Federal and New York Regulatory Update

Federal and New York Regulatory Update

Federal and New York Regulatory Update

The Bureau of Consumer Financial Protection (“CFPB”) published a bulletin regarding mortgage servicing.  The New York Department of Financial Services (“DFS”) extended emergency regulations related to mortgage servicing.

 

CFPB Bulletin and Policy Guidance (effective October 23, 2014)

 

On August 19, 2014, the CFPB issued a compliance bulletin and policy guidance addressing mortgage servicing transfers to residential mortgage servicers and subservicers in light of potential risks to homeowners that may arise in connection with transfers of mortgage servicing rights.  We reported on Bulletin 2014-01 on August 21st but at that time, the effective date had not yet been published.

 

Bulletin 2014-01 was published in the Federal Register and became effective on October 23, 2014.

 

NEW YORK EMERGENCY RULES PART 418 AND SUPERVISORY PROCEDURES MB 109 AND 110

 

Our July 21, 2009, October 27, 2009, January 25, 2010, March 22, 2010, August 10, 2010, December 16, 2010, March 24, 2011, June 30, 2011, September 29, 2011, January 25, 2012, April 11, 2012, July 11, 2012, October 17, 2012, April 1, 2013, June 20, 2013, November 12, 2013, January 8, 2014, March 24, 2014, and July 16, 2014 Compliance Memoranda discussed Emergency Regulations issued by the DFS addressing mortgage loan originator licensing and application requirements and mortgage loan servicer registration and financial responsibility requirements.  The DFS recently extended all of the Emergency Regulations effective August 25, 2014, with an expiration date of November 24, 2014.

 


NEW YORK EMERGENCY RULES PART 419 

 

Our August 23, 2010, December 8, 2010, March 24, 2011, May 20, 2011, August 23, 2011, November 18, 2011, January 25, 2012, May 8, 2012, August 15, 2012, December 3, 2012, January 17, 2013, May 7, 2013, July 19, 2013, November 12, 2013, January 8, 2014, April 15, 2014, and July 16, 2014 Compliance Memoranda discussed New York Emergency Regulations addressing the servicing of mortgage loans, which were effective October 1, 2010, November 1, 2010, February 1, 2011, May 2, 2011, July 22, 2011, October 20, 2011, January 17, 2012, April 17, 2012, July 12, 2012, October 7, 2012, December 13, 2012, June 26, 2013, September 15, 2013, December 19, 2013, and May 28, 2014 respectively.  The DFS recently extended the Emergency Regulations effective September 11, 2014, with an expiration date of December 8, 2014.