The CFPB recently issued two updates for its Mortgage Servicing Rule amendments to Regulations X and Z. Issued on August 4, 2016, the Mortgage Servicing Final Rule amended various aspects of the existing Mortgage Servicing Rules. These changes will become effective either on October 19, 2017 or April 19, 2018.
First, the CFPB issued non-substantive, technical corrections to the Mortgage Servicing Final Rule issued in 2016. The corrections include several typographical errors, revisions to show the correct effective date for certain provisions, and a citation correction.
The CFPB also issued non-binding policy guidance for a three-day period of early compliance with the amended Mortgage Servicing Rules. According to the Bureau, the policy guidance was issued in response to industry concerns over operational challenges presented by the mid-week effective date. Industry participants sought the ability to implement and test these changes over the weekend prior to the effective date.
Accordingly, the non-binding policy guidance states that the CFPB does not intend to take supervisory or enforcement action for violations of existing Regulation X or Regulation Z provisions, resulting from a servicer’s compliance with the new requirements, up to three days before the applicable effective dates. Therefore, for amendments that become effective on October 19, 2017, the three-day period will cover Monday, October 16 through Wednesday, October 18. For amendments that will take effect on April 19, 2018, the three-day period will cover Monday, April 16 through Wednesday, April 18.
