Effective January 10, 2014, the CFPB mortgage servicing rules will require credit unions to implement the following provisions under Regulation Z (TILA) and Regulation X (RESPA):
Regulation X (RESPA- Real Estate Settlement Procedures Act)
- Error resolution and information requests
- Force-placed insurance
- General servicing policies, procedures, and requirements
- Early intervention with delinquent members
- Continuity of contact with delinquent members
- Loss mitigation
Regulation Z (TILA- Truth In Lending Act)
- Interest rate adjustment notices for ARMs
- Prompt crediting of payments and responses to requests for payoff amounts
- Periodic statements for mortgage loans
Credit unions who are considered a Small Servicer are exempt from certain portions of the mortgage servicing rules.
Small Servicer Exemption:
- The credit union, together with any affiliates, service 5,000 or fewer mortgage loans, and the credit union (or affiliate) are the creditor or assignee for all of them.
- You are a Housing Finance Agency (HFA)