March 4, 2013 – NAFCU members can learn more about the small servicer exemptions that are available for certain CFPB mortgage servicing requirements and how to determine whether their credit union qualifies by reading the March issue of the NAFCU Compliance Monitor newsletter.
The article explains that the new mortgage servicing rules include nine major requirements and numerous smaller requirements. Credit unions that qualify as small servicers are eligible for exemption from four major requirements: mortgage periodic statements; general servicing policies, procedures and requirements; early intervention with delinquent borrowers; continuity of contact with delinquent borrowers.
Steve Van Beek
These exemptions are there, the article notes, because “NAFCU and credit unions argued successfully that the servicing failures of the largest servicers should not result in increased regulatory requirements for small servicers.”
The article also explains which requirements are eligible for partial exemptions and which ones offer no exemptions.
The first step for credit unions who service mortgage loans needs to be a review of their eligibility for the small servicer exemptions,” said NAFCU Director of Regulatory Compliance Steve Van Beek. “With all the new mortgage requirements, knowing which requirements aren’t applicable is an extremely important part of a credit union’s mortgage implementation plan.”
In addition, the March issue (login required) looks at NAFCU’s recently unveiled CFPB mortgage rule scope-and-applicability charts and NCUA’s final rule on credit ratings that impacts credit union investment activities.