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Mortgage Servicing Final Rule Analysis Now Available

Last month, the Consumer Financial Protection Bureau (CFPB) finalized required amendments made by the Dodd-Frank Wall Street Reform and Consumer Protection Act to Regulation Z and Regulation X. These required amendments will have a significant impact on the way closed-end mortgage loans are serviced by credit unions going forward. The final rules become effective January 10, 2014. The Credit Union National Association (CUNA) regulatory advocacy staff have been studying the rules carefully since their issuance by the bureau, and have also prepared a Final Rule Analysis that credit unions may use to help facilitate compliance with the new rules. The rules contain an important exemption for “small servicers,” as further detailed in our Final Rule Analysis, and credit unions will want to review this aspect of the final rules to determine whether the exemption will apply. There is also a more general summary that was posted the day after the rules were announced.