New CFPB mortgage servicing rules present significant challenges for mortgage servicers

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1 New CFPB mortgage servicing rules present significant challenges for mortgage servicers Prepared by: Jose Vivar, Director, McGladrey LLP , Michael Sher, Partner, McGladrey LLP , August 2013 Effective January 14, 2014, mortgage servicers will need to comply with new rules issued by the Consumer Financial Protection Bureau (CFPB). These rules amend Regulation Z, implementing the Truth in Lending Act (TILA); Regulation X, implementing the Real Estate Settlement Procedures Act (RESPA); and certain provisions of the Dodd-Frank Act. The challenge Implementation and compliance presents a challenge, because the mortgage servicing rules breadth will require new policies and procedures, system changes and training development and delivery. Ultimately, the biggest challenge is finding personnel who can effectively plan, design, oversee and implement the changes, while still fulfilling their normal responsibilities. The project s size and importance merits a comprehensive and focused effort. There is significant reputational, operational and financial risk at stake, as evidenced by the regulatory actions and adverse media coverage of mortgage servicers already subject to similar rules. Further, the effort needs to start now, if it hasn t already, in order to have everything tested and operational by January The rules The first step for mortgage servicers is to understand the requirements. These rules are extensive, covering nine major aspects of mortgage servicing: y Periodic billing statements y Interest rate adjustment notices for Adjustable Rate Mortgages (ARMs) y Payment crediting and payoff statements y Force-placed insurance y Error resolution and information requests y General servicing policies, procedures and requirements y Early intervention with delinquent borrowers y Continuity of contact with delinquent borrowers y Loan mitigation procedures

2 Following is a brief overview of the key rules in the nine major areas. Servicers should read the complete rules to gain a full understanding of the new requirements. Periodic billing statements The new rule prescribes the timing, form and content that servicers must provide in periodic billing statements. The rule requires that each periodic billing statement includes information on the amount due and explanation, past payment breakdown, transaction activity and information on partial payments, servicer contact, account specifics and delinquency, if the borrower is more than 45 days past due. These new rules apply to closed-end consumer loans secured by a residential dwelling, and do not apply to reverse mortgages, time-share plans or to fixed-rate loans for which the servicer provides a coupon book. With respect to coupon books, the following must be included; (i) amount due, (ii) account information, (iii) contact information, and (iv) notice that help is available by request, either by telephone, in writing or in person. It has to be noted that mortgage loans originated with an ACH payment option will be subjected to the new rules. Interest rate adjustment notices for ARMs There are a host of notice requirements: y Interest rate adjustments on ARMs have to be communicated at least 210 days, but not more than 240 days, prior to the first payment due after the rate first adjusts. y At least 60 days, but not more than 120 days, before payment at a new level, when a rate adjustment causes the payment to change. y ARMs with scheduled interest rate adjustments occurring every 60 days or more frequently, and ARMs originated prior to January 10, 2015, in which the interest rate and payment are based on an index available as of a date that is less than 45 days prior to the interest rate adjustment date notice, must be provided notice at least 25 days, but not more than 120 days, before the first payment at a new level is due. y Notice of an interest rate change must be provided at least 25 days before payment at a new level, as a result of interest rate change for ARMs, if the change occurs within 60 days of closing and the new rate disclosed at closing is an estimate. The new rules also apply to: (i) closed-end consumer loans secured by a residential dwelling in which the interest rate may change after closing, and (ii) ARMs that convert to a fixed-rate mortgage loan, if the conversion results in a payment change. Interest rate change notices do not apply to: (i) ARMs that have a term of one year or less, or to (ii) ARMs if the first payment change is due within 210 days after closing, provided the new interest rate disclosed at closing was not an estimate. Prompt payment crediting and payoff statements The new rule stipulates the timing of crediting and applying payments, and responding to payoff requests. Servicers must credit periodic payments on the day they are received. If a servicer receives a payment less than the amount due for a periodic payment, the payment may be held in a suspense account until the amount in the suspense account covers a periodic payment; then, the servicer must apply the funds to the consumer s account. A payment qualifies as a periodic payment, even if it is insufficient to cover late fees, other fees or repayment of corporate advances. 2

