CSBS Model State IMB Capital, Liquidity, and Governance Standards

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During July 2021, the Conference of State Bank Supervisors (CSBS) released model state prudential and governance standards for independent mortgage bank (IMB) servicers. Prior to the model's release two states, Washington & Oregon, enacted legislation relating to capital & liquidity and corporate governance for IMB servicers. In lieu of allowing a patchwork of laws without guidance, CSBS began working towards this uniform model for other states to follow.   During development, MBA worked closely with CSBS to help shape the final proposal and has subsequently urged state policy makers that pursue adoption of any prudential servicing framework to adhere closely to the CSBS model to ensure consistency across independent state regulatory regimes. Uniform standards, aligned with federal requirements that apply to government sponsored enterprise and government loan servicing, will ensure that MBA’s IMB member companies are not subjected to conflicting supervisory standards across the states in which they operate.

CSBS Prudential Standards Adoption Map


States Which Have Adopted the Prudential Standards for Nonbank Servicers
Introduced Legislation
No Current Activity
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