Some things to be aware of…
The CFPB recently updated its Mortgage Servicing Small Entity Compliance Guide to incorporate its mortgage servicing Final Rule that’s effective August 31st and its 2020 Interim Final Rule regarding loss mitigation options based on an incomplete loss mitigation application. The revised Guide also clarifies that large servicers can use multiple electronic systems to create a servicing file, as long as the necessary documents and data can be put together within five days.
The CFPB also announced that final rules under The Fair Debt Collection Practices Act (FDCPA) will take effect as originally scheduled on November 30, 2021, as it determined any delay is unnecessary. As a reminder, one of these rules focuses on communications and behaviors considered to be unfair, deceptive and/or abusive. The other rule clarifies disclosure requirements and prohibitions related to time-barred debt.
If you’re a national bank or federal savings association, the OCC issued Bulletin 2021-35 to provide/update the names and addresses to be used for public notices under The Community Reinvestment Act (CRA), Fair Housing Act posters and adverse action notices under The Equal Credit Opportunity Act (ECOA)/Regulation B. Any necessary changes are to be made within 90 days of the August 5th bulletin.
Published
2021/08/16
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!