Bulletin 2020-02-Compliance Bulletin and Policy Guidance: Handling of Information and Documents During Mortgage Servicing Transfers
| Published date | 01 May 2020 |
| Citation | 85 FR 25281 |
| Record Number | 2020-09151 |
| Section | Rules and Regulations |
| Court | Consumer Financial Protection Bureau |
Federal Register, Volume 85 Issue 85 (Friday, May 1, 2020)
[Federal Register Volume 85, Number 85 (Friday, May 1, 2020)]
[Rules and Regulations]
[Pages 25281-25285]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-09151]
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Rules and Regulations
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains regulatory documents
having general applicability and legal effect, most of which are keyed
to and codified in the Code of Federal Regulations, which is published
under 50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by the Superintendent of Documents.
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Federal Register / Vol. 85, No. 85 / Friday, May 1, 2020 / Rules and
Regulations
[[Page 25281]]
BUREAU OF CONSUMER FINANCIAL PROTECTION
12 CFR Part 1024
Bulletin 2020-02--Compliance Bulletin and Policy Guidance:
Handling of Information and Documents During Mortgage Servicing
Transfers
AGENCY: Bureau of Consumer Financial Protection.
ACTION: Compliance bulletin and policy guidance.
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SUMMARY: The Bureau of Consumer Financial Protection (Bureau) is
issuing a compliance bulletin and policy guidance (Bulletin) entitled,
``Compliance Bulletin and Policy Guidance: Handling of Information and
Documents During Mortgage Servicing Transfers.'' The purpose of the
policy statement is to provide guidance to residential mortgage
servicers regarding the transfer of mortgage loans, including examples
of practices that the Bureau may consider as contributing to policies
and procedures that are reasonably designed to achieve the objectives
of the regulatory requirements.
DATES: This Bulletin is applicable on May 1, 2020.
FOR FURTHER INFORMATION CONTACT: Eric Lum, Analyst, Office of
Supervision Policy, at 202-435-9783 or Allison I. Brown, Deputy
Assistant Director, Office of Supervision Policy, at 202-435-7107. If
you require this document in an alternative electronic format, please
contact [email protected].
SUPPLEMENTARY INFORMATION:
I. Introduction
The Bureau of Consumer Financial Protection (Bureau) is issuing
this Bulletin to residential mortgage servicers and subservicers
(collectively, servicers), in light of potential risks to consumers
that may arise in connection with transfers of residential mortgage
servicing rights. This bulletin covers: (A) Transfer-related policies
and procedures, and (B) loan information and documents for ensuring
accuracy.
II. Compliance Bulletin and Policy Guidance
A. Background
A mortgage servicer, among other things, collects and processes
loan payments on behalf of the owner of the mortgage note, conducts
escrow related processes and handles loss mitigation as appropriate.
Servicing transfers are common and may occur in several ways. The
mortgage owner may sell the rights to service the loan, called the
Mortgage Servicing Rights (MSR), separately from the note ownership.
The owner of the loan or MSR may, rather than servicing the loan
itself, hire a vendor-typically called a subservicer-to take on the
servicing duties or aspects of such servicing. MSR owners frequently
sell MSR outright as an asset. Servicing transfers may also occur
through whole loan servicing transfers or whole loan portfolio
transfers, rather than through sales of MSR. In this document, we use
the term ``transfer'' broadly to cover transfers of servicing rights as
well as transfers of servicing responsibilities, in total or in part,
through subservicing or whole loan servicing arrangements. The term
``transferor'' servicer means a servicer who transfers or will transfer
the right to perform servicing functions pursuant to an agreement or
understanding. The term ``transferee'' servicer means a servicer who
obtains or who will obtain the right to perform servicing functions
pursuant to an agreement or understanding.
As consumers do not have a choice with respect to the transfer of
servicing, seamless and accurate transfers are important to prevent
consumer harm. In 2014, the Bureau issued CFPB Bulletin 2014-01.\1\ The
Bulletin discussed the servicing transfer requirements in the
Regulation X mortgage servicing rules.\2\ The Bulletin also addressed
frequently asked questions, the focus areas for Bureau examinations,
and the other Federal consumer financial laws applicable to servicing
transfers.
