ABA submitted two comment letters to the CFPB in response to the CFPB’s request for comments on proposed amendments to the CFPB’s mortgage servicing rules.
The first letter comments on the provisions clarifying the relationship between State law and the Real Estate Settlement Procedure Act’s (Regulation X) servicing provisions; and the small servicer exemption from certain serving rules.
The second letter comments on the use of government-sponsored enterprise and Federal agency purchase, guarantee or insurance eligibility for determining qualified mortgage status; and the determination of debt and income for purpose of originating qualified mortgages.
Read the first comment letter.
Read the second comment letter.