Shonk details policies and procedures banks will need to adopt to implement the successors in interest provision, as well as how banks will treat confirmed successors. She also addresses the new requirements for periodic statements, which represent "a significant departure" from prior practice.
Even though the requirements pertaining to successors in interest and periodic statements for borrowers in bankruptcy don’t go into effect until April 2018, implementation of these provisions is anticipated to be a substantial task. Banks should begin implementation as soon as possible, while being mindful of the October 2017 implementation deadline for all other provisions of the new servicing rules.
To help facilitate compliance, ABA recently released a 200-page, members-only Reference Guide to Mortgage Servicing.
Read the article.
Download the reference guide.