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\1\ Bulletin 2014-01 was published in the Federal Register as
Compliance Bulletin and Policy Guidance--Mortgage Servicing
Transfers, 79 FR 63295 (Oct. 29, 2014). Bulletin 2014-01 replaced
the earlier Bulletin 2013-01 (Mortgage Servicing Transfers),
released in February 2013, which addressed servicing transfers
before the effective date of 12 CFR 1024.38(a), (b)(4).
\2\ 12 CFR 1024.38(a), (b)(4).
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In supervisory examinations conducted since 2014, the Bureau has
continued to find weaknesses in compliance management systems and
violations of Regulation X related to mortgage servicing transfers.\3\
Specifically, the Bureau has seen inadequacies in servicers' policies
and procedures for transferring all the loan information and documents
to the new servicer in a timely and accurate manner. It is also
important that servicing functions continue on an uninterrupted basis
during servicing transfers-such as the payment of taxes and insurance
from escrow accounts or continuing to exercise reasonable diligence in
obtaining documents and information to complete a loss mitigation
application. Recent economic conditions and structural changes to the
mortgage servicing market, including the growth of nonbank servicers
that are not subject to the same capital standards as banks, contribute
to these risks.\4\
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\3\ In addition to the requirements discussed in this bulletin,
State laws and regulations may impose additional requirements
applicable to servicers.
\4\ See Kim, You Suk, Steven M. Laufer, Karen Pence, Richard
Stanton, and Nancy Wallace. 2018. ``Liquidity Crises in the Mortgage
Market.'' BPEA Conference Draft, Spring, and Goodman, Laurie, and
Karan Kaul. 2016. ``Nonbank Servicer Regulation: New Capital and
Liquidity Requirements Don't Offer Enough Loss Protection'' Urban
Institute Brief.
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Taking into consideration the coronavirus pandemic that led to the
President's declaration of a national emergency on March 13, 2020
(National Emergency), and the economic and social dislocations caused
by the pandemic, for the duration of the National Emergency and for 120
days thereafter, if a servicing transfer is requested or required by a
Federal regulator or by the security issuer of ``Government Loans'' (as
defined in the CARES Act), the Bureau intends, for activity during this
period, to consider the challenges that entities may face as a result,
including operational and time constraints related to the transfer, and
to be sensitive to good-faith efforts demonstrably designed to transfer
the servicing without adverse impact to consumers. The Bureau intends
to focus supervisory feedback for institutions, if needed, on
identifying issues, correcting deficiencies, and ensuring appropriate
remediation to consumers.
[[Page 25282]]
B. General Transfer-Related Policies and Procedures
In its supervisory examinations, the Bureau reviews mortgage
servicers for compliance with Regulation X servicing transfer
requirements, which among other things, require servicers to maintain
certain policies and procedures related to facilitating the transfer of
information during mortgage servicing transfers.\5\ Specifically,
Regulation X requires transferor servicers to maintain policies and
procedures that are reasonably designed to achieve the objective of the
timely transfer of all information and documents in the possession or
control of the servicer relating to a transferred mortgage loan to a
transferee servicer in a form and manner that ensures the accuracy of
the information and documents transferred and that enables a transferee
servicer to comply with the terms of the transferee servicer's
obligations to the owner or assignee of the mortgage loan and
applicable law.\6\
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\5\ ``Small servicers'' as defined in Regulation Z, 12 CFR
1026.41(e)(4), do not have to comply with the policies and
procedures requirements described in this Bulletin. Regulation X, 12
CFR 1024.30(b)(1).
\6\ 12 CFR 1024.38(b)(4)(i). 12 CFR 1024.38(b)(4) does not
prescribe any specific policies or procedures that a servicer must
implement; the rule says that the policies and procedures must be
``reasonably designed'' to achieve the goal of facilitating the
transfer of information during servicing transfers. The Bureau will
consider a servicer's transfer-related policies and procedures as a
whole, in light of the servicer's particular facts and
circumstances, in determining whether they are reasonably designed
to achieve the rule's objectives. Title 12 CFR part 1024, Supplement
I, Comment 38(a)-1 also states that a servicer may determine the
specific policies and procedures it will adopt and the methods by
which it will implement those policies and procedures so long as
they are reasonably designed to achieve the objectives set forth in
Sec. 1024.38(b). And a servicer has flexibility to determine such
policies and procedures and methods in light of the size, nature,
and scope of the servicer's operations, including, for example, the
volume and aggregate unpaid principal balance of mortgage loans
serviced, the credit quality, including the default risk, of the
mortgage loans serviced, and the servicer's history of consumer
complaints.
