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