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ARTICLE · 06 OCTOBER 2014

Lessons From The CFPB's First Mortgage Servicer Rule Enforcement Action

The Consumer Financial Protection Bureau indicated that it would not aggressively enforce the rule for the first six months the rule was in effect.

United StatesFinance and Banking

Following its adoption of the mortgage servicing rules on January 17, 2013, the Consumer Financial Protection Bureau (CFPB) indicated that it would not aggressively enforce the rule for the first six months the rule was in effect. With the issuance of an enforcement order for violation of those servicing rules, however, the industry is now on notice that the leniency period is over and servicers need to be fully compliant with the rules.

Background: The Servicing Rules

The servicing rules are composed of amendments to both Regulations X, the implementing regulation for the Real Estate Settlement Procedures Act, and Regulation Z, the Truth in Lending Act.

Regulation X

The Regulation X servicing rules are:

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