On August 19, 2014, the Consumer Financial Protection Bureau (CFPB) replaced the 2013-01 compliance bulletin and policy guidance with new updates. The New Guidance, Bulletin 2014-01, reinforces the original document and reflects results of the new servicing rules additional components in terms of regulations. These are a consequence of the new servicing rules and supervisory activities from the CFPB over the past eighteen months.
There are two new sections in the New Guidance. The first section entitled “General Transfer Related Policies and Procedures” details examples of the policies and procedures that CFPB examiners use to evaluate whether servicers have been successful in transferring related requirements. There are also fine points on post-transfer policies and procedures that servicers may spotlight in upcoming examinations. These include regularly scheduled calls between transferor and transferee servicers help identify research and promptly resolve any possible loan complications.
The second latest part entitled “Applicability of the New Servicing Rules to Transfers” responds to FAQs about how the altered Regulation X is applicable to servicing transfers. The section specifies certain areas of interest, including the number of transfers that might implicate requirements under the following:
The CFPB is utilizing the New Guidance in order to reinforce three important messages to the mortgage servicing industry. The first message entails the expectation of the CFPB that all mortgage servicers keep an active compliance management system (CMS). CMS would prevent violations of consumer protection laws and necessitate solutions to any violations. The second message instills close monitoring of the mortgage servicing market and may appoint further regulations. Third, the CFPB remains concerned about the current state of mortgage servicing transfers due to ongoing intense volume of servicing transfers.
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