ABA wrote to the CFPB regarding proposed rules that would amend the mortgage servicing provisions of Regulation Z under the Truth in Lending Act (TILA) and Regulation X under the Real Estate Settlement Procedures Act (RESPA).
“ABA agrees that all borrowers deserve high-quality mortgage servicing. However, we are concerned about the scope of the proposal, whether it meaningfully advances consumer protection, and its potential implementation costs. We also have a number of comments regarding the specific requirements that the CFPB has proposed.”
ABA provided specific comments on the proposal in the areas of servicer diversity, cumulative impact, the small servicer exemption, compliance costs and effective date, and preemption. The letter also noted concerns regarding procedures and that not all of the proposed requirements are mandated by the Dodd-Frank Act.
Read the full letter.