After reviewing the CFPB’s proposed mortgage servicing regulations, our basic observation is that the proposals follow the script contained in the CFPB’s exam guidelines, the fact sheet issued by the CFPB in April outlining what the proposals would contain, and the March settlement of high profile servicing-related enforcement actions by the federal government and state attorneys general. We have prepared a legal alert that provides details on the proposals.
Much work will need to be done during the comment period to ensure that the final rules truly reflect the industry’s concerns and the operational realities of mortgage servicing. Ballard Spahr’s Mortgage Banking Group will provide ongoing analysis of the CFPB’s efforts to reset the way mortgage servicing is conducted. On September 6, from 11:00 AM – 12:00 PM ET, the group will be conducting a webinar: “The Evolution of Mortgage Servicing: How the CFPB’s Proposed Servicing Rules Will Affect the Industry.” Information about the webinar and a link to register can be found here.