First Call Day



  • Plaintiff's Financial Information Form may be filed either before or at the first mediation session.  You might have an opportunity to complete the form while waiting your turn for mediation, but failure to provide the form by the deadline may result in a Report of Noncompliance.  Mediators need form FDP-02A to complete the NPV spreadsheet.

  • No prior review required. Some lenders may have received and reviewed complete document packages and be ready to discuss the results of its analysis, but this is not a requirement for the first mediation. The priority of First Call Day is to ensure a thorough discussion of the homeowner's situation, the status of the loan, possible options available, and how to pursue them. The mediator facilitates and reports the parties' next steps and deadlines.

  • Mediators will not delay the session waiting for a bank representative. When the lender's representative is not readily available, mediators will move on to the next case and will return to the skipped case later.


  • Bring appropriate forms. Please bring any bank-specific forms that may be needed. If plaintiff's counsel provides any bank-specific forms at the mediation, discussion of sending and receiving those forms, including deadlines and confirmation of receipt, will be eliminated. There will be no dispute later about whether lenders sent any particular forms. This will simplify the discussion at mediation.

  • Changing lender representatives. The same mediator will take all cases from one plaintiff's counsel. Sometimes this will require lenders' counsel to facilitate quickly changing from one lender representative to another for the next case. Suggestions: Please plan ahead.  If you have several cases, you may contact the court clerk to learn the order of those cases ahead of time.  If you have more than four cases, please arrange for additional attorney coverage because no mediator will be scheduled for more than four cases in a half-day.  In mediation, while the mediator is writing the report, counsel may contact (by email or by stepping outside the room and phoning) the lender for the next mediation session. Alternatively, someone at lead counsel's office could contact the lender and advise them to have a representative call the mediation room in 10 minutes.