The CFPB has released its proposed mortgage servicing rules.  The proposals consist of a 250-page Real Estate Settlement Procedures Act (Regulation X) rule and a 178-page Truth in Lending Act (Regulation Z) rule.  Comments on the proposals will be due by October 9, 2012.  

While the proposals’ page count may seem modest compared to the CFPB’s nearly 1,100 page proposal integrating RESPA/TILA disclosures, the servicing proposals are untypically single-spaced rather than double-spaced.  … Continue Reading

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 related model forms and disclosures.… Continue Reading

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 and information about counselors who can assist in working with servicers and avoiding foreclosure.
Continue Reading

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 customer service phone lines like the ease of getting to a live person, the average hold times, and the abandonment rate of phone calls. … Continue Reading