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4 More Days to Comment on CFPB Mortgage Servicing Proposal

Comments are due on October 9th, so you have 4 more business days to submit a comment on the CFPB’s mortgage servicing proposal.  Depending, of course, on how you define ‘business days.’  (compliance humor!)  We have blogged about the servicing rules here and here.  You can get more information about the rule, including a the rule itself, a summary, and the report from the small business panel, here.

You can submit comments easily by going here for the Reg Z portion of the proposed rule, and here for the Reg X portion.

Comments from credit unions are very important so please consider making a comment.  If you’ve read the proposed rules you can see where the CFPB has taken comments from the small business panel into consideration in crafting some of the rules.  They can’t do the same with comments from credit unions unless credit unions actually comment. 

Things to consider when commenting: is the small servicer exemption threshold of 1,000 mortgages high enough?  Will it cover your credit union?  Will it cover your credit union if you continue to write mortgages at your current pace?  What if interest rates start rising and refinances slow down?  How often do your members refinance with another financial institution (the CFPB based the 1,000 threshold on the assumption that consumer refi every 5 years). 

How does your credit union handle member information requests and error complaints?  How does your credit union handle communications and follow up with delinquent borrowers?  Even though your credit union maintains good communication with members, especially delinquent members, how will these rules adversely affect your credit union?

With all the other proposed rules coming down the CFPB pipeline, how long should you have to implement these changes after the final rules are issued?  Why should you have a longer period then the large servicers?  Are some of these changes as simple as a vendor flipping a switch?

Of course, there are a hundred other issues that you could address in your comments.  If you don’t want to read the entire rule, I would suggest reading the CFPB summaries and CUNA’s comment call.  If something  jumps out at you you can always delve into the proposed rule to get more details.  It can also be helpful (and fun) to review comments that have already been filed.

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