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Regulation X also requires transferee servicers to maintain
policies and procedures that are reasonably designed to ensure that the
servicer can identify necessary documents or information that may not
have been transferred by a transferor servicer and obtain such
documents from the transferor servicer.\7\ The following are examples
of servicer practices that the Bureau may consider as contributing to
policies and procedures that are reasonably designed to achieve the
objectives of these transfer requirements:
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\7\ 12 CFR 1024.38(b)(4)(ii).
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Planning and Pre-Transfer Testing
For each transfer of mortgage servicing that occurs,
developing a servicing transfer plan that includes a communications
plan, testing plan (for system conversion), a timeline with key
milestones and an escalation plan for potential problems.
Conducting meetings to discuss and clarify issues with
counterparties in a timely manner; for large transfers, this could
occur months in advance of the transfer for the purposes of developing
transfer plans and the obligations of all involved parties, including
service providers and investors.
Recognizing if the transfer cannot be implemented
successfully in a single batch of all accounts and implementing
alternative protocols, such as splitting the transfer into several
smaller bundles of accounts to be transferred in subsequent months to
ensure that the transferee can comply with its servicing obligations
for every loan transferred.
Determining servicing responsibilities for legacy accounts
including tax reporting, credit bureau reporting and other questions
that may arise.
Using tailored testing protocols to evaluate the
compatibility of the transferred data with the transferee servicer's
systems and data mapping protocols.
Proactively identifying material issues that potentially
impact the accuracy or completeness of the loan data or documentation
to be transferred as well as each servicer's ability to comply with the
law or investor guidelines with respect to the transferred loans.
Identifying any loans in default, active foreclosure and
bankruptcy. Where applicable, include documentation regarding loss
mitigation activity for each loan, including status and notes
pertaining to the loss mitigation action, copies of agreements entered
into with a borrower on a loss mitigation option, and any analysis by a
servicer with respect to potential recovery from a non-performing
mortgage loan.
Engaging in quality control work after a transfer of
preliminary data to validate that the data on the transferee's system
matches the data submitted by the transferor. Prioritizing data mapping
errors that occurred during de-boarding or on-boarding process for
resolution.
Post-Transfer Monitoring
Conducting a post-transfer review or de-brief to determine
effectiveness of the transfer plan and whether any gaps have arisen
that require resolution.
Monitoring consumer complaints and loss mitigation
performance metrics including borrower engagement rate, approvals of
trial modifications, repayment plans, non-home retention options, and
completed workouts for at least four to six months post-transfer. Also
monitoring for delinquencies, foreclosures and bankruptcies to detect
trends, including for month-to-month increases after transfer.
As the composition and complexity of servicer portfolios vary,
servicers may not need to implement all the example policies and
procedures listed above in order to meet the objectives outlined in
Regulation X. However, the Bureau emphasizes the importance of post-
transfer monitoring to ensure that transferred data is complete,
accurate and functional for the transferee. For example, the Bureau
found at least one servicer that did not engage in adequate post-
transfer validation with its transferee, which contributed to its
failure to identify that it had not transmitted all the loss mitigation
documents in its possession. Only after a borrower complained to the
transferee did either servicer become aware that the transferor failed
to send an executed loan modification agreement to the transferee.\8\
Generally, transferees must have policies and procedures reasonably
designed to ensure, in connection with a servicing transfer, that the
transferee receives copies of any loss mitigation applications and
agreements, finds out about the status of any prior discussions with
borrowers, and retrieves missing loss mitigation documents and
information from the transferor servicer before asking the borrower for
such information.\9\ These obligations apply to any accounts for which
the servicer's determination of the borrower's eligibility for loss
mitigation is in process, including any short-term payment forbearance
program or a short-term repayment plan that the servicer may offer
based on an evaluation of an incomplete loss mitigation
application.\10\
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\8\ The Bureau published supervisory findings related to
mortgage servicing transfers in the June 2016 edition of Supervisory
Highlights, available here: https://files.consumerfinance.gov/f/documents/Mortgage_Servicing_Supervisory_Highlights_11_Final_web_.pdf.
