Three years after it began, the presidentially declared COVID-19 national emergency is officially over. On April 10, 2023, President Biden signed H. J. Res. 7, officially ending the COVID-19 national emergency a month earlier...more
On January 18, 2023, the Consumer Financial Protection Bureau (CFPB) released an updated version of its Mortgage Servicing Examination Manual. As the CFPB described in a corresponding blog post, the manual outlines “the types...more
As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our...more
As fears of a recession grow, it would be prudent for everyone—servicers and regulators alike—to think hard about default servicing improvements and reforms.
More than two years after the COVID-19 pandemic took hold of the...more
On Thursday, September 22, 2022, the Consumer Financial Protection Bureau (CFPB) issued a new request for information (RFI) regarding mortgage servicing, potentially opening the door for much-needed regulatory reforms. The...more
Two recent announcements by the Federal Housing Finance Agency (FHFA) will push the mortgage servicing industry to increase its collection and maintenance of consumer demographic and language preference data.
On May 3,...more
On March 13, 2020, President Donald Trump declared a national emergency in response to the novel coronavirus disease (COVID-19). Shortly thereafter, to assist consumers impacted by the COVID-19 pandemic, Congress passed the...more
Just two short months after the Consumer Financial Protection Bureau announced its COVID-19 mortgage servicing final rule, the effective date of August 31, 2021, is here. As we noted in our detailed breakdown of the final...more
With the release of the Consumer Financial Protection Bureau’s COVID-19 mortgage servicing final rule and an August 31, 2021, effective date that will be here before we know it, the race is on for servicers to digest the...more
6/30/2021
/ Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Evasion ,
Final Rules ,
Financial Services Industry ,
Foreclosure ,
Loss Mitigation ,
Moratorium ,
Mortgage Servicers ,
Mortgages ,
Regulation X
On June 28 2021, the Consumer Financial Protection Bureau released its much-anticipated mortgage servicing final rule related to COVID-19. This rulemaking amends Regulation X and, as expected, largely tracks the proposal that...more
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. The polling covers hot topics, including forbearances, deferrals, HUD loss mitigation...more
5/6/2021
/ Compliance ,
Coronavirus/COVID-19 ,
Credit Reports ,
Deferral Standard ,
Financial Services Industry ,
Forbearance Agreements ,
Foreclosure ,
HUD ,
Mortgage Lenders ,
Mortgages ,
Notarization ,
Polling ,
State and Local Government
Yesterday, the CFPB issued a proposed rule that would extend implementation of both parts of its debt collection rule by 60 days — from November 30, 2021, to January 29, 2022. The debt collection rule, which we have discussed...more
On April 5, 2021, the Consumer Financial Protection Bureau issued a proposal to amend the existing loss mitigation rules in Regulation X. As stated in the Bureau’s press release, the proposal is designed to “help prevent...more
On January 28, 2021, Acting Director David Uejio of the Consumer Financial Protection Bureau (CFPB) confirmed the CFPB’s new, aggressive approach to enforcement of COVID-19-related matters. Uejio’s statement, posted as a...more
On January 21, 2021, the Consumer Financial Protection Bureau (CFPB) released the 23rd issue of its Supervisory Highlights report, a special edition focusing entirely on the COVID-19 Prioritized Assessments that have been...more
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. This report is intended to show industry trends, not facts, and does not necessarily...more
12/23/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Credit Reports ,
Creditors ,
Debtors ,
Forbearance Agreements ,
Foreclosure ,
Loan Servicing ,
Loans ,
Mortgage Servicers ,
Mortgages ,
Notarization ,
Polling ,
State and Local Government ,
Tax Deferral
Oh what a year it has been in the mortgage servicing world! In 2020, our COVID-19 Compliance Roundtable met weekly to discuss emerging compliance issues under the CARES Act, federal agency guidance, state laws and orders, and...more
In mid May 2020, we highlighted that the Fannie Mae and Freddie Mac (GSEs) COVID-19 payment deferral programs put mortgage servicers at risk of violating some of the Consumer Financial Protection Bureau’s (CFPB) Mortgage...more
12/11/2020
/ Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Deferral Standard ,
Fannie Mae ,
Freddie Mac ,
GSE ,
Interim Final Rules (IFR) ,
Loss Mitigation ,
Mortgage Servicers ,
Mortgages ,
Relief Measures
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables...
The polling results included in this report are the anonymous responses of...more
12/2/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Credit Reports ,
Creditors ,
Debtors ,
Forbearance Agreements ,
Foreclosure ,
Loan Servicing ,
Loans ,
Mortgage Servicers ,
Mortgage Servicing Rules ,
Mortgages ,
Polling ,
State and Local Government ,
Tax Deferral
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. This report is intended to show industry trends, not facts, and does not necessarily...more
9/9/2020
/ Borrowers ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Credit Reporting Agencies ,
Deferral Standard ,
Escrow Agreements ,
Financial Distress ,
Forbearance Agreements ,
Foreclosure ,
GSE ,
Interim Final Rules (IFR) ,
Mortgages ,
Third Party Purchaser (TPP)
On May 14, 2020, shortly after the Fannie Mae and Freddie Mac COVID-19 payment deferral options were announced, we warned mortgage servicers about the legal risks associated with offering payment deferral programs to...more
6/24/2020
/ Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Fair Housing Act (FHA) ,
Fannie Mae ,
Freddie Mac ,
Interim Final Rules (IFR) ,
Loss Mitigation ,
Mortgage Bankers Association ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgages ,
Regulation X
On May 22, 2020, the CFPB issued a No-Action Letter (NAL) Template to a software company utilizing an internet-based platform for submission and processing of loss mitigation applications. Mortgage servicers may use the NAL...more
On Wednesday, May 13, 2020, Fannie Mae and Freddie Mac unveiled new retention workout options that were jointly developed and “specifically designed to help borrowers impacted by a hardship related to COVID-19 return their...more
On Friday, April 3, the Consumer Financial Protection Bureau (CFPB), Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the...more
The CFPB’s April 1, 2020, statement regarding credit reporting for loans affected by COVID-19 announced a “flexible supervisory and enforcement approach during this pandemic.” In addition to guidance regarding furnishing...more