CFPB Issues Interim Rule and Proposal

On October 4th the Consumer Financial Protection Bureau (CFPB) issued an interim final rule and a proposed rule impacting mortgage servicing.  The interim final rule provides mortgage servicers with greater flexibility in communicating with borrowers about foreclosure prevention options when borrowers request a cease of communication.  The interim final rule becomes effective October 19, 2017.  The proposed rule would provide greater certainty to mortgage servicers in providing periodic statements to consumers during the bankruptcy process.  The proposed rule comment period ends 30 days after it is published in the Federal Register.  If approved the proposed rule would be effective April 19, 2018.

The interim final rule on mortgage servicer communication flexibility is available at: http://files.consumerfinance.gov/f/documents/201710_cfpb_amendments-to-2016-Servicing-Rule_interim-final-rule.pdf

The proposed rule on periodic statements is available at: http://files.consumerfinance.gov/f/documents/201710_cfpb_amendments-to-2016-Servicing-Rule_NPRM.pdf

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John Zasada is a principal with CLA and leads the firm’s financial institution regulatory compliance practice. He assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments. In addition, John is a frequent speaker at industry conferences and state associations. Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.

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