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Monday, November 25, 2013

Banking Trade Associations Comment on Regulations X and Z

The ABA, Consumer Bankers Association, and Mortgage Bankers Association have submitted a joint comment letter to the CFPB on their October 23, 2013 Interim Final Rule that amends certain mortgage servicing-related provisions in Regulation X and Regulation Z as well as the corresponding Commentary to these rules (collectively, the “Servicing Rules”).

The Interim Final Rule improves compliance certainty by creating certain exemptions from the Servicing Rules in situations where the Rules conflict with bankruptcy law and the Fair Debt Collection Practices Act (“FDCPA”).

“The Interim Final Rule, in conjunction with CFPB Bulletin 2013-12, has helped to improve servicer certainty with respect to the intersection of the Servicing Rules and other applicable law. We also believe that the Interim Final Rule will help to avoid unnecessary confusion for borrowers who have declared bankruptcy…. Accordingly, we request that CFPB finalize the Interim Final Rule as published.

While we strongly support the Interim Final Rule, we note that this is the third set of amendments to the Servicing Rules in 9 months… While these revisions have been helpful, keeping up with the evolving rules has been a significant challenge for many of our members.”

Read the comment letter.
Read the interim final rule.

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