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.
Recent MBA Activity Related to CFPB Servicing Issues
- Comment Letter: MBA to CFPB on LIBOR Transition Issues (August 4, 2020)
- Comment Letter: MBA Comments on Proposed Debt Collection Rule (September 18, 2019)
- Joint Trades Letter: Coalition to Senate in Support of Kathy Kraninger Confirmation (November 12, 2018)
- Comment Letter: MBA to CFPB on RFI regarding Consumer Complaints and Inquiries (July 16, 2018)
- Comment Letter: MBA to CFPB on RFI regarding Guidance and Implementation Support (July 2, 2018)
- Comment Letter: MBA to CFPB on RFI regarding Inherited Rulemaking (June 25, 2018)
- Comment Letter: MBA to CFPB on RFI regarding Adopted Regulations and Rulemaking Authority (June 19, 2018)
- Comment Letter: MBA to CFPB on RFI regarding Rulemaking Processes (June 7, 2018)