\9\ Comment 38(b)(4)(ii)-1.
\10\ See 12 CFR 1024.41(c)(2)(iii) (describing requirements for
servicers offering certain short-term loss mitigation options based
on an evaluation of an incomplete loss mitigation application); see
also comments 41(b)(1)-4.iii and 41(c)(2)(iii).
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The Bureau also emphasizes the importance of maintaining the
transferred data after receipt. Under Regulation X, servicers must
maintain certain documents and data on each
[[Page 25283]]
mortgage loan account serviced by the servicer in a manner that
facilitates compiling such documents and data into a servicing file
within five days.\11\ A servicing file includes, among other things, a
schedule of all transactions credited or debited to the mortgage loan
account (including to any escrow or suspense account), a copy of the
security instrument, copies of any loan modifications, any notes
created by servicer personnel reflecting communications with the
borrower about the mortgage loan account, and to the extent applicable,
a report of the data fields relating to the borrower's mortgage loan
account.\12\ Transferors must also retain records that document actions
taken with respect to a borrower's mortgage loan account until one year
after the date a mortgage loan is discharged or servicing of a mortgage
loan is transferred by the servicer to a transferee servicer.\13\ The
Bureau encourages servicers to adopt strong policies and procedures for
maintaining documents and information received in a transfer as part of
an overall compliance program.
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\11\ 12 CFR 1024.38(c)(2).
\12\ 12 CFR 1024.38(c)(2)(i) through (v).
\13\ 12 CFR 1024.38(c)(1).
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C. Loan Information and Documents To Be Transferred or Received
Regulation X requires transferor servicers to maintain policies and
procedures that are reasonably designed to achieve the objectives of
timely transferring all information and documents in the possession or
control of the servicer relating to a transferred mortgage loan to a
transferee servicer in a form and manner that:
Ensures the accuracy of the information and documents
transferred, and
Enables a transferee servicer to comply with the terms of
the transferee servicer's obligations to the owner or assignee of the
mortgage loan and applicable law.\14\
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\14\ 12 CFR 1024.38(b)(4)(i).
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Use of a uniform data standard like the Mortgage Industry Standards
Maintenance Organization (MISMO) standard would increase data
compatibility and strengthen compliance across the servicing industry
by fostering more consistency in the data fields used by servicers. The
Bureau encourages servicers to adopt a common data standard and data
dictionary to facilitate these goals.
Other practices that could contribute to compliance include having
contracts that require transferors to provide all the necessary
information and documents at loan boarding to a transferee servicer's
systems. Necessary information and documents could include foundational
information for servicing the loan, but not limited to, a unique
identifier for each loan, the terms of the loan (including the rate and
term), current unpaid principal balance (UPB) as of a specific date,
information concerning any escrow accounts (including balances,
distribution history, and future obligations), payment histories, the
terms of any loss mitigation that was offered to a borrower under which
the borrower is performing, and any other modifications or other
information needed to adequately service the loan.
Certain information and documents present heightened compliance
risk. For example, failure to transfer private mortgage insurance
cancellation and mid-point dates may contribute to violations of the
Homeowners Protection Act.\15\ Likewise, loss mitigation-related
documents, including incomplete applications and executed modification
agreements are critical for compliance. Regulation X requires
transferor servicers to maintain policies and procedures with respect
to the transfer of any information reflecting the current status of
discussions with a borrower regarding loss mitigation options, any
agreements entered into with a borrower on a loss mitigation option,
and any analysis done with respect to potential recovery from a non-
performing mortgage loan, as appropriate.\16\ Because borrowers may
continue to provide loss mitigation-related documents and information
to the transferor servicer after their loans have transferred,
transferors must work with transferees to ensure that the new
information and documents are transferred and that borrowers are not
adversely affected.\17\ A borrower that submits a facially complete or
complete application to the transferor servicer after the transfer date
has the same rights and protections that would have applied if the
borrower had submitted the complete application to the transferee
servicer.\18\ An application that was facially complete under Sec.
