Although its new mortgage servicing regulations do not take effect until next January, the CFPB sent a reminder to residential mortgage servicers last week that they need to be ready now for the CFPB to take a close look at their operations.  In Bulletin 2013-1, the CFPB issued guidance warning servicers and subservicers that CFPB

In their letter commenting on the CFPB’s mortgage servicing proposal, Americans for Financial Reform and numerous other consumer advocacy groups, including Consumers Union, have asked the CFPB to consider withdrawing and reissuing the portions of the proposal that deal with loss mitigation and error resolution.

With regard to error resolution, the groups criticize the CFPB

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

Two recent notices published by the CFPB in the Federal Register shed some light on the CFPB’s plans for testing the mortgage servicing disclosures it’s developing and for collecting information about the potential compliance costs of its proposals.

A notice published on May 11 seeks comments on the CFPB’s plans to qualitatively test mortgage servicing

The CFPB has announced that it is working on a mortgage servicing rules proposal that it plans to issue this summer and adopt by January 21, 2013, with an implementation date still under consideration.

Aspects of the rules under consideration include:

  • Requiring monthly mortgage statements that include detailed payment information and, for delinquent borrowers, alerts

The CFPB’s Mortgage Servicing Examination Procedures, which I wrote about recently, cover lots of interesting topics.  Today, I want to focus on the section of the procedures that deals with a servicer’s consumer complaint handling process. 

The CFPB intends to assess the quality of servicers’ systems for receiving and dealing with complaints, including aspects of