CFPB Issues Guidance on Important Effective Dates

July 3, 2017 at 8:49 am Leave a comment

The CFPB  last week issued important guidance about the effective dates to amendments to its mortgage servicing rules. This is definitely something you should talk over with your vendor and/or IT person.

In 2016, the CFPB finalized important amendments to its original mortgage servicing  and RESPA rules . The  amendments touched  on a broad range of subjects, from the identification and treatment of Successors in Interest  in estates with mortgaged property, to the legality of reaching out to  delinquent homeowners who declare  bankruptcy.

Different parts of the rule were to take effect on October 19, 2017 and April 19, 2018.  Both of these dates fall on a Thursday, a fact  that Siri just  confirmed  for me.  If I’m not careful between Siri and Alexa I’m in danger of becoming a functional illiterate but I digress.

Some quick-witted compliance folks were apparently able to explain to the CFPB why Thursdays are never a good day to have new rules take effect. As the Bureau That Never Sleeps explained in last week’s  guidance  “for many servicers, the Thursday effective dates could afford less than a full day—from the close of business overnight on each of the preceding Wednesdays—to update and test systems in order to be compliant with the 2016 amendments. If servicers do not have sufficient time to complete these tasks, their systems may be more likely to produce errors, which could expose servicers and consumers to risk.”

The Bureau’s guidance explains that  regulatory action will not be taken against servicers  that comply with the amendments as early as October 16, 2017  and April 16, 2018 respectively. This means that you will have the previous weekend to test-drive your systems. That might ruin your football Sunday but  if you are a Jet fan you should already be looking for excuses to avoid watching them play.

Have a great July 4th. .

Entry filed under: Compliance, Regulatory. Tags: .

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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