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NCUA reiterates TILA guidance in Reg Alert
ALEXANDRIA, Va. (1/10/14)--Small servicers, those defined as servicing 5,000 or fewer mortgages, are exempt only from portions of the Consumer Financial Protection Bureau's new Truth In Lending Act (TILA) mortgage servicing rule that requires issuance of periodic statements for closed-end mortgage loans, the National Credit Union Administration reminded in a regulatory alert (14-RA-03).

The NCUA noted that the TILA mortgage servicing rule, which becomes effective today, also requires:
  • New and revised disclosures for certain adjustable-rate mortgages; and
  • Prompt crediting of mortgage payments and responding to requests for payoff amounts.
The alert addresses timing requirements for standard and adjustable-rate mortgage statements, and what information must be included in the statements.

The agency also reminded that additional mortgage servicing requirements may apply under the new Real Estate Settlement Procedures Act (RESPA) mortgage servicing rule issued by the CFPB. Those requirements will be addressed in an upcoming NCUA Regulatory Alert (14-RA-04) expected soon.

Credit unions that act as creditors, assignees, or mortgage servicers should be familiar with both of these mortgage servicing rules to determine whether these rules regulate the loans that they service, and if so, what their compliance obligations are under the rules, the NCUA added.

For the full alert, use the resource link.
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