CUNA
submitted comments to the CFPB in response to their interim final rule titled,
“Treatment of Certain COVID-19 Loss Mitigation Options Under RESPA (Reg X).”
This rule would amend Regulation X to temporarily permit mortgage
servicers to offer certain loss mitigation options based on the evaluation of
an incomplete loss mitigation application.
In this comment letter, CUNA generally supports the interim
final rule as a helpful response to CUNA President Nussle's March request for
"temporary flexibility for the consumer disclosure and application
processing requirements related to loss mitigation efforts, especially for
COVID-19 related loan modifications, forbearance agreements, and repayment
plans."
In addition, this letter calls for clarification of a
confusing hypothetical example provided by the CFPB, expresses our preference
for no additional notice requirements related to this regulatory change, and
advocates for additional changes to provide servicers with similar flexibility
for loss mitigation in all emergencies and disasters, not just the COVID-19
emergency.
CUNA will continue to work with
the CFPB to ensure credit unions have the regulatory flexibility necessary to
reach the right solutions for members in need of assistance during emergencies
and disasters.