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Since Reg X doesn’t clearly define what the CFPB considers to be 120 days past due, how are you handling this? On loans covered by 1024.41, do you require that a borrower be 120 days delinquent on a particular payment before you proceed with foreclosure? OR, do you consider the number of days they have been delinquent? For example, a borrower has paid 30 days late since May and have never brought the loan current during that time. They have been delinquent well over 120 days, but they’ve never been 120 days past due on any particular payment. Would your bank initiate foreclosure proceedings?
Check out this prior Q&A: https://mycomplianceresource.com/forums/topic/when-does-120-day-count-begin-for-foreclosures/
Also, here’s a good article that lays out the information: https://www.mondaq.com/unitedstates/x/396300/Financial+Services/The+120+Days+Before+Foreclosure+Requirement
And here’s the link to the proposal referenced in the article: https://www.gpo.gov/fdsys/pkg/FR-2014-12-15/pdf/2014-28167.pdf
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