Archive

On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements […]

On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement […]

During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions.  Many banks have in […]

On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to rules for servicers that went into effect on January 10, 2014. The CFPB issued proposed amendments to those rules in November 2014, and the final rule adopts many of the proposed provisions. This final rule clarifies, revises, or amends provisions regarding: Force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; Prompt crediting and periodic […]

“The Consumer Financial Protection Bureau has begun drafting a Notice of Proposed Rulemaking (NPRM) to make adjustments to the Know Before You Owe rule,” CFPB director Richard Cordray told industry trade groups in an April 28 letter. Cordray said he hopes the NPRM will be issued in late July. Well his “hopes” became reality late last week. On July 28 the CFPB Published a 293-page proposal. The proposal has a quick 82-day comment period, which […]