On April 30, 2014, the Consumer Financial Protection Bureau (CFPB) announced proposed minor changes to mortgage rules. The modifications include provisions primarily to address the impact of the new origination and servicing rules on non-profit housing providers, which include:

  • Offering an alternate definition for small servicer to allow certain 501(c)(3) non-profit organizations exemption from some of the servicing rules.
  • Tailoring provisions so certain 501(c)(3) non-profit organizations, such as Habitat for Humanity, can make interest-free forgivable loans without regard to the 200 mortgage loan limit
  • Providing a limited, post-closing cure mechanism for loans originated with a good faith expectation as qualified mortgages, but actually exceed the 3 percent points and fees limit.

The CFPB is seeking your comments on these proposed amendments before June 5, 2014.

In addition, the CFPB is seeking comments on additional mortgage lending topics:

  • If a post-consummation correction for loans originated with a good faith expectation as qualified mortgages, but exceed the 43 percent debt-to-income ratio should take place and how.
  • Feedback from smaller creditors as to how their operation and originations have been impacted by certain new mortgage rules.

Comments on the above items must be received July 5, 2014.

How To Submit Comments

To submit your comments on mortgage two ways

  1. Electronically at www.regulations.gov.
  2. Mail or Hand Delivered to Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552.

If you have questions about how this could impact your mortgage servicing operations, contact our compliance specialists in Michigan, Houston or Ft. Lauderdale.