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CFPB Readiness Assessments

The Consumer Financial Protection Bureau (CFPB) is taking an aggressive stand on servicer compliance – examining servicers’ compliance with existing federal consumer financial laws and in preparation for the new servicing-related rules that are effective January 10, 2014. With the CFPB implementation deadline looming, there is skepticism in the industry that servicers are prepared for a CFPB examination.

In response to these concerns, Stewart Lender Services® (SLS) has developed a comprehensive CFPB Readiness Assessment to determine if mortgage servicers are in compliance with existing regulations and adequately prepared for the new CFPB rules. The CFPB Readiness Assessment will also assist servicers who need to remediate compliance deficiencies before the January 2014 deadline.

Having the assessment performed by an independent team of compliance experts demonstrates to regulators that the servicers are proactively working 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:

Routine 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

Default Servicing

  • Collections and accounts in bankruptcy
  • Loss mitigation

Foreclosure

  • Foreclosures

Stewart Lender Services offers several types of CFPB Readiness 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.

Reporting

SLS produces 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 Stewart Lender Services’ experience in mortgage servicing and our understanding of the CFPB requirements. For more information, contact us today at capitalmarkets@stewart.com or (303) 305-4025.