the property-preservation vendor ecosystem. The U.S. Department of Housing and Urban Development (HUD) and the Consumer Financial Protection Bureau (CFPB) have oversight in aspects of mortgage servicing and default management, but the field services vendor layer has largely escaped public regulatory scrutiny. When labor is squeezed and vendor diversity vanishes into a handful of mega-platforms, the potential for reduced service quality and fewer accountability pathways increases. Inspectors and Technicians, as frontline labor, often have no voice in the ordering platforms—they are sub-vendors or subcontractors to the major vendors. That structural asymmetry warrants deeper regulatory attention.

From the standpoint of labor economics, the consolidation trend creates structural fragility for those whose livelihoods depend on the field services chain. Field Service Technicians often lack the safety net of large employers, working through small local firms or as independent vendors. If those firms get absorbed or driven out by consolidation, technicians face job instability, wage stagnation, and reduced bargaining power. Inspectors face similar risks: fewer vendors to choose from, fewer bidding options, and less possibility of switching platforms to protect rate levels. In a market where the ordering entity captures margins at scale, labor ends up competing with itself. The labor-first reality is that consolidation is not a neutral business story — it is a story of diminished alternatives and rising vulnerability.

With the acquisition of MCS by Stewart Information Services Corporation, a publicly traded entity listed on the NYSE under the ticker symbol STC, the once-opaque financial operations of Mortgage Contracting Services will now come under the regulatory transparency of the Securities and Exchange Commission’s quarterly (Form 10-Q) and annual (Form 10-K) filings. Under Littlejohn & Co.’s private-equity ownership, MCS operated behind a wall of private disclosure, leaving contractors, competitors, and even regulators guessing about its true revenues, liabilities, and vendor-payment practices. That era of financial secrecy has ended. As part of a public company, Stewart will be required to itemize MCS’s performance metrics, segment revenues, goodwill valuations, and risk disclosures, all of which will be subject to SEC review and investor scrutiny. This new layer of visibility means that for the first time, Field Service Technicians, Inspectors, and the broader mortgage field services industry will have access to audited financial data that can reveal how much profit is extracted from the labor chain versus reinvested into vendor infrastructure. It is a development that transforms MCS from a privately guarded empire into a measurable, accountable line item in a public corporate ledger—a shift that could expose, in black and white, the true economics of property preservation.

Looking ahead, the Stewart-MCS deal may mark a tipping point. If a major title/closing/servicer platform integrates property-preservation operations end-to-end, the entire vendor chain from Field Service Technician through Inspector up to servicer may be funneled through one vertically-integrated entity. That raises questions about transparency, vendor selection fairness, and labor participation. Will technicians and inspectors see improved rates as scale is realized, or will the dominant platform use its clout to compress costs further? Will smaller vendors be locked out or pushed to specialty niches? And will regulatory agencies treat the field-services vendor market as deserving competition review, or continue to treat it as a minor back-office area?

For the workers in the field, the narrative is clear: they are not simply labor inputs to a massive platform—they are the backbone of property preservation, community stabilization and serving the housing-market ecosystem during defaults and vacancies. Yet the business story being told by MCS and Stewart is about scale, technology, efficiency, acquisition, margin. The labor story is about fewer buyers, tighter rates, heightened competition among peers, and the hidden cost of consolidation in terms of job security, upward mobility and dignity of work. The mortgage field services industry may indeed become more efficient in ledger-sheet terms, but efficiency alone is no virtue if it comes at the expense of the very technicians and inspectors who maintain houses, communities and neighborhoods.

In conclusion, the Stewart acquisition of MCS is more than a headline, more than a financial transaction. It is a reflection of how the mortgage-field-services vendor ecosystem has shifted from many small vendors serving many servicers, to a centralized feed-chain dominated by platform vendors. For Field Service Technicians and Inspectors this consolidation means reduced competition, reduced bargaining power, and increased risk. For communities it means pressure on quality and responsiveness in preserving distressed or vacant properties. And for regulators it means a warning flag: when the vendor layer consolidates unchecked, the structural vulnerabilities of labor and neighborhood stabilization deepen. It is time that labor-voice, vendor-diversity and service-quality be raised as policy concerns in this industry, not left as silent casualties of C-suite growth strategies.


