WHAT?
On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to the Dodd-Frank rules for servicers. Most of the revisions took effect on October 19, 2017. The provisions relating to successors in interest and the provisions relating to periodic statements for borrowers in bankruptcy will take effect April 19, 2018.
The final rule clarified, revised, or amended provisions regarding:
- Force-placed insurance notices, general policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions;
- Prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions;
- Certain servicing requirements when a person is a potential or confirmed successor in interest, is a debtor in bankruptcy, or sends a cease communication request under the Fair Debt Collection Practices Act.
WHY?
The revisions were extensive and impact all servicers to some degree. Implementation of most of the revisions was mandatory by October 19, 2017; however, key elements related to successors in interest take effect April 19, 2018. The program explains each revision and clarifies what steps institutions must take to assure compliance.
Topics Will Include:
Upon completion of the program participants understand the:
- Successors in interest rules including:
- The definitions of successor in interest for purposes of Regulation X’s subpart C and Regulation Z;
- How a mortgage servicer confirms a successor in interest’s identity and ownership interest; and
- The application of the Regulation X and Z mortgage servicing rules to successors in interest once a servicer confirms the successor in interest’s status;
- Definition of "delinquency;"
- Revised rules for requests for information;
- Revisions for force-placed insurance disclosures and model forms;
- Revised early intervention rules;
- Major rework of loss mitigation rules;
- Clarification of prompt crediting requirements;
- Changes to periodic statement rules;
- Clarification and expansion of the small servicer exemption; and
- The tweaks made to the Fair Debt Collection Practices Act.
Who Should Attend?
The program is designed for mortgage department managers, loan officers, compliance officers, loan processors and clerks, auditors, and anyone else with responsibilities related to the servicing of mortgage loans.
Instructor
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 41 years. In 36 years as a trainer over 130,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company.
There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. As a contractor, he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.