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Washington
Mortgage Reg Recommendations Featured In CompBlog
WASHINGTON (8/8/13)--Existing and upcoming mortgage changes, and how credit unions can comply with and prepare for them, feature heavily in the latest edition of the Credit Union National Association's CompBlog Wrap-Up.

One mortgage question credit unions are asking is whether the "prompt crediting of payments" requirement in the Consumer Financial Protection Bureau's mortgage servicing rule applies to home equity lines of credit (HELOCs).

The answer is no, according to CUNA compliance staff. The provision requiring "prompt crediting of payments" under Reg. Z Section 1026.36(c)(1) applies to closed-end mortgage loans secured by the borrower's principal dwelling. It does not apply to HELOCs.

CUNA compliance staff also answer another key question in the wrap-up: Are mortgage servicers required to establish a process for receiving notices of error and information requests through our website?

In this case, the answer is also no. According to the CFPB's new rule, a mortgage servicer is allowed, but not required, to establish a process for receiving error resolution and information request notices through email, website form, or other online intake methods. Any such online intake process will be in addition to, and not in lieu of, any process for receiving error resolution and information request notices by mail.

This month's Wrap-Up also links to a five-part CompBlog series on error resolution and information notice requirements in the new mortgage servicing regulation. The series addresses:
  • Preparing policies and procedures for error resolution and information requests required by the new mortgage servicing rule;
  • What is a "notice of error" or "information request" as defined by the new mortgage servicing rule;
  • Acknowledging the receipt of the error resolution and information request notice;
  • How to respond to an information request; and
  • How to respond to a notice of error.
The Wrap-Up also features details on the CFPB's finalized ability-to-repay and mortgage servicing rules, and update on legislative activities, and other compliance resources.

And, as it does every month, the CompBlog Wrap-Up lists the upcoming effective dates of new regulations, important compliance articles and reports to read, as well as CUNA training programs.

For more of the CUNA CompBlog Wrap-Up, and other compliance gems, use the resource link.
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