ABA wrote to the CFPB seeking clarifications on several mortgage servicing rule questions bankers face.
Specifically, ABA asked how the bureau’s 120-day delinquency threshold applies to rolling delinquencies, when a delinquent borrower resumes making scheduled payments but never becomes current on the loan. ABA also sought clarification on the periodic statement requirement for loans that have been charged off, and it urged the bureau to adopt its interim final rule on exceptions for bankruptcies as proposed.
Finally, ABA urged the bureau to issue clarifications that will not require major systems modifications, as banks continue to test new systems for the mortgage rules that took effect in January and prepare for the TILA-RESPA integration next year.
Read the letter.