CFPB 2016 Mortgage Servicing Rule – Update
On August 4, 2016, the Consumer Financial Protection Bureau (CFPB) issued a final rule (2016 Mortgage Servicing Rule) amending certain mortgage servicing provisions in Regulation X (RESPA) and Regulation Z (TILA). On October 18, the 2016 CFPB Mortgage Servicing Rule was published in the Federal Register.
- All provisions (except the ones below) are effective October 19, 2017;
- Successor in interest provisions are effective April 19, 2018;
- Bankruptcy periodic statement provisions are effective April 19, 2018
The final rule covers nine major topics:
- Requests for Information;
- Definition of Delinquency;
- Lender-placed insurance;
- Prompt Payment Crediting;
- Small Servicers;
- Successors in Interest;
- Early Intervention;
- Loss Mitigation;
- Periodic Billing Statements.
Cenlar implemented a Project Management Team (PMO) responsible for the governance of the implementation of these new rules. Cenlar’s Legal Team spent the months of September and October reviewing and interpreting the new rules.
Lead by Cenlar’s PMO and Compliance Team, Cenlar is now meeting with the applicable business areas to scope out the Impact of the 9 major topics. The goal is to have a project plan completed by the end of December that can be shared with our Clients on a monthly basis.