CFPB Servicing Issues

Clarity, guidance, and causality; CFPB Mortgage Servicing Regulations found wanting. 

Overview: The CFPB's Mortgage Servicing Rules added a federal layer of regulation that contributed to the record increase in servicing costs in the last decade. MBA consistently advocates for clarity in guidance for its members and repeatedly revealed weaknesses in the crafting of the policy. In 2019, the CFPB's own "lookback" of the mortgage servicing rules revealed an inability to attribute a causal relationship between the policies which cost millions of dollars to implement and an improvement in borrower outcome. 

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