SINCE THE PASSAGE of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) in July 2010, the regulatory environment has continued to impose many challenges on loan servicers. In addition to the servicing rules that became effective in January 2014, the Consumer Financial Protection
Bureau (Bureau) has continued to provide additional clarifications and revisions resulting
from industry and consumer feedback. The Bureau issued a final rule in August 2016 titled
Amendments to the 2013 Mortgage Rules Under the Real Estate Settlement Procedures Act
(Regulation X) and the Truth in Lending Act (Regulation Z), referred to as the 2016 Mortgage
Servicing Rule (the Rule). The Bureau has staggered the implementation dates so that some
provisions of the Rule will become effective on October 19, 2017, while others (rules addressing
successors in interest and bankruptcy) will not be implemented until April 19, 2018. Now is a
good time to step back and assess how prepared your organization is for these new provisions.
The Mortgage
Servicing
Rule
Are You
Prepared?
BY JIM SHANKLE, CFSA, AND LIZA WARNER, CPA, CFSA, CRMA
