To help bankers as they prepare to comply with the operationally complex “successor-in-interest” provisions of the Consumer Financial Protection Bureau’s servicing rule, the American Bankers Association today released several frequently asked questions addressed by CFPB officials on a recent conference call.
While the CFPB staff answers are unofficial oral guidance and do not constitute official interpretations, they may provide useful context as bankers prepare for these provisions to go into effect on April 19, 2018. Topics include definitions and scope, identifying and communicating with potential successors in interest, handling confirmed successors, various policies and procedures and other legal requirements.
“One of the most significant changes to the servicing rules involves situations where a borrower transfers a legal interest in mortgaged property to a ‘successor in interest,’” wrote ABA VP Krista Shonk in the latest issue of the ABA Banking Journal. “Now is the time for banks to mobilize their change management teams, budget for implementation, allocate staff time and proactively inquire about third-party vendor preparations to comply with the new requirements.”
In addition to the new members-only FAQs, ABA will hold a webinar on June 22 on the successor-in-interest provisions to answer banker questions.
