Comments Due to NAFCU: CFPB - Protections for Borrowers Affected by COVID-19 Under RESPA

Important Regulatory Dates Add to Calendar 2021-05-10 17:00:00 2021-05-10 17:00:00 Comments Due to NAFCU: CFPB - Protections for Borrowers Affected by COVID-19 Under RESPA NAFCU would like to highlight the following: The NPRM creates a temporary COVID-19 emergency pre-foreclosure review period that would prohibit mortgage servicers from making the first notice or filing required for judicial or non-judicial foreclosure until after December 31, 2021. Next, the NPRM would allow streamlined loan modification options to borrowers with COVID-19-related hardships based on an evaluation of an incomplete loan modification, provided certain criteria are met. Lastly, the NPRM amends the early intervention requirements and requires mortgage servicers to discuss additional COVID-19-related information during live contact with borrowers not in a forbearance program where available options exist, and provide information for those borrowers in a forbearance program at least 30 days before the end of the forbearance program. The proposed early intervention requirements would sunset on August 31, 2022. The small servicer exemption would still apply. Comments due to NAFCU: May 7, 2021 Comments due to CFPB: May 10, 2021 Comment now   NAFCU will send comments on behalf of its members to the CFPB by their deadline (May 10, 2021). Location NAFCU digital@nafcu.org America/New_York public

NAFCU would like to highlight the following:

  • The NPRM creates a temporary COVID-19 emergency pre-foreclosure review period that would prohibit mortgage servicers from making the first notice or filing required for judicial or non-judicial foreclosure until after December 31, 2021.
  • Next, the NPRM would allow streamlined loan modification options to borrowers with COVID-19-related hardships based on an evaluation of an incomplete loan modification, provided certain criteria are met.
  • Lastly, the NPRM amends the early intervention requirements and requires mortgage servicers to discuss additional COVID-19-related information during live contact with borrowers not in a forbearance program where available options exist, and provide information for those borrowers in a forbearance program at least 30 days before the end of the forbearance program. The proposed early intervention requirements would sunset on August 31, 2022.
  • The small servicer exemption would still apply.

Comments due to NAFCU: May 7, 2021

Comments due to CFPB: May 10, 2021

Comment now  

NAFCU will send comments on behalf of its members to the CFPB by their deadline (May 10, 2021).