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Oh what a year it has been in the mortgage servicing world! In 2020, our COVID-19 Compliance Roundtable met weekly to discuss emerging compliance issues under the CARES Act, federal agency guidance, state laws and orders, and the many operational hurdles regarding residential mortgage loans that servicers are facing. We’ve summarized the key trends and notable differences in approach that we’ve seen to date:
Credit Reporting
As we close 2020, credit reporting continues to be an area fraught with confusion. It is also likely to be a hot spot for regulatory inquiry and potential litigation in 2021, as the guidance on credit reporting is less than clear and operationally difficult. Six months later, the CFPB’s June 16, 2020, FAQ 10 on credit reporting after the accommodation ends has yet to be cleared up, leaving servicers with uncertainty on how to address post-forbearance defaults that are not cured.