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CFPB Winter 2020 Supervisory Highlights

The CFPB has published issue 21 (Winter 2020) of its Supervisory Highlights, reporting examination findings in the areas of debt collection, mortgage servicing, payday lending, and student loan servicing that were completed between April 2019 and August 2019. These observations were reported:

  • Debt collection
    • Failure to disclose in subsequent communications that communication is from a debt collector
    • Failure to send notice of debt
  • Mortgage servicing
    • Loss mitigation notice violations
  • Payday lending
    • Failing to apply borrowers’ payments to their loans
    • Inaccurate disclosure of annual percentage rate
    • Failure to include a fee in calculation of finance charge and annual percentage rate
    • Failure to retain evidence of compliance with Regulation Z
    • Adverse action notices that failed to disclose the principal reason(s) for the adverse action
    • Unfair imposition of unauthorized and undisclosed fee
  • Student loan servicing
    • Inaccurate monthly payment amounts after servicing transfer

As for the loss mitigation notice violations found in exams of mortgage servicers, the Bureau noted that several such problems followed on the heels of major natural disasters that prompted much larger volumes of assistance requests, and no "matters requiring attention" were issued.

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