The Consumer Financial Protection Bureau (CFPB) should focus on the cost and benefit of its Real Estate Settlement Procedures Act (RESPA) servicing rule, CUNA wrote to the bureau. CUNA’s letter came in response to the CFPB’s request for information involving its assessment of the 2013 final rule.
In the letter, CUNA cited a recent report from the Treasury showing the cost to service a performing loan has increased fourfold, from approximately $59 per annum in 2008, to approximately $228 per annum by the first half of 2016.
It also found the cost of servicing a delinquent loan has ballooned from approximately $482 to more than $2,500 per annum over the same period.
“As such, the CFPB’s assessment should focus on whether this increased cost has yielded a justifiable corresponding benefit to consumers,” the letter reads. “Further, the study should focus on the benefit specifically for credit unions who overwhelmingly retain ownership of their mortgages, or alternatively sell their mortgages but retain servicing, and where there has been little, if any, evidence, of systematic pervasive harmful behavior.”
CUNA also offered the following suggestions: