Do You Have A Plan For Transferring Your Servicing Rights? You Probably Should…

Gone are the days that a simple "Hello/Goodbye" letter could satisfy the transfer of servicing obligations from one mortgage company to another. In light of potential risks to consumers during the mortgage servicing transfer process, the Consumer Financial Protection Bureau (CFPB) has issued Bulletin No. 2014-01, which replaces Bulletin No. 2013-01. The Bulletin targets issues that the CFPB continues to believe pose a risk to consumers when the servicing of their mortgage is transferred. It also gives a roadmap to what examiners will be looking for the next time they come in for an examination.

The Bulletin is divided into four parts: (i) general transfer-related policies and procedures; (ii) applicability of the other servicing rules to transfers; (iii) protections under other consumer credit protection laws; and (iv) plans for handling servicing transfers.