Mortgage Servicing

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)

Back to CFPB Mortgage Compliance Center

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