MBA Letter to the CFPB on the CFPB’s Regulation X
MBA welcomes the opportunity to comment on the Consumer Financial Protection Bureau's (the Bureau) notice of proposed rulemaking (NPRM) Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties (the Proposal). The Proposal significantly changes the mortgage servicing provisions of Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA), and discusses new possible obligations for serving borrowers with limited English proficiency. While we appreciate the Bureau's decision to modernize Regulation X's loss mitigation framework to align with existing practices, the Bureau should amend the Proposal to motivate borrowers to contact their servicers and pursue loss mitigation assistance as early in the delinquency as possible.