New Mortgage Servicing Rules and FAQs

Adam Witmer
Regulatory Update

Earlier this month, the CFPB issued a final rule that amends certain parts of the 2016 mortgage servicing rules relating to periodic statements.  This rule revised the timing requirements for services that are transitioning between modified or unmodified periodic statements and coupon books when a consumer enters or exits bankruptcy.  In addition to these rules, the CFPB

The Revised Loan Estimate

Adam Witmer
TRID

While most seem to fully understand the rules regarding the disclosure of an initial Loan Estimate, many seem to have a more difficult time understanding when a revised loan estimate is required.  For example, I have heard the following questions asked many times:

Compliance Management Systems

Compliance Management Systems

Adam Witmer
Compliance Management

Adam talks about the core elements needed in a compliance management system including board of director oversight and the sub-elements of a compliance program.  This video outlines the expectations of a CMS as outlined by the CFPB and other regulatory agencies.  A sister article to this video can be found here.

Regulation D Excessive Transaction Monitoring

Adam Witmer
Regulation D, Compliance Management

Regulation D sets transaction limitations on savings accounts where a customer is not permitted to make more than 6 restricted transaction from the account during the statement cycle (or calendar month).  If a customer repeatedly makes excessive withdrawals, Regulation D, by definition, changes the account type from a savings account to a transaction account. The result is that a converted account would be incorrectly reported on the Call report by the financial institution.  Therefore, Regulation D requires financial institutions to monitor restricted transactions and to take action if a consumer exceeds the maximum number of transactions permitted on a savings account.

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