Some things to be aware of…

The CFPB recently updated its Mortgage Servicing Small Entity Compliance Guide to incorporate its mortgage servicing Final Rule that’s effective August 31st and its 2020 Interim Final Rule regarding loss mitigation options based on an incomplete loss mitigation application.  The revised Guide also clarifies that large servicers can use multiple electronic systems to create a servicing file, as long as the necessary documents and data can be put together within five days.

The CFPB also announced that final rules under The Fair Debt Collection Practices Act (FDCPA) will take effect as originally scheduled on November 30, 2021, as it determined any delay is unnecessary.  As a reminder, one of these rules focuses on communications and behaviors considered to be unfair, deceptive and/or abusive.  The other rule clarifies disclosure requirements and prohibitions related to time-barred debt.

If you’re a national bank or federal savings association, the OCC issued Bulletin 2021-35 to provide/update the names and addresses to be used for public notices under The Community Reinvestment Act (CRA), Fair Housing Act posters and adverse action notices under The Equal Credit Opportunity Act (ECOA)/Regulation B.  Any necessary changes are to be made within 90 days of the August 5th bulletin.

Published
2021/08/16

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