The Consumer Financial Protection Bureau today issued policy guidance stating that it does not intend to take supervisory or enforcement action for violations of existing Regulation X or Regulation Z resulting from a servicer’s early compliance with the 2016 final servicing rule for a period of three days before the applicable effective dates.
Certain amendments to the rule will take effect on Thursday, Oct. 19, 2017, while others have a compliance date of Thursday, April 19, 2018. Servicers are prohibited from early adoption of some of the 2016 servicing amendments, which further complicates the midweek compliance deadlines. Under the new policy guidance, servicers would be permitted to implement the new rules the Monday before the Thursday effective date. This will allow servicers to update and test their systems over a weekend rather than over a weeknight.
In addition, the CFPB also announced technical corrections to the rule, including those related to official comments and certain periodic statement sample forms, and the CFPB’s authority citation for Regulation Z.