We wanted to remind everyone that most of the CFPB’s new mortgage lending and mortgage servicing regulations go into effect in January 2014. The time to prepare is now, and this post is intended to highlight some of the resources (both paid resources and free resources) that are available to assist your credit union with the transition.
The best resource that we have seen is a reasonably priced compliance package put together by CUNA in partnership with PolicyWorks. You can learn more about this package, which CUNA is calling the “Mortgage Compliance Implementation Toolkit,” by visiting the CUNA website here. Many of the webinars that are included can also be purchased individually without purchasing the full package.
There are also many free resources that are available to assist you with the transition. Among them:
The CFPB maintains a web page designed to help explain all of the rules and provide compliance resources. You can find that page here.
CUNA has a chart that provides a good overview of the new regulations, which you can find on CUNA’s website here, and the League has put together an 80-page introduction to the regulations that is designed to help you identify and understand the ones that apply to your credit union. You can find that resource on the League’s website here.
CUNA’s online e-Guide includes up-to-date information on the new mortgage regulations, and CUNA’s compliance blog has recently had an ongoing tutorial addressing many of the more frequently asked questions about the new rules, including:
A five-part overview of how the new mortgage-servicing rules will affect the loss-mitigation process, including new requirements related to:
- drafting loss-mitigation policies and procedures (see post from Aug. 5, 2013)
- receiving, and acknowledging receipt of, loss-mitigation applications (see post from Aug. 6, 2013).
- evaluating and making decisions on loss-mitigation applications (see post from Aug. 7, 2013).
- a borrower’s acceptance or rejection of a loss-mitigation offer, and appeal of a loss mitigation denial (see post from Aug. 8, 2013)
- when the servicer can initiate foreclosure, as well as how a borrower’s loss-mitigation application affects the foreclosure process (see post from Aug. 9, 2013). This post also clarifies that “small servicers” are exempt from most of the loss-mitigation requirements.
A multi-part discussion of issues related to the “small servicer” exception, including posts that:
- explain who qualifies for the “small servicer” exception (see post from Aug. 14, 2013)
- explain what type of loans must be counted, and what type can be ignored, in determining whether the “small servicer” exception applies (see post from Aug. 21, 2013)
- explain what happens when a servicer begins to exceed the “small servicer” threshold (see post from Aug. 22, 2013).
- clarify which of the regulations are inapplicable to small servicers (see post from Aug. 23, 2013).
- explain that the exemption from the “general servicing policies and procedures requirements” does not relieve a “small servicer” from the obligation to implement policies and procedures required for compliance with other aspects of the mortgage servicing rules (see post from Aug. 27, 2013)
- explain whether and how the “small servicer” exception applies when a CUSO is servicing some of the credit union’s mortgages (see post from Aug. 28, 2013)
To follow any of the above links to CUNA’s website and the League’s website, you will first need to be logged onto those websites. If you are an employee of a credit union that is affiliated with CUNA and the Virginia Credit Union League, then you are entitled to have full access to both websites, and you are missing out on a lot of valuable information if you do not take the time to register. If you have trouble registering for either site, please contact us at firstname.lastname@example.org.
For compliance questions, contact the compliance team:
800.768.3344 ext. 610 (phone)