Regulatory Alert Examines CFPB Mortgage Service Rules | 2021-07-27



NCUA issued a regulatory warning (21-RA-08) this week on the final rule of Regulation X by the Bureau of Consumer Financial Protection on June 30 to help borrowers affected by the pandemic. The latter rule applies only to servicing companies serving mortgages secured by the borrower’s primary residence and does not apply to small servicing organizations.

The rule takes effect August 31, and the NCUA is urging credit unions to “completely rethink the rule and enforce these temporary amendments.”


  • Defines the difficulties associated with COVID-19 as “financial difficulties directly or indirectly related to the emergency in the country in connection with the COVID-19 pandemic, declared in Proclamation 9994 on March 13, 2020.”
  • Temporarily modifies real-time early intervention messages and reasonable due diligence obligations.
  • Authorizes service centers to offer loan modifications to borrowers experiencing difficulties with COVID-19 based on an assessment of an incomplete application when the specified criteria are met.
  • Establishes temporary special procedural measures to reduce losses from COVID-19 so that the borrower has a real opportunity to use mitigation options.


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