On Friday, January 10, 2014, the Consumer Financial Protection Bureau (“CFPB”) published updates to its mortgage origination exam procedures and mortgage servicing exam procedures. It is no coincidence that the exam procedures were published on the effective date of the new mortgage regulations. Financial institutions should review the examination manuals and identify what, if any, steps are missing from their origination and servicing procedures and internal rules.
Although the CFPB has signaled that it will look for good faith compliance efforts during the first few months post-effective date, additional rules and updates will be forthcoming from the CFPB, and it is important for financial institutions not to get behind. To the extent that questions arise as your institution implements its procedures, please contact Spilman or other knowledgeable counsel.