Mortgage Servicing Compliance & Guidance During COVID
In a sense, servicing consumer mortgage loans has always been a bit of the "wild west" of compliance, meaning there was little in the way of rules and regulations. But thanks to the COVID-19 events of 2020, including the difficulties so many borrowers are having with their loans, the flood of accommodation requests, and the unfortunate number of delinquencies and defaults, servicing, accommodations, and default management has become critically important. As well, after the financial crisis over a decade ago and resulting exposure of unsavory practices, rules were put into place by the Dodd-Frank Act. The CFPB has also issued additional regulations since that time that further the requirements mortgage servicers must follow. As well, the CFPB plans on issuing a final rule on debt collection standards soon. The rules around servicing include many "standard" requirements dealing with periodic statements and escrows, for example, but many of the requirements focus on how servicers deal with distressed borrowers - from mandating "early intervention" and processes around loss mitigation applications, to foreclosure timing rules. And within the last six months, the agencies have issued many proclamations and allowances for dealing with the many issues the pandemic has created. We'll focus on these critical areas as well as the rules, and provide practical advice on how to meet both regulatory and borrower expectations.