Some Servicers Think CFPB Proposed Change Must Go Further
November 20, 2017
Back in October, the CFPB issued a proposed rule to clarify the timing for mortgage servicers to transition to providing modified or unmodified periodic statements and coupon books in connection with a consumer’s bankruptcy case. Since its 2016 mortgage servicing rule was adopted, the bureau said it has received significant input that certain aspects of the single-billing-cycle exemption and timing requirements may be more complex and operationally challenging than it realized, and that the relevant provisions may be subject to different interpretations. Therefore, the CFPB proposed several revisions to replace the single-billing-cycle exemption with a single-statement exemption. More specifically, the bureau proposed to revise the single-billing-cycle exemption to instead provide a single-statement exemption for the next periodic statement or coupon ...