3 Servicers also have to provide an accurate payoff balance to a consumer within seven business days of receiving a written request from the borrower or party acting on behalf of the borrower. Force-placed insurance There are a variety of changes regarding force-placed insurance, including: (i) not assessing a force-placed insurance premium, unless the servicer has a reasonable basis to believe that the borrower has failed to maintain hazard insurance, and (ii) providing written notices before charging the borrower for force-placed insurance. Specific items have to be included in the first notice, and the second notice is similar to the first notice, except for the requirement of additional disclosures. A similar notice is required upon the renewal of force-placed insurance, except no second notice is required before assessing a force-placed insurance premium after 45 days from the date of the notice. Error resolution and information requests Requirements that servicers must meet when responding to written information requests or complaints about errors are set in the new rules. Servicers must comply with the error resolution procedures for a number of categories of covered errors, and may designate a specific address for borrowers to use for information requests or error complaints. Furthermore, servicers must: (i) acknowledge information requests and error complaints within five days, in addition to correcting and providing notice of correction, and (ii) provide information within 30 to 45 days. Formal tracking reports will need to be implemented company-wide to help monitor compliance, if not already, in order to manage this process and to provide evidence of compliance. General servicing policies, procedures, and requirements The new rules require servicers to establish policies and procedures, which have to take into account the size, scope and nature of the servicer s operations. The CFPB and other bank regulators will be able to supervise servicers within their jurisdiction to assure compliance with policies and procedures. However, there will not be a private right of action to enforce these provisions. Servicers will need to perform a gap analysis to determine which current processes and procedures need to change as a result of the new rules. Early intervention with delinquent borrowers Servicers have to make a good faith effort to establish contact with borrowers by the 36th day of their delinquency and must: (i) promptly inform the borrowers of their loss mitigation options, and (ii) provide the borrowers with written notice by the 45th day of a borrower s delinquency. This notice includes specific elements, and a servicer is not required to provide the written notice more than once in any 180-day period. Formalized tracking systems will need to be implemented to manage this process and provide evidence that the servicer is compliant. 3

4 Continuity of contact with delinquent borrowers Maintaining reasonable policies and procedures for providing delinquent borrowers assistance with loss mitigation options is required in the new rules. Such policies and procedures should ensure assignment of trained personnel to a delinquent borrower by the time of the required written notice, and ensure availability of personnel by phone to respond to borrower inquiries and to provide assistance to the borrower. Despite the CFPB and other bank regulators having the ability to supervise servicers to assure compliance with these requirements, there will not be a private right of action to enforce the provisions. As with other aspects of these rules, servicers will need to implement formalized tracking systems to manage continuity of contact with delinquent borrowers to provide evidence that they are in compliance. Loss mitigation procedures One objective of the new rules is to prevent dual tracking, whereby a servicer is simultaneously evaluating a consumer for loan modification, while also preparing to foreclose. The new rules establish specified loss mitigation procedures for mortgage loans secured by a borrower s principal residence, including: requiring the servicer to acknowledge receipt of applications in writing; and to provide information on the application s completeness, the borrower s options for alternative financing options and the time period to submit any missing information. The servicer has additional requirements upon receipt of a complete loan modification application, and has the duty to exercise reasonable diligence in evaluating all loss mitigation options available. If the borrower s loan modification is denied, the borrower must be given a notice stating why. Additionally, if a complete loan modification application is received 90 days or more before a foreclosure sale, the borrower must be given at least 14 days to accept or reject the loan modification offer. There is a right of public action for all of the provisions relating to loss mitigation. Additionally, the CFPB and other bank regulators can supervise servicers. Policies and procedures for managing the existing residential portfolio must be enhanced to reflect the requirements of early intervention with borrowers and loss mitigation rules. The new rules require careful legal interpretation, in order to avoid violation of certain rules. For example, notice of receipt of a completed loan modification application or notice of missing information is explicitly required when received 45 days or more before a foreclosure sale. However, it is always a good practice to communicate to the borrower missing information within a specified period. Policies and procedures should state that written communications should be sent to a borrower within a specified period acknowledging receipt of a completed loan modification application or providing a listing of missing information. Exemptions Not all mortgages servicers are subject to all of the new rules. General exemptions The 2013 amendments to RESPA generally apply to all closed-end, federally related mortgage loans, except for loans on property of 25 acres or more, business purpose loans, temporary financing, loans secured by vacant land and certain loan assumptions or conversions. Open-end mortgage loans are generally exempt, and servicers of reverse mortgages or servicers who are qualified lenders under the Farm Credit Act of 1971 are generally exempt from a number of rules. 4

