On February 13, 2015, the Federal Deposit Insurance Corporation (FDIC) announced the release of the third in a series of three new technical assistance videos developed to assist banks in complying with certain mortgage rules issued by the Consumer Financial Protection Bureau (CFPB). This third release consists of five short videos covering the Mortgage Servicing Rules.
The videos provide a good explanation of how banks can accurately determine whether they qualify for the Small Servicer status, therefore qualifying for certain exemptions from the mortgage servicing rules. The videos also discuss some of the challenges Servicers are facing and tips/suggestions for compliance management.
As a refresher, if you qualify as a Small Servicer, the following provisions related to the 2014 Mortgage Servicing Rules STILL apply to you:
1. Promptly crediting payments and providing payoff statements;
2. Providing accurate and timely ARM disclosures;
3. Providing timely and accurate information in response to requests for information;
4. Investigating, responding to, and, as appropriate, making corrections in response to errors, and informing borrowers appropriately;
5. Following the loss mitigation 120-day pause rule;
6. Following the new force-placed insurance and related escrow rules; and,
7. Mortgage servicing transfer rules.