1024.41(c)(2)(iv) with respect to the transferor servicer remains
facially complete under the transferee servicer as of the date it was
facially complete with respect to the transferor servicer. And if an
application was complete with respect to the transferor servicer, but
is not complete with respect to the transferee servicer, the transferee
servicer must treat the application as facially complete as of the date
the application was complete with respect to the transferor
servicer.\19\
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\15\ See CFPB Bulletin 2015-03. ``Compliance Bulletin: Private
Mortgage Insurance Cancellation and Termination''.
\16\ Comment 38(b)(4)(i)-2.
\17\ See Amendments to the 2013 Mortgage Rules Under the Real
Estate Settlement Procedures Act (Regulation X) and the Truth in
Lending Act (Regulation Z), 81 FR 72160, 72273-76 (Oct. 19, 2016);
comments 38(b)(4)(i)-2 and 41(k)(1)(i)-1.iii.
\18\ See 12 CFR 1024.41(k)(1)(i); Comment 41(k)(1)(i)-2.
\19\ Comment 41(k)(1)(i)-2.
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Appendix A provides examples of information and documents grouped
by subject area which the Bureau intends to use to assess compliance
with Regulation X. The appendix is provided as a guide and focuses on
common data elements essential to the servicing of mortgage loans.
Servicers may use the appendix to assess the baseline appropriateness
of their transfer-related policies and procedures. Some listed
documents and information may be not applicable to certain loans. Other
loans may require documents and information not listed in Appendix A.
The overall composition and complexity of a servicer's portfolio is
important in determining whether its policies and procedures meet the
objectives outlined in Regulation X. For example, servicers with very
few adjustable rate mortgages might have relatively simple policies and
procedures for ensuring documents and information related to interest
rate adjustments are timely transferred and accounted for. And
servicers with large default portfolios might have robust policies and
procedures for ensuring that loss mitigation documents and information
pertaining to defaulted accounts are timely transferred.
Regulatory Requirements
This Bulletin is a non-binding general statement of policy
articulating considerations relevant to the Bureau's exercise of its
supervisory authority under Regulation X and RESPA and reciting certain
requirements of Regulation X and other Federal consumer financial laws
applicable to servicing transfers. It is therefore exempt from the
notice and comment rulemaking requirements under the Administrative
Procedure Act pursuant to 5 U.S.C. 553(b).\20\ Because no notice of
proposed rulemaking is required, the Regulatory Flexibility Act does
not require an initial or final regulatory flexibility analysis. 5
U.S.C. 603(a), 604(a). The Bureau has determined that this Bulletin
does not impose any new or revise any existing recordkeeping,
reporting, or disclosure requirements on
[[Page 25284]]
covered entities or members of the public that would be collections of
information requiring OMB approval under the Paperwork Reduction Act,
44 U.S.C. 3501 et seq.
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\20\ However, this is not a ``statement of policy'' as that term
is specifically used in Regulation X, 12 CFR 1024.4(a)(1)(ii).
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Pursuant to the Congressional Review Act, 5 U.S.C. 801 et seq., the
Bureau will submit a report containing this Bulletin and other required
information to the United States Senate, the United States House of
Representatives, and the Comptroller General of the United States prior
to its applicability date. The Office of Information and Regulatory
Affairs has designated this Bulletin as not a ``major rule'' as defined
by 5 U.S.C. 804(2).
Appendix A--Examples of Information and Data To Be Transferred or
Received 21
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\21\ This is not an exhaustive list of documents and information
that may be necessary for the transfer.
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I. Foundational Loan Information
Name and version of servicing systems of record for each
product type serviced
Loan number and MIN
Principal balance
[cir] Original principal balance
[cir] Modified principal balance
Periodic payment due
[cir] Amount of interest due
[cir] Amount of principal due
[cir] Next payment due date
[cir] Amount of any overdue payment
Amount of any principal prepayments
Amount of funds in suspense account
Balloon payment data
Origination date
Property address
Borrower mailing address
Name of originator, NMLS ID if available
Original loan to value
Purchase loan/refinance
Loan term
Maturity date
Successor-in-interest
[cir] If yes
[cir] Address and identity
[cir] Confirmed?
