CFPB Mortgage Servicing Amendments

Please see our monthly Regulatory Compliance Change Management Summary .

Noteworthy Updates:

  • The most current version of the Executive Summary has been provided.
  • Definition of Delinquency – After further review the determination was made that there would be no changes to the timing of the validation of debt letter so no testing will be needed. QA Validation package has been submitted.
  • Request for Information – Draft procedures have been submitted to Compliance and Legal for review and QA package is anticipated to be submitted by 8/31/2017.
  • Periodic Statements – Implementation stage was extended to 7/31/17 to accommodate delivery of Black Knight enhancement. Enhancement was delivered and moved to testing. Sample file for PBS changes was sent to NCP and conditional language for Charge off loans was approved by Compliance and Legal. Additional test file for charge off loans will be provided to NCP by the end of the month.
  • Force Place Insurance – Sample letters provided by Assurant, changes requested and updated letters are anticipated to be received by 9/5/2017. Once letters are approved by Compliance and Legal the QA Validation packages will be submitted.
  • Current project plans for all items has been included.
  • RESPA Policy – Attached is the draft changes to the RESPA Policy that has been updated to reflect the regulatory changes effective 10/19/2017.  The policy will not be finalized until 10/19/2017 due to conflicts with current regulatory requirements.

Additionally, as procedure changes and sample letters are reviewed and approved they will be provided in future advisories. Any questions on the documents provided or implementation can be direct to compliancechgmgnt@cenlar.com.