PROPOSED CHANGES TO REGULATIONS X AND Z

Earlier this week the Consumer Financial Protection Bureau published proposed changes to Regulations X (RESPA) and Z (TIL). The proposed changes focus primarily on clarifying, revising, or amending provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and periodic statement requirements under Regulation Z’s servicing provisions. Extensive proposed comment appears on the definition of the term “delinquency” when used, among other purposes, for determining when the first notice regarding foreclosure under section 1024.41(f)(1)(i) may be sent.

The comment period expires 90 days after publication of this proposed rule in the Federal Register. Publication is expected soon.

A copy of the 491-page proposal is available here.

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