WASHINGTON (3/1/16)--The Credit Union National Association was in attendance Monday at a discussion about the Consumer Financial Protection Bureau (CFPB) regarding its “successors-in-interest” proposal. The CFPB first proposed changes to the rule in December 2014, and CUNA expressed a number of concerns in its March 2015 comment letter, but no rule has been finalized.
Approximately 15 trade associations, and roughly 20 others, were at the mortgage servicing roundtable Monday.
Successors in interest are defined as individuals who inherit or receive property when there is still an outstanding mortgage loan on the property. The CFPB’s proposed changes would:
CUNA believes this will likely cause operational challenges for servicers, particularly with regard to accurately confirming the status of a successor in interest. It asked the bureau to help mitigate the impact of these changes by laying out a process by which servicers can and should identify and communicate with successors in interest.
Compliance with such a process should afford servicers a safe harbor under the rule, CUNA believes.