5 Small servicer exemption The CFPB provided an exemption for small servicers for some of the new rules. Small servicers are defined as those servicing 5,000 or fewer mortgage loans, and servicing only mortgage loans that the servicer or an affiliate owns or originated. However, this exemption only applies to: (i) periodic billing statements, (ii) general servicing policies, (iii) procedures and requirements, (iv) early intervention with delinquent borrowers and (v) continuity of contact with delinquent borrowers. Small servicers are required to comply with several portions of the loss mitigation provisions, and are not exempt from rules pertaining to interest rate adjustment notices, payment crediting and payoff statements, force-placed insurance (except as noted above), error resolution and information requests and loss mitigation procedures. Achieving compliance After having gained an understanding of the new requirements, it is prudent to perform an operation-wide assessment that identifies the people, processes and technology involved in each of the affected operational areas. An evaluation should include the following areas of your operations: y IT systems; to determine what changes will have to be made, in order to meet the reporting and other demands of the new rules y Business operations; to determine how to best design and document procedures that will allow them to perform compliance with the new rule effectively and efficiently y Training; to get people up to speed with new requirements and changes in procedures and systems Some questions to keep in mind as you perform your assessment: y Have you quantified the number of mortgage loans serviced, including estimating loans expected to be serviced effective January 2014? y Do you outsource some of the activities, such as monthly loan statements? Are third-party vendors ready to comply with the requirements of the above rules? y Have you quantified the manpower required to implement and comply with the above rules? Do you need additional personnel to design and implement a plan? Do you need additional personnel to maintain compliance with the new rules after implementation? Do you have the resources to design and present effective training for your personnel? The next step is to develop an implementation plan, including the following considerations: y Have you performed a gap analysis to determine what processes and procedures need to change as a result of the new rules? Do your policies and procedures reflect reality? y Has the plan been approved by senior management and the board (or similar oversight functions), as appropriate? y Has the plan been developed in consultation with or reviewed by key stakeholders, such as legal, risk, compliance and information technology? y Do you have a capable person with availability to champion the implementation plan? 5

6 y Does the plan contain key milestones, dates for completion of required steps for compliance and progress reports? How are you monitoring progress, such as through periodic reporting? Who monitors progress and keeps tasks on track? y Does the plan include an internal audit review? Have testing procedures been defined? How are results and progress tracked? y Does the plan identify the responsible parties for developing the plan, ensuring adherence to the plan, and maintaining future compliance? Is progress reported to senior management or the board (or similar oversight functions), as applicable? y Is your plan on schedule? If not, has the deviation from schedule been approved by the board, senior management or similar oversight function, as appropriate, and discussed with regulators? Are all aspects of your plan scheduled to be complete prior to the rule effective dates? y Have you discussed your implementation plan with regulators and compliance counsel, as applicable? Have discussions with regulators resulted in any changes to your implementation plan? y Do you have contracts with any third parties related to mortgage activities? If so, have you discussed and evaluated their implementation plan? Do you have a back-up plan, should the vendor not fully implement the necessary changes prior to the effective dates? A sound and well-executed implementation plan should result in a relatively orderly and effective incorporation of the new rules into your day-to-day business operations. Summary As you can appreciate, these are substantial new rules that will have an impact across your organization, and will expose you to new risks. The new rules will require effective and efficient implementation, as well as a planned and coordinated effort. McGladrey can relieve much of the strain by helping you develop an implementation and compliance plan, and once implemented, we make sure that compliance with the new servicing standards is being maintained. Our services can range from high-level guidance and facilitation to detailed planning and design. We can fill the manpower gap necessary to achieve the comprehensive and focused effort This document contains general information, may be based on authorities that are subject to change, and is not a substitute for professional advice or services. This document does not constitute assurance, tax, consulting, business, financial, investment, legal or other professional advice, and you should consult a qualified professional advisor before taking any action based on the information herein. McGladrey LLP, its affiliates and related entities are not responsible for any loss resulting from or relating to reliance on this document by any person. McGladrey LLP is an Iowa limited liability partnership and the U.S. member firm of RSM International, a global network of independent accounting, tax and consulting firms. The member firms of RSM International collaborate to provide services to global clients, but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. McGladrey, the McGladrey logo, the McGladrey Classic logo, The power of being understood, Power comes from being understood, and Experience the power of being understood are registered trademarks of McGladrey LLP McGladrey LLP. All Rights Reserved. 6

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