CFPB Servicing Standards-September 2013 Update
As a continuation of our communications relating to changes being made as a result of the CFPB Servicing Standards, we are updating you on several changes occurring on billing statements and coupon books and the manner in which they are provided to your borrowers:
- The format of the current monthly billing statement will be change to coincide with CFPB requirements.
- ACH borrowers that are not currently receiving billing statements will either receive a coupon book or billing statement, depending on your particular parameters with Cenlar.
- Borrowers who are currently on coupon books and become 45 days or more delinquent will be converted to monthly billing statements. Once a borrower is converted to monthly billing statements, they will not be able to switch back to coupon books.
- Borrowers who are active in foreclosure or bankruptcy will receive a monthly billing statement (with applicable disclosures).
- Borrowers with adjustable rate mortgages (ARMs) and on coupon books will be converted to monthly billing statements.
- Messaging capability on monthly billing statements will be affected:
- No messaging will be available to borrowers who are more than 45 days delinquent;
- Borrowers less than 45 days delinquent may have less space available for messaging.
Please note: the changes above are not applicable for borrowers with a Home Equity Line of Credit (HELOC).
Borrowers who remain on coupon books will receive a new coupon book that includes the applicable CFPB required information.
Lastly, all rules above become effective January 10, 2014.
If you have any questions or concerns, please contact your Relationship Manager or Nancy Irwin, Vice President Client Relations at 609-883-3900 extension 2551.