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#2256273 - 07/02/21 05:06 PM Recent Regulatory Changes
Compliance504 Offline
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Joined: Dec 2008
Posts: 694
Tennessee
I'm preparing a report which includes Regulatory Updates for 2nd Qtr.....with all the issuances surrounding mortgage servicing and debt collection due to COVID....I've gotten a little lost.....

The Reg X Mortgaging Rule issued on 6/28 was the answer to the proposed rules on 4/5 or 4/6....there are no other pending proposed rules...is this correct?

These rules are effective 8/13/21 and small servicers are excluded....we are a small servicer...we should still review and consider this rule.....is this correct?

The Debt Collection Interim Final Rule issued on 4/19 effective 5/3 applied to landlords....we are not a debt collector....so we don't need to be concerned with this rule...is this correct?

The proposed rule to delay the effective date of two rules for Reg F from 11/30 to 1/29 is still outstanding.....we are not a debt collector so these rules do not apply to us....but we should still review and consider these rules....is this correct??

Any guidance on this would be greatly appreciated....

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#2256289 - 07/02/21 07:56 PM Re: Recent Regulatory Changes Compliance504
Compliance504 Offline
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Joined: Dec 2008
Posts: 694
Tennessee
I think I've got this figured out.....

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#2256334 - 07/06/21 07:54 PM Re: Recent Regulatory Changes Compliance504
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,627
Cape Cod
You could be a landlord if you hold any rental property in REO.

Reg X amendments are effective 8/31/21 (not 8/13). While they don't directly affect small servicers, they and the Bureau, with its heavy public relations reach to consumers, set borrower expectations. If you have a lot of loans in some form of forbearance, you better be ready for the tsunami of consumer inquiries as the forbearance agreements approach their end dates.

You have the Reg F amendments right.
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