This posting was written by Travis P. Nelson.
Our colleague in the Financial Industry Group, Colleen H. McDonald, recently wrote about a Guidance issued by the Consumer Financial Protection Bureau (CFPB) on mortgage servicing transfers. With the new mortgage servicing rules under the Real Estate Settlement Procedures Act (Regulation X) (RESPA) scheduled to go into effect January 10, 2014, the CFPB’s decision to issue guidance on the existing servicing transfer regulations may have been unexpected by some. However, given the high volume of recent servicing rights transfers, the CFPB determined that the time was right to provide servicers with notice that their policies and procedures on servicing rights transfers will be closely scrutinized. The guidance serves as "advance notice" of what the CFPB’s examiners will be looking for with regard to transfers of mortgage servicing.
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Travis P. Nelson is counsel in the Financial Services Regulatory Group at Reed Smith LLP, resident in the Princeton and New York offices, and a co-leader of the firm’s Financial Institutions Enforcement & Investigations Task Force. Prior to joining Reed Smith, Travis was an Enforcement Counsel with the Office of the Comptroller of the Currency, U.S. Treasury Department, in Washington, D.C. Travis is also adjunct faculty at Villanova University School of Law, and a frequent lecturer at national and regional banking conferences.