Regulations X and Z – 2017 Revised Servicing Rules
On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to the Dodd-Frank rules for servicers.
Those rules were originally effective on January 10, 2014. The CFPB issued proposed amendments in November 2014. The final rule adopts many of the proposed provisions.
This new 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 statement requirements under Regulation Z’s servicing provisions
Certain servicing requirements when a person is a potential or confirmed successor in interest, is a debtor in bankruptcy, or sends a cease communication request under the Fair Debt Collection Practices Act
Most of the revisions will take effect on October 19, 2017. The provisions relating to successors in interest and the provisions relating to periodic statements for borrowers in bankruptcy will take effect April 19, 2018.
The revisions are extensive and impact all servicers; some more than others. Implementation of most of the revisions is mandatory by October 19, 2017. The program explains each revision and clarifies what steps each institution must take to assure compliance.
- Successors in interest rules including:
- The definitions of successor in interest for purposes of Regulation X’s subpart C and Regulation Z
- How a mortgage servicer confirms a successor in interest’s identity and ownership interest
- The application of the Regulation X and Z mortgage servicing rules to successors in interest once a servicer confirms the successor in interest’s status
- Definition of “delinquency”
- Revised rules for requests for information
- Revisions for force-placed insurance disclosures and model forms
- Revised early intervention rules
- Major rework of loss mitigation rules
- Clarification of prompt crediting requirements
- Changes to periodic statement rules
- Clarification and expansion of the small servicer exemption
- Tweaks made to the Fair Debt Collection Practices Act
The program is designed for mortgage department managers, loan officers, compliance officers, loan processors and clerks, auditors, and anyone else with responsibilities related to the servicing of mortgage loans.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 41 years. In 36 years as a trainer over 130,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. As a contractor, he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.
Kelly M. Owsley is Director of Training Services for Compliance Resource, LLC. Kelly’s career in banking began in 2000. Since then she has worked for financial institutions ranging in asset size from $250 million to $3 billion. Kelly has worked in numerous areas of the financial services industry including retail branch management, lending, product development and training. In addition, Kelly spent three years in a training and development role with CUNA Mutual Group servicing the largest credit union in the United States. Most recently, she served as the Vice President of Compliance, BSA Officer, and CRA Officer for a community bank where she was responsible for implementing and training all compliance related topics. Kelly has conducted seminars in multiple states and has participated in numerous webinars sponsored by national providers. She is a Certified Regulatory Compliance Manager.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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