WASHINGTON (9/24/13)--Details of the Consumer Financial Protection Bureau's (CFPB's) final rule that amends its Ability-to-Repay, Mortgage Servicing and Mortgage Loan Originator Rules are laid out in a new Credit Union National Association Final Rule Analysis.
The CFPB amended and clairified parts of the mortgage rules to ensure a smoother implementation process in 2014.
Topics outlined in the final rule analysis include:
The small creditor exemptions;
How credit insurance premiums are "financed" by a creditor when the creditor allows the consumer to defer payment of the premium past the month in which it is due;
Specific procedures for servicers to follow if they fail to identify and inform a borrower upon an initial review that certain information is missing from a borrower's loss mitigation application;
Modifications that make it easier for servicers to offer short-term forbearance plans for delinquent borrowers who need only temporary relief without going through a full loss mitigation evaluation process. Servicers, upon reviewing an incomplete loss mitigation application, may provide a 6-month forbearance to a borrower who is suffering a short-term, temporary hardship; and
The circumstances under which a loan originator's or creditor's administrative staff acts as loan originators.
For the full CUNA analysis of the CFPB final rule, use the resource link.
CUNA members can also access a compilation of CUNA compliance resources available to help credit unions work through all the regulations' requirements.