In yesterday’s Federal Register, the CFPB published the compliance bulletin and policy guidance (Bulletin 2014-01) regarding mortgage servicing transfers that it previously issued on August 19, 2014 (New Guidance). The New Guidance updates and replaces earlier guidance regarding mortgage servicing transfers set forth in Bulletin 2013-01. We summarized the New Guidance in a prior blog post.
The New Guidance as published in the Federal Register does not include Appendix A which was part of the version issued on August 19. The Appendix contained a list of key regulatory provisions related to servicing transfers and mentioned in the New Guidance.
The Federal Register version gives the following cryptic description of the effective date of the New Guidance: “This bulletin is effective October 23, 2014 and applicable beginning August 19, 2014.”