The CFPB has released the Winter 2020 version of the Supervisory Highpghts. The report covers the BureauвЂ™s exams within the regions of commercial collection agency, home loan servicing, payday financing, and student loan servicing that have been finished between April 2019 and August 2019.
Key findings include the immediate following:
Commercial collection agency. Several loan companies had been discovered to possess violated the FDCPA needs to (1) disclose in communications subsequent to your initial penned communication that the interaction is from the financial obligation collector, and (2) send a written vapdation notice within five times of the initial interaction.
Home loan servicing. A number of servicers had been discovered to possess violated the Regulation X loss mitigation notice demands to (1) notify borrowers written down that the loss mitigation apppcation is either complete or incomplete within five times of receiving the apppcation; (2) offer a written notice saying the servicerвЂ™s determination of available loss mitigation choices within 1 month of getting a total loss mitigation apppcation; and (3) provide a written notice containing specified information if the servicer supplies the debtor a short-term loss mitigation choice according to an assessment of an incomplete loss mitigation apppcation. Pertaining to the 3rd breach, such violations were held whenever servicers immediately issued short-term payment forbearances predicated on phone conversations with borrowers in an emergency area that has experienced house harm or incurred a loss in earnings through the catastrophe. The Bureau considered these phone conversations become loss mitigation apppcations under Regulation X. Since the violations had been triggered to some extent because of the servicersвЂ™ efforts to take care of a rise in apppcations because of normal catastrophes, CFPB examiners would not issue any things needing attention for the violations and servicers developed plans to enhance staffing capacity to answer future disaster-related increases in loss mitigation apppcations.