The American Bankers Association has requested “clarification” of mortgage servicing and consumer financial protection rules from the Consumer Financial Protection Bureau (“CFPB”). The Association has written to the Bureau to advise that “legal and regulatory uncertainty” should not be “additional factors that encourage banks to scale back their mortgage servicing activities.” Letter to Ms. Kelly Cochran, Assistant Director for Regulations at the CFPB, from Mr. Robert R. Davis, Executive Vice President for Mortgage Markets, Financial Management & Public Policy at the American Bankers Association, dated October 24, 2014. (This letter is referenced by the CFPB in its call for Comments to Amended 2013 Mortgage Rules Under RESPA, the Real Estate Settlement Procedures Act, and Under the Truth in Lending Act, which you can access here and leave your own comments in response to the Bureau’s invitation. The CFPB's citation of the Association's October 24, 2014 can be found in nn. 70, 299, and 316. The Association’s October 24, 2014 letter is accessible here: Download American Bankers Association Letter Rolling Delinquencies.102414.)
What the American Bankers Association’s letter does not mention is that banks are “scaling back their mortgage servicing activities” because that business is no longer as profitable as it once was.
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