On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to the Dodd-Frank rules for servicers. Those rules were originally effective on January 10, 2014. The CFPB issued proposed amendments in November 2014. The final rule adopts many of the proposed provisions.
This new final rule clarifies, revises, or amends provisions regarding:
- Force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions
- Prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions
- Certain servicing requirements when a person is a potential or confirmed successor in interest, is a debtor in bankruptcy, or sends a cease communication request under the Fair Debt Collection Practices Act
Most of the revisions will take effect on October 19, 2017. The provisions relating to successors in interest and the provisions relating to periodic statements for borrowers in bankruptcy will take effect April 19, 2018.
The revisions are extensive and impact all servicers; some more than others. Implementation of most of the revisions is mandatory by October 19, 2017. The program explains each revision and clarifies what steps each institution must take to assure compliance.
- Successors in interest rules including:
- The definitions of successor in interest for purposes of Regulation X’s subpart C and Regulation Z
- How a mortgage servicer confirms a successor in interest’s identity and ownership interest
- The application of the Regulation X and Z mortgage servicing rules to successors in interest once a servicer confirms the successor in interest's status
- Definition of "delinquency"
- Revised rules for requests for information
- Revisions for force-placed insurance disclosures and model forms
- Revised early intervention rules
- Major rework of loss mitigation rules
- Clarification of prompt crediting requirements
- Changes to periodic statement rules
- Clarification and expansion of the small servicer exemption
- Tweaks made to the Fair Debt Collection Practices Act
Who Should Attend?
The program is designed for mortgage department managers, loan officers, compliance officers, loan processors and clerks, auditors, and anyone else with responsibilities related to the servicing of mortgage loans.
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