CFPB Issues Mortgage Servicing Proposals

Written by Steve Van Beek

Editor's Note:  Today's regularly scheduled post was bumped to Monday to provide the latest from the CFPB.  

The Good News.  The CFPB has added a search bar to their website.  

The Bad News.  The CFPB issued two mortgage servicing proposed rules today - one under Regulation Z (TILA) and the other under Regulation X (RESPA).  The comment period will end October 9, 2012 and the CFPB intends to finalize these rules by January 21, 2013.  

The Reg Z (TILA) proposal clocks in at 178-pages and the Reg X (RESPA) proposal clocks in at 250-pages.  Small in comparison, you might say.  Well, the CFPB seems to be feeling the heat for their massive proposals as they stopped using double-spacing. 

The CFPB also released additional documents:

• A 7-page Summary of the Proposals;
• A 4-page Fact Sheet;
• Report of the SBREFA Panel; and
• Summary of Design and Testing Findings.

And, NAFCU's Regulatory Affairs team will be drafting Regulatory Alerts on both proposals for NAFCU members.  

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You may be banging your head on your desk scratching your head wondering how you can keep up.  We'll do our best to help - including two upcoming education events.  

Seminar.  Our Compliance Seminar - October 23-26 in Seattle - will have sessions on the TILA/RESPA proposal, the remittances final rule and these latest mortgage servicing proposals.  Sign up by August 31st and Save $100.

September 5th Mortgage Webcast.  Additionally, on September 5th I'll be doing a NAFCU webcast titled "Inside the CFPB's Mortgage Proposals."  I'll dive into the details of the TILA/RESPA proposal (including the potential change to finance charges and the APR), the HOEPA/high-cost proposal as well as the new mortgage servicing proposal.  Sign up by August 29th to Save $100.  Also, the webcast is currently slated for 1.5 hours but we'll definitely going much longer than that given the amount of material to cover.   

Have a great weekend everyone!   

Comments

[Erin]

Thanks Steve for keeping us up to date. I took a quick glance at the new statement requirements (since I think I'm still suffering from the trauma of the 21 day rule from a couple years ago). Lo and behold, I found that once again the CFPB is making life miserable for all of us CUs that aggregate account statments. With the new statement timing requirements we'll either have to stop aggregating statements (extra cost) or send out payment coupons that no one wants (extra cost)

[Joyce]

Erin, we aggregate our account statements as well. I can assure you that we will be commenting on that aspect of the rule - along with so many other proprosed changes!