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Readers of NAFCU's Compliance Blog learned Tuesday that the Consumer Financial Protection Bureau's proposed rule for mortgage servicers includes an exemption that, on close inspection, is narrower than it appears to be at first glance.

The proposed rule, issued earlier this month, would require mortgage servicers to provide some pretty detailed periodic statements to homeowners, but the rule exempts those servicing no more than 1,000 mortgages, provided those loans were originated by them and for which they still have servicing rights. But this exemption isn't pegged to the number of mortgages issued yearly but the total being serviced at any given time – including those loans originated "many years ago," writes NAFCU Director of Regulatory Compliance Steve Van Beek.

Van Beek looks at this and two other key points of this proposed rule in Tuesday's blog post. The others are the CFPB's assumptions about regulatroy burden – for which the CFPB has already admitted a lack of supporting data – and its assumptions about consumer behavior. For example, it assumes that consumers only refinance their mortgages by going to a new provider.

Van Beek is encouraging credit unions to make use of the public comment period on this proposed rule, which ends Oct. 9. NAFCU is preparing a Regulatory Alert seeking members' input to its official comment letter.

Credit unions can learn more about this and other CFPB proposed rules on mortgage lending during NAFCU's Sept. 5 webcast, "Inside the CFPB's Mortgage Proposals"; register now.