No paper coupon books allowed

Posted By: Cloud9

No paper coupon books allowed - 08/20/12 06:32 PM

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?
Posted By: Tater

Re: No paper coupon books allowed - 08/20/12 06:34 PM

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?
Posted By: John Burnett

Re: No paper coupon books allowed - 08/20/12 06:39 PM

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.
Posted By: straw

Re: No paper coupon books allowed - 08/20/12 06:39 PM

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.
Posted By: John Burnett

Re: No paper coupon books allowed - 08/20/12 06:50 PM

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.
Posted By: Bat21

Re: No paper coupon books allowed - 10/11/12 02:24 AM

When does these rules have to be put in to play?
Posted By: Dani York, CRCM

Re: No paper coupon books allowed - 10/11/12 01:27 PM

They have to finalize it first.
Posted By: Reads Regs

Re: No paper coupon books allowed - 10/11/12 02:24 PM

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.
Posted By: Bat21

Re: No paper coupon books allowed - 10/16/12 03:57 PM

thanks