Get Ready for CFPB Periodic Statements
Servicers, sharpen your pencils: now is the time to gather resources for development and deployment with regard to bankruptcy periodic statements. While compliance with the Consumer Financial Protection Bureau (CFPB or Bureau) mandate is not required until April 10, 2018, the reality is that the rollout should occur well-before that deadline. There are still many unanswered questions and further CFPB clarification is unlikely. The industry will have to rely on logic and reason, as well as prior holdings to formulate statements and implement policies and procedures that will (hopefully) ensure the highest likelihood of consistent compliance.
A small contingent of mortgage creditor representatives met …