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#2077585 - 05/09/16 02:05 PM Notice of Transfer - Disclosure for ACH payments
Compliqueen Offline
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Joined: Feb 2015
Posts: 4
In reviewing the CFPB mortgage servicing exam manual - Module one, one of the questions states:

"Determine whether the servicer takes steps to facilitate the transfer of the consumer’s automated clearing house (ACH) payments in connection with the transfer of servicing rights. For example, determine whether the servicer takes steps, including making disclosures, so that consumers do not inadvertently fail to make a timely mortgage payment or make a double mortgage payment following the transfer"

My question is what kind of disclosure can we provide and where would this disclosure be? Would this typically be included on the Notice of transfer? Does anyone have a sample disclosure they can share?

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#2077973 - 05/10/16 08:41 PM Re: Notice of Transfer - Disclosure for ACH payments Compliqueen
Inspector Offline
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Joined: Apr 2016
Posts: 283
I don't have a specific reference for this but it seems logical that the disclosure that is being referred to is the Notice of transfer and its required contents. Anything outside of this information and the model form would be institution specific information. If you are the institution that is transferring servicing to someone else you probably won't have much specific information that you can provide outside of the notice.

However, if you are taking over the servicing on a loan you may have more specific information you would want to provide in order to facilitate the consumers ability to make payments, such as available ways payments can be made and any costs or timing differences that might be involved.
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