Occupancy code (i.e. primary residence, second home,
investment property)
Interest rate
Interest calculation method (i.e. 30/360, DSI)
ARM loan
[cir] Index
[cir] Margin
[cir] Next change date
Loan Type
[cir] FHA
[cir] VA
[cir] USDA
[cir] Conventional
[cir] State bond program
Fees owed and whether reimbursable/collectible from borrower
or investor
[cir] Late fees
[cir] Broker price opinion fees owed
[cir] Property inspection fees owed
[cir] Attorney fees owed
[cir] Publication fees owed
[cir] Fees owed for copies of documents
[cir] Corporate advances owed
[cir] Prior bankruptcy
[ssquf] Discharge date
[ssquf] Dismissal date
II. Investor Information
Name
Contact Information
Disbursement Information
Reporting Requirements
Remittance type (Scheduled/scheduled, scheduled/actual,
actual/actual)
III. Escrow Accounts
Amount of escrow payment due with periodic payment
Date of last escrow analysis
Tax agency code for each applicable agency
Date of last tax payment to local agency
Estimated total tax payments for next cycle
Next tax due date(s)
Parcel number (if multiple parcels include all)
Date of last insurance payment
Identity of insurer
Confirmation of proof of adequate insurance received
Historic escrow records (to address borrower questions and
disputes)
Tax service contracts that will stay in effect
For any items paid from the escrow account other than taxes or
insurance,
[cir] Identity of the payee
[cir] Due date(s) of payment
[cir] Date of last payment and date of next payment
[cir] Estimated payments for the next cycle, and other information
necessary to maintain payment of such item pursuant to the escrow
account agreement.
IV. Private Mortgage Insurance
Amount last paid
Name and address of insurer
Amount due
Date due
Original value of the property
The date based on amortization schedule(s) when a borrower may
request cancellation
Date on which monthly premiums are no longer required for 78%
loan to original value
Date on which monthly premiums are no longer required based on
loan midpoint
V. FHA Insurance
MIP amount
MIP last paid
MIP due
MIP due date
Loan origination date
Loan term
Partial claim amount, if any
FHA case number assignment date
MIP cancellation date based on original amortization
VI. Hazard Insurance/Flood Insurance
Policy numbers
Name and address of insurer (voluntary and lender placed)
Expiration/renewal date(s)
Premium amount(s)
Frequency of payment
Coverage levels
Original value of property
Flood zone determination certificate
Prior completed insurance claims
Open insurance claims
[cir] Claim amount
[cir] Loss draft funds held
[cir] Inspection dates and completion estimates
VII. Loss Mitigation (Including Short-Term Options)
Current status of discussions with a borrower on a loss
mitigation option
Any agreements made with a borrower on a loss mitigation
option
Any analysis by a servicer with respect to potential recovery
from a non-performing mortgage loan
Copies of complete and incomplete loss mitigation
application(s) and information and documents submitted in conjunction
with the application, including acknowledgment notices and denial
notices
[cir] Date of forbearance, modification or other loss mitigation
option
[cir] New loan amount
[cir] New payment amount (show Principal and Interest as well as
taxes and insurance, if applicable.)
[cir] Term
[cir] Due date of plan
[cir] Denial date
[cir] Denial reason
[cir] New gross modification amount
[cir] Modified appraisal value
VIII. Foreclosure
Status of foreclosure
Date referred to attorney
Attorney name and contact information
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Publication date
Anticipated or scheduled sale date
All time line step and events
Borrower contact information
All phones numbers on file
Email addresses for all borrowers
IX. Bankruptcy
Notice of bankruptcy/court and case number
Bankruptcy chapter and filing date
Status of case
Proof of Claim filing date
Next prepetition and post-petition payment due dates
Motion for Relief filing date
Plan conversion date, if applicable
Attorney acknowledgement of bankruptcy
Other bankruptcy documents
X. Signing Authority
The Director of the Bureau, having reviewed and approved this
document is delegating the authority to electronically sign this
document to Laura Galban, a Bureau Federal Register Liaison, for
purposes of publication in the Federal Register.
Dated: April 24, 2020.
Laura Galban,
Federal Register Liaison, Bureau of Consumer Financial Protection.
[FR Doc. 2020-09151 Filed 4-30-20; 8:45 am]
BILLING CODE 4810-AM-P
