CFPB updates mortgage servicing small entity compliance guide
On August 4, the CFPB updated the mortgage servicing Small Entity Compliance Guide to include guidance on the 2021 Mortgage Servicing COVID-19 Final Rule and the 2020 Mortgage Servicing COVID-19 Interim Final Rule. In June, the Bureau finalized amendments to certain federal mortgage servicing regulations, which added provisions applicable to borrowers as federal foreclosure protections ended. As previously covered by InfoBytes, the CFPB previously released new FAQs regarding the Mortgage Servicing Rule and Regulation X and Regulation Z relating to escrow account guidance and analysis. The guide clarifies the servicing file requirements under the existing mortgage servicing rules and provides guidance regarding compliant use of multiple electronic systems. The guide also reflects updates made to the final rule regarding, among other things: (i) loss mitigation foreclosure protections; (ii) loss mitigation incomplete application requirements; (iii) and early intervention live contact. The final rule provisions addressed in the guide are temporary and phase out over time. Miscellaneous administrative changes have been made throughout the guide, as well.