"CFPB order offers insight into pandemic mortgage servicing" by Jeffrey P. Naimon and H Joshua Kotin (Law360)
Law360Jeffrey P. Naimon, H Joshua Kotin
The U.S. Consumer Financial Protection Bureau in December issued a consent order based on alleged violations of its 2014 mortgage servicing regulations.
The consent order, which also bootstraps claims of unfairness and deception to alleged technical violations of the servicing regulations — principally adopted under Section 6 of the Real Estate Settlement Procedures Act — creates a remediation framework that financial institutions servicing mortgage loans should consider as they navigate the COVID-19 pandemic and prepare to work through the likely backlog of loans awaiting foreclosure once federal and state moratoria end.
Originally published in Law360; reprinted with permission.