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Rebranding the Rot: NADP, NAMFS, and REOMAC All Have the Same Playbook

In the mortgage field services industry, where euphemism and obfuscation have become tools of survival, few words have been more misused than “rebrand.” What was once a corporate exercise in modernization has become a mechanism for escaping accountability. The National Association of Mortgage Field Services (NAMFS), now experimenting with its new identity as the “National Asset Management and Field Services,”— legally the National Association of Asset Management and Field Services—is simply the latest actor in a long-running drama of retreat. But before NAMFS took its first awkward steps toward reinvention, another organization blazed the trail: the National Association of Default Professionals (NADP), formerly REOMAC. And like NAMFS, NADP’s own transformation looks less like progress and more like an exercise in burying the evidence.

The origins of NADP’s troubles can be traced to the collapse of the REOMAC Foundation, its nominal charitable arm. According to official IRS records, the REOMAC Foundation’s 501(c)(3) tax-exempt status was automatically revoked on May 15, 2021, for failing to file the required Form 990 returns for three consecutive years. It should be noted that NAMFS is in the same boat according to the IRS and their nonprofit search page. The revocation was formally posted by the IRS on August 9, 2021, and to date there is no record of reinstatement. Despite this, NADP continues to feature the defunct REOMAC Foundation on its website, giving the impression of ongoing charitable legitimacy. In a sector where credibility is already thin, the decision to promote a revoked foundation reads as either breathtaking negligence or calculated deception. NADP’s leadership has refused to clarify the matter, reinforcing the perception that its rebrand was as much about rewriting history as redefining purpose. And NAMFS? Well, they still cannot agree on what their name is!

NAMFS, meanwhile, sits on the same slippery slope. The organization’s last publicly filed IRS Form 990 covers Fiscal Year 2023, which—while technically current—arrived after years of public opacity and internal turmoil. Since 2011, Executive Director Eric Miller has presided over a steady unraveling of NAMFS’ finances, credibility, and moral compass—logging an average of a $110,000 annual salary, travel junkets, hotels, and expenses. His salary has routinely exceeded total membership dues, an inversion of nonprofit purpose that would have embarrassed even the most cynical corporate board. While NAMFS remains on the IRS rolls for now, its delayed filings, refusal to release their Form 990 to the American public, and chronic membership fraud, one wonders if they are the same questions that doomed REOMAC’s tax-exempt status. One missed filing cycle, and NAMFS joins its new partner on the auto-revocation list.


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The alliance between NADP and NAMFS has been publicly described as a “strategic partnership,” but privately it looks more like a reputational life raft shared by two sinking ships. NAMFS, battered by declining membership and most recently the public relations fallout from the murder of Field Service Technician Michael Dodge II last month, needed a new ally to lend an air of credibility. NADP, still haunted by its foundation’s revocation and internal leadership overlap, needed visibility. Together, the groups found in each other what neither could find alone: a veneer of legitimacy. Yet even the basics of this partnership have been clouded by evasiveness. When asked about the relationship, NADP’s leadership declined to respond years ago. Transparency, in both cases, remains a casualty.

It is not the first time NAMFS has sought to polish its tarnished image through association. Over the years, it has partnered with data analytics behemoth Verisk, whose aggressive consolidation of property preservation software has drawn the attention of Housing and Urban Development (HUD) officials concerned about antitrust violations. A senior HUD official, speaking privately, confirmed that Verisk’s dominance “would certainly help lay the groundwork for an Anti-Trust case.” Despite those warnings, NAMFS ceded its own 2023 conference—mockingly dubbed “#FraudFest” by many—to Verisk’s marketing apparatus. Verisk’s fingerprints were on every panel, every sponsorship, every speech. By the end of the event, it was clear that NAMFS no longer represented the mortgage field services industry; it represented Verisk’s business interests within it.

