November 17, 2017

NAFCU supports Reg Z mortgage servicing rule changes

NAFCU Regulatory Affairs Counsel Andrew Morris, in a letter to the CFPB Friday, said the association is supportive of the bureau's efforts to address the statement timing provisions connected with a consumer's bankruptcy case housed in the Regulation Z mortgage servicing rules.

The CFPB's proposed amendments would allow a single-statement exemption at any point in the billing cycle related to the use of modified or unmodified periodic statements or coupon books used with bankruptcy cases. Morris told the CFPB this change would "vastly reduce the complexity associated with tracking and monitoring discrete triggering events in consumer bankruptcy actions."

Morris also recommended that the small-servicer exemption be expanded to give more regulatory relief to credit unions. He said while some credit unions do qualify for the exemption, many others remain ineligible and "would experience severe strain once successor in interest and bankruptcy periodic statement provisions go into effect."

The CFPB's mortgage servicing rules are set to take effect in April.