Understand the New Requirements of the CFPB’s Mortgage Servicing Rules
Beginning October 19, 2017, mortgage servicers must comply with significant changes to the Consumer Financial Protection Bureau’s (CFPB) Mortgage Servicing Rules regarding the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z). Other changes are effective April 19, 2018. Insufficiency of hazard insurance may lead to new requirements for lender-placed insurance, and early intervention with delinquent buyers will be governed by new contract obligations. Also, there will be several changes to periodic statement requirements and to the definition of a “small servicer.” Mortgage servicers have a lot to prepare for in order to be ready by October.
This session with financial services attorney Chrys Lemon will provide a user-friendly approach to understanding the new requirements and changes to the CFPB’s Mortgage Servicing Rules. Chrys will address, in easy-to-understand detail, how the Mortgage Servicing Rules apply to successors in interest, including the key to confirmation of a successor in interest’s identity and ownership interest. He’ll discuss what constitutes a mortgage “delinquency” and how you should respond to requests for ownership information on certain Fannie Mae and Freddie Mac loans. Chrys will also address several changes to the loss mitigation requirements and prompt payment crediting for borrowers under loss mitigation programs. Charts and reference documents that detail how the mortgage servicing rules will soon change will also be provided as takeaways.
What is a “successor in interest,” and what new requirements apply to them?
How must a servicer respond to requests for information about ownership in connection with loans in trust where Fannie Mae or Freddie Mac is the owner of the loan or the trustee of a related securitization trust?
How has the CFPB clarified the live contact obligations for early intervention connected to delinquent borrowers?
How have the loss mitigation requirements changed?
How must a servicer treat periodic payments when a consumer is performing under either temporary loss mitigation programs or permanent loan modifications?
What are the new requirements for periodic statements on mortgage loans that have been accelerated or permanently modified?
What is required to qualify as a “small servicer?”
Who Should Attend
Anyone involved in servicing consumer mortgages, including compliance managers and legal counsel
Chrys Lemon is a partner in McIntyre & Lemon, PLLC, in Washington, D.C. He specializes in financial services law, particularly related to marketing of consumer financial products and services, privacy law, insurance law, and regulation of financial institutions by the Consumer Financial Protecti...
Disclaimer: The content herein does not represent any association between CFPB and Eli Financial LLC. CFPB neither endorses any product of Eli Financial LLC nor warrants accuracy of the content hereto.