The American Bankers Association told the CFPB its members are working hard to refine their implementation of the bureau’s new mortgage servicing rules, but have bumped into a handful of questions and concerns they’d like the agency to address via regulatory guidance or amendment. The first issue involved rolling delinquencies and the “120-day rule.” The bureau’s rule prohibits a servicer from making the first notice or filing for foreclosure unless a borrower’s mortgage loan obligation is more than 120 days delinquent. Many ABA members asked how this 120-day rule applies to “rolling delinquencies,” which occur when delinquent borrowers resume making payments on the loan without making up for past missed payments. “ABA members need regulatory certainty regarding how to apply ...