CFPB Servicing Assessments
The Consumer Financial Protection Bureau (CFPB) is taking an aggressive stand on servicer compliance with existing federal consumer financial laws and the new servicing-related rules that became effective January 10, 2014. Since the CFPB implementation, Servicers have seen an increased level of scrutiny on their servicing practices with substantial monetary fines, servicing restrictions, and negative publicity at risk.
In response to this new regulatory environment, Stewart Lender Services has developed a comprehensive CFPB Servicing Assessment to determine if mortgage servicers are in compliance with existing regulations and adequately prepared for the new CFPB rules. The CFPB Servicing Assessment will also assist servicers who need to remediate compliance deficiencies identified before or after a CFPB audit.
Having the assessment performed by an independent team of compliance experts demonstrates to regulators that the servicers are working in good faith to ensure compliance. The assessment can also help servicers reduce risk to their reputation from undetected compliance issues.
CFPB examiners will focus on nine specific modules within mortgage servicing:
- Servicing transfers, loan ownership transfers, and escrow disclosures
- Payment processing and account maintenance
- Customer inquiries and complaints
- Maintenance of escrow accounts and insurance products
- Credit reporting
- Information sharing and privacy
- Collections and accounts in bankruptcy
- Loss mitigation
We offer several types of CFPB Servicing Assessments: policy and procedure review, compliance management system evaluation, loan-level review, and servicer performance management. These assessments can be performed independently or in conjunction with one another. The servicer can determine the depth and breadth of the assessment in order to satisfy the organization’s risk tolerance and budget constraints.
We produce a comprehensive report summarizing the findings of the assessment. Our compliance experts identify any deficiencies in the servicer’s operations relative to the minimum regulatory requirements of the nine CFPB exam modules. These reports contain findings and observations, an assessment of risks categorized by module, and recommendations to remediate the compliance deficiencies. The CFPB readiness report enables the servicer to evaluate its readiness for CFPB audits, and document its pursuit of “Responsible Business Conduct” to regulators.
You can have complete confidence in our experience in mortgage servicing and our understanding of the CFPB requirements.
All services and products referenced herein are offered by or through a member of the Stewart family of companies, as applicable, and may vary by state or local jurisdiction. The statements herein are not a representation that services or products are being offered or performed by Stewart Lender Services or any particular Stewart company. Where applicable, all services and products are performed and produced by an entity fully licensed to do so.