The parallels between NAMFS and NADP go beyond structure and timing—they extend into ideology. Both organizations frame themselves as advocates for “industry professionals,” yet neither includes Field Service Technicians or Inspectors in that definition. For Technicians—the laborers who secure, clean, and repair foreclosed properties—and for Inspectors, who perform occupancy checks and condition reports, the associations’ rebrands mean nothing. These workers have seen over seventy percent of their ranks vanish in the past decade, according to NAMFS’ own data. The reason is simple: low pay, dangerous conditions, and a total absence of representation. The associations’ leaders, meanwhile, continue to collect salaries and sponsorships while ignoring the blood and sweat underwriting their existence. Moreover though, NAMFS members have received enormous price hikes in virtually every category, including inspections. Not a penny of that has filtered through. Labor’s pay remains stagnant over the past 30+ years.

When Michael Dodge II was murdered while performing a property preservation work order, NAMFS had a moral and institutional obligation to respond. Instead, it remained silent other than an incorrect and hastily worded private email. Its newly titled Unlocked podcast, hosted by Board Member Kellie Chambers—formerly of Mortgage Specialists, Inc., a company notorious for defrauding contractors—released episodes focused on profitability and “vicious animals” while Dodge’s death went unmentioned. It was a moment of chilling symbolism: a trade group obsessed with animals but indifferent to the human lives lost in its own backyard. NADP’s silence about its revoked foundation and its partnership with NAMFS suggests a similar moral void.

The irony is hard to miss. Both associations operate under the banner of professionalism, ethics, and compliance—words that ring hollow in the face of their conduct. NADP’s foundation, revoked for failing to meet the simplest of IRS obligations and NAMFS, whose FY2023 filing barely staves off scrutiny, continues to avoid meaningful engagement with the public or its members—or their required past two years of IRS 990 filings. These are not the actions of organizations committed to integrity. They are the actions of institutions that have learned to survive by rebranding rather than reforming.

This culture of perpetual reinvention is not just a branding problem—it is a structural threat to the industry itself. Many NAMFS members collect the pay owed to Field Service Technicians and Inspectors, steal it, and then rebrand. The involuntary bankruptcy of National Field Network, which eventually cost Shari Nott her life in an auto accident, is a prime example! By hiding behind nonprofit status while operating as trade cartels for management firms, associations like NAMFS and NADP distort the regulatory landscape. They claim to speak for the industry while silencing its labor. They invoke professionalism while enabling the very abuses that have driven Technicians and Inspectors out of the field. Their conferences, webinars, and “partnerships” serve as ritualized performances of legitimacy, not vehicles for reform.

If NADP’s revoked foundation represents one end of the spectrum and NAMFS’ better late than never FY2023 filing and the missing two years of filings the other, then the continuum between them is corruption disguised as continuity. Both organizations are running on fumes—fiscally, legally, and morally. What little credibility they still possess comes not from transparency or leadership, but from inertia. The system has not yet forced them to collapse, so they continue to exist. But make no mistake: they are ghosts, propped up by corporate sponsors and the illusion of nonprofit respectability.

The broader danger, however, extends beyond the walls of these associations. When nonprofits in federally adjacent industries like mortgage servicing flout transparency laws, they erode public trust in the very programs they orbit. HUD, the VA, the GSEs—all rely on trade groups to liaise with industry participants in good faith. Yet what they have instead are self-serving shells that neither protect workers nor uphold compliance. If REOMAC’s revocation is any indication, enforcement is possible. The only question is whether regulators will have the will to look past the rebrands and see the rot beneath.

