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Getting Ready for January: CFPB Mortgage Servicing Rules
Wednesday, November 13, 2013 6:55 AM

Effective Jan. 10, 2014, the Consumer Financial Protection Bureau’s (CFPB) Final Rule will make changes to Regulations X and Z.  The final rule changes mortgage servicing in nine areas, the first four applying to all credit unions:

  1. New and additional adjustable interest rate (ARM) mortgage notices and disclosures;
  2. New payoff statement and prompt payment crediting requirements;
  3. New force-placed insurance notification and premium charging requirements;
  4. New error resolution and information request handling and response procedures;

And the last five apply to many credit unions, but with limited applicability to “small servicers”:

  1. New periodic mortgage billing statements;
  2. New servicing policies, procedures and requirements;
  3. New Early intervention requirements for delinquent borrowers;
  4. New continuity of contact requirements for delinquent borrowers; and
  5. New loss mitigation application, processing and handling procedures.

A “small servicer” is defined as an entity that services 5,000 or fewer mortgage loans, all of which the servicer (or an affiliate) is the creditor or the assignee.  This number is determined by the number of mortgage loans serviced by the servicer and any affiliates as of Jan. 1, and remains in effect for the remainder of the calendar year.

CUNA’s Rule Analysis on the Final rule is available here, and the CFPB has more information available here.  The CFPB has also released an easy to read small-entity compliance guide available here.

For any questions, please contact Cornerstone Credit Union League’s InfoCentral, at (512) 853-8515, or email