On August 19, 2014, the Consumer Financial Protection Bureau (CFPB) replaced the 2013-01 compliance bulletin and policy guidance with new updates. The New Guidance, Bulletin 2014-01, reinforces the original document and reflects results of the new servicing rules additional components in terms of regulations. These are a consequence of the new servicing rules and supervisory activities from the CFPB over the past eighteen months.

There are two new sections in the New Guidance. The first section entitled “General Transfer Related Policies and Procedures” details examples of the policies and procedures that CFPB examiners use to evaluate whether servicers have been successful in transferring related requirements. There are also fine points on post-transfer policies and procedures that servicers may spotlight in upcoming examinations. These include regularly scheduled calls between transferor and transferee servicers help identify research and promptly resolve any possible loan complications.

The second latest part entitled “Applicability of the New Servicing Rules to Transfers” responds to FAQs about how the altered Regulation X is applicable to servicing transfers. The section specifies certain areas of interest, including the number of transfers that might implicate requirements under the following:

• Error Resolution Procedures
• Early Intervention
• Loss Mitigation
• Continuity of Contact
• Force-placed Insurance.

The CFPB is utilizing the New Guidance in order to reinforce three important messages to the mortgage servicing industry. The first message entails the expectation of the CFPB that all mortgage servicers keep an active compliance management system (CMS). CMS would prevent violations of consumer protection laws and necessitate solutions to any violations. The second message instills close monitoring of the mortgage servicing market and may appoint further regulations. Third, the CFPB remains concerned about the current state of mortgage servicing transfers due to ongoing intense volume of servicing transfers.

Acuity National Real Estate Solutions, LLC provides its clients the best of both worlds?old-fashioned professional excellence supplemented by the cutting edge technology necessary for an optimized process and smooth, speedy transactions. In today?s market, you need an agile title and closing partner that can still keep its feet on the ground. To learn more about Acuity?s services, call us today at (502) 238-7500.