Until then, the mortgage field services industry will continue its descent into the theater of the absurd—a place where defunct nonprofits run “foundations,” trade associations rename themselves to escape their pasts, and laborers are murdered while their supposed advocates like Kellie Chambers talk about animals on podcasts. Whether NAMFS joins NADP on the IRS revocation list is almost beside the point. Both have already forfeited what no reinstatement can restore: credibility. And for the Field Service Technicians and Inspectors still out there, knocking on doors and risking their lives for pennies, that loss is more than symbolic—it’s existential.

Steve Horne’s Black Dome Buys A2Z Field Services: Another Chapter in the Exploitation of Labor

In yet another reshuffling of the same broken deck, Steve Horne’s Black Dome Services has acquired A2S Field Services. For those who have endured the cyclical bankruptcy and collapse of Horne’s prior ventures, including the now-infamous Wingspan Portfolio Advisors, this acquisition is less a fresh start than it is a chilling return to form. It is signaling . . .

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The Knock That Never Should Have Happened: Why It’s Time to End Door Hangers and Return to Drive-By Inspections

In the aftermath of a year already marred by violence and fear within the mortgage field services industry, the image of a brightly colored door hanger bearing the logo of Select Portfolio Servicing, Inc. should chill anyone who values safety, legality, and basic human decency. The notice—left on doors by Inspectors under orders from banks, mortgage servicers, or order mills—demands “property verification” from occupants and includes language that many consumer attorneys now argue runs afoul of the Fair Debt Collection Practices Act (FDCPA). To the untrained eye, it may seem like harmless paper. To those in the field, however, it represents a direct invitation to confrontation, liability, and, increasingly, violence. The time has come for the industry to return to the pre-COVID practice of drive-by inspections, where Inspectors document from the curb and leave residents in peace.

Before COVID-19, occupancy inspections were largely visual drive by inspections. Inspectors confirmed habitation through observable indicators—lights on, trash cans out, curtains drawn—without any face-to-face contact. HUD, the VA, the USDA, and even the GSEs never required door knocks or physical contact as a condition of compliance. The logic was simple: Inspectors are not debt collectors. They are independent contractors tasked with reporting property conditions, not initiating borrower communication. When the pandemic hit, servicers panicked. In the name of “verification,” they began requiring Inspectors to photograph the front door, knock, and even engage with occupants to confirm identity and phone numbers. What began as a temporary COVID-era safety measure quickly metastasized into a permanent expectation—one that now places workers directly in harm’s way.

The FDCPA makes it clear that any communication that could be construed as an attempt to collect a debt falls under its jurisdiction. Door hangers like the one from SPS are saturated with collection language—statements about debt validity, disclosures required for collection agencies, and contact information for disputing debt claims. Yet, the individuals distributing them are not licensed debt collectors. They are Inspectors operating under subcontracts, often through two or three layers of vendor management, earning as little as three to five dollars per inspection. By instructing these workers to leave such materials, servicers are effectively transforming them into unlicensed collection agents, exposing both themselves and their contractors to potential federal violations. Worse, they are doing so without offering insurance, training, or legal indemnity.

It would be naïve to think that the National Association of Mortgage Field Services—or whatever it calls itself now—will raise its voice against this encroaching disaster. After all, this is an industry whose leadership remained silent after one of its own was murdered. Instead of calling for improved safety standards or coordinated identification systems, it launched a podcast series celebrating profitability and workflow management. The silence of NAMFS, and by extension the silence of the large national firms it protects, has created the perfect vacuum into which laws are flagrantly violated.

This transformation has ethical implications beyond mere compliance. Inspectors are not equipped to deal with irate or frightened homeowners. Many of the people receiving these notices are already under immense stress—behind on payments, facing unemployment, or grappling with medical debt. A stranger knocking at the door and leaving a notice bearing the name of a mortgage servicer can easily escalate a volatile situation. The death of Field Service Technician Michael Dodge II should have been a clarion call for reform. Dodge’s murder while performing legitimate preservation work illuminated the deadly consequences of forcing labor into unpredictable environments. Requiring Inspectors to knock and engage with occupants only amplifies that danger. And now with ICE sending out private bounty hunters to perform nearly identical tasks, the reality is not if but when do the bodies begin piling up!

