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#1732868 - 08/20/12 06:32 PM No paper coupon books allowed
Cloud9 Offline
100 Club
Joined: Jul 2008
Posts: 205
One of our employees recently returned from a FIS seminar in which they were told on residential real estate loans that we are no longer allowed to use paper coupon books and only paper bills monthly. I can't find the source of this anywhere. Does anyone know what this is?

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#1732869 - 08/20/12 06:34 PM Re: No paper coupon books allowed Cloud9
Tater Offline
Platinum Poster
Joined: Jan 2006
Posts: 627
Missouri
I've heard something about this being part of a proposal that is pending but hadn't heard it as a final rule yet. It's a rule not worth enacting in my opinion but I thought it was open for comment or at the very least still in the formative stages.

If you find a citation, will you PM me?
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#1732875 - 08/20/12 06:39 PM Re: No paper coupon books allowed Cloud9
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Misinformation, I imagine. The CFPB has just published a proposed rule that would mandate specific content and arrangement for periodic mortgage billing, but the accompanying information says "The periodic statement requirement generally would not apply for fixed-rate loans if the servicer provides a coupon book, so long as the coupon book contains certain information specified in the rule and certain other information is made available to the consumer. The proposal also includes an exception for small servicers that service 1000 or fewer mortgage loans and service only mortgage loans that they originated or own."

Note that the exception for coupon-book servicers only applies to fixed-rate loans.
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#1732876 - 08/20/12 06:39 PM Re: No paper coupon books allowed Cloud9
straw Offline
Power Poster
straw
Joined: Nov 2002
Posts: 9,121
From my recollection, new servicing rule allows you to still use coupon books, but you need to provide the same information in your coupon book that you do in a periodic statement.

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#1732883 - 08/20/12 06:50 PM Re: No paper coupon books allowed Cloud9
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
Some of the dynamic information that would be included on a periodic statement won't have to be included in a coupon book, but would have to be made available for the consumer's asking.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1748328 - 10/11/12 02:24 AM Re: No paper coupon books allowed Cloud9
Bat21 Offline
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Joined: Aug 2007
Posts: 176
When does these rules have to be put in to play?

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#1748368 - 10/11/12 01:27 PM Re: No paper coupon books allowed Cloud9
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
They have to finalize it first.
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#1748415 - 10/11/12 02:24 PM Re: No paper coupon books allowed Bat21
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,292
For the mortgage servicing proposals, the final rules have to be out by 1/21/13. They can be effective up to one year after the final rule is issued. If no final rules are issued by 1/21/13, the provisions take effect on 1/21/13. Search the proposed rule for "January 21, 2013" and you'll see various discussions. The CFPB is soliciting public comment on how much time will be needed to comply.
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#1749564 - 10/16/12 03:57 PM Re: No paper coupon books allowed Cloud9
Bat21 Offline
100 Club
Joined: Aug 2007
Posts: 176
thanks

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