Ironically, the government agencies that oversee mortgage servicing have already abandoned most of their pandemic-era protocols. Under the Trump administration, nearly all temporary COVID mandates tied to the US government, including in-field verification, were rescinded. Federal guidance now explicitly favors non-intrusive inspection methods. Yet order mills continue to cling to the knock-and-hang model, driven not by necessity but by profit. Each “verified contact” can be billed at a higher rate to investors, and in an industry where margins are razor-thin, the temptation to monetize human risk has proven irresistible. What remains unspoken is that every dollar earned through this practice comes at the potential cost of a life.

Field Service Technicians and Inspectors occupy different but equally vulnerable positions within the mortgage field services hierarchy. Technicians handle the physical labor—board-ups, lock changes, debris removal—often at abandoned or condemned properties. Inspectors, on the other hand, are dispatched to verify occupancy and condition. Both groups are misclassified as independent contractors, both lack meaningful safety protocols, and both face escalating hostility from the public. The growing confusion between these roles—compounded by servicers treating Inspectors as quasi-collectors—has made every job more dangerous. Homeowners no longer distinguish between a preservation worker and a repossession agent. To them, every knock is a threat.

The SPS hanger in the photograph epitomizes this confusion. Its fine print references debt collection disclosures, New York City licensing, and consumer dispute rights—all hallmarks of an FDCPA notice. Yet, Inspectors have no training in debt collection law and no authority to discuss account balances. By distributing such documents, servicers are effectively deputizing untrained workers to perform a function they neither understand nor are legally allowed to conduct. If challenged in court, these hangers could be used as evidence of unlawful debt collection practices and worker misclassification. The legal exposure for both servicers and their contractors is staggering, but the human cost remains higher still.

The simplest, safest, and most compliant solution is also the oldest one: the drive-by inspection. No knock. No door hanger. No confrontation. Just observation, documentation, and submission. Technology now allows for geotagged photographs and real-time GPS verification, rendering the old-fashioned door knock obsolete. The government’s own servicing guidelines do not require it. Yet the industry persists, trapped in a mindset that equates visibility with value. They would rather risk a lawsuit—or another death—than lose a few dollars in billable contact attempts.

It is worth remembering that the mortgage field services industry exists because of government tolerance, not statutory entitlement. HUD, the VA, and the GSEs could easily impose uniform safety standards tomorrow, prohibiting door knocks and prohibitive contact. They could mandate that any borrower contact be handled by licensed mortgage servicers or verified third-party call centers. They could remind the industry that Inspectors are not collectors, that Field Service Technicians are not law enforcement, and that property preservation should never become a death sentence. Instead, regulators have allowed servicers to set their own rules—rules that reward aggression and punish caution.

For those who labor in the field, every new door hanger is a reminder of how expendable they have become. Inspectors are told to “make contact” but not to trespass, to “engage politely” but not to argue, to “get the photo” but not to get killed. It is an impossible calculus, one that forces workers to gamble with their safety for pennies on the dollar. Returning to drive-by inspections is not just a matter of compliance or convenience. It is a matter of survival. The paper hanging on that door is more than an FDCPA violation waiting to happen—it is a warning that the system itself has forgotten who does the work, who takes the risk, and who ends up paying the ultimate price.

Until the mortgage field services industry acknowledges this truth, Inspectors and Technicians alike will remain at the mercy of policies written by people who have never once stood on a stranger’s porch with a clipboard, wondering whether this will be the house that ends them. The solution is simple, humane, and long overdue: stop the knocks, stop the hangers, and bring back the drive-by inspection. Anything less is an invitation to tragedy.