This document provides a policy for Alston & Bird LLP regarding closed-end servicing disclosures as required by the Consumer Financial Protection Bureau's (CFPB) mortgage servicing rules. The policy outlines requirements for providing adjustment notices when loan rates or payments change, periodic billing statements, and other notices. It establishes roles and responsibilities within the firm to ensure compliance. Appendices provide model disclosure forms and checklists for auditing compliance.
RBI GUIDELINES: CREDIT CONTROL AND OTHER MEASURES FEBRUARY 2003GK Dutta
One Time Settlement (OTS) of Non-Performing Assets (NPAs) of Primary (Urban) Co-operative Banks. We have been receiving representations from the urban co-operative banks and their Federations / Associations for extending the cut-off date for the compromise settlement of NPAs under the One Time Settlement Scheme.
JMFL Home Loans is engaged in the business of providing home loans tailor-made for your every need. Our Goal is to help you acquire your dream home, your own little piece of heaven. We cater even to those home buyers who lack income proofs and also to those who need small home loans. We leverage our superior technological capabilities and our wealth of experience and rich expertise to provide a diverse range of highly customised products and services to home-buyers. https://www.jmfl.com/what-we-do/fund-based-activities/home-loans
RBI GUIDELINES: CREDIT CONTROL AND OTHER MEASURES FEBRUARY 2003GK Dutta
One Time Settlement (OTS) of Non-Performing Assets (NPAs) of Primary (Urban) Co-operative Banks. We have been receiving representations from the urban co-operative banks and their Federations / Associations for extending the cut-off date for the compromise settlement of NPAs under the One Time Settlement Scheme.
JMFL Home Loans is engaged in the business of providing home loans tailor-made for your every need. Our Goal is to help you acquire your dream home, your own little piece of heaven. We cater even to those home buyers who lack income proofs and also to those who need small home loans. We leverage our superior technological capabilities and our wealth of experience and rich expertise to provide a diverse range of highly customised products and services to home-buyers. https://www.jmfl.com/what-we-do/fund-based-activities/home-loans
#Whether GST Applicable on Liquidated Damages? By SN PanigrahiSN Panigrahi, PMP
#Whether GST Applicable on Liquidated Damages? By SN Panigrahi,
Essenpee Business Solutions,
Section 7(1) (d) of the GST Act, 2017,
Advance Ruling on Liquidated damages ("LD")
US$30M LOAN - 12 % Debt Only - CASH OR GOLDNorm Dobson
Facilitation of a loan by a Lender/investor. The Lender/investor would receive 12% interest over a 4-year period.
The loan amount shall be sent through the US LLC.
Option 1: Principal + Interest
Option 2: Principal + Physical Gold
Option 3: Physical Gold
A Non-performing asset (NPA) is defined as a credit facility in respect of which the interest and/or installment of Bond finance principal has remained 'past due' for a specified period of time. NPA is used by financial institutions that refer to loans that are in jeopardy of default.
#Whether GST Applicable on Liquidated Damages? By SN PanigrahiSN Panigrahi, PMP
#Whether GST Applicable on Liquidated Damages? By SN Panigrahi,
Essenpee Business Solutions,
Section 7(1) (d) of the GST Act, 2017,
Advance Ruling on Liquidated damages ("LD")
US$30M LOAN - 12 % Debt Only - CASH OR GOLDNorm Dobson
Facilitation of a loan by a Lender/investor. The Lender/investor would receive 12% interest over a 4-year period.
The loan amount shall be sent through the US LLC.
Option 1: Principal + Interest
Option 2: Principal + Physical Gold
Option 3: Physical Gold
A Non-performing asset (NPA) is defined as a credit facility in respect of which the interest and/or installment of Bond finance principal has remained 'past due' for a specified period of time. NPA is used by financial institutions that refer to loans that are in jeopardy of default.
Auditing A Practical Approach Canadian 2nd Edition Moroney Solutions ManualGalvinee
Full download : https://alibabadownload.com/product/auditing-a-practical-approach-canadian-2nd-edition-moroney-solutions-manual/ Auditing A Practical Approach Canadian 2nd Edition Moroney Solutions Manual
MBA Compliance Essentials Consumer Compliants Resource GuideMBAMortgage
The CFPB made establishing its consumer complaint system a top priority and also made clear that the choice of who will be examined will at least in significant part be "complaint driven." Toward that end, understand how to establish a robust, trackable consumer complaint management system; learn how to interface properly and effectively with the CFPB consumer complaint portal; become familiar with the required responsive timing requirements; and, develop clear and comprehensive policies and procedures.
Accounting and Financial Reporting Update for the Health Care IndustryPYA, P.C.
Recent Financial Accounting Standards Board and Governmental Accounting Standards Board activity related to revenue recognition, leases, and other audit and accounting topics are discussed within this presentation.
What are the best practices for municipal securities issuers to help ensure t...CohenGrigsby
For many years, issuers of municipal securities (bonds, notes or other obligations sold to the public) focused only on primary offering disclosure with respect to such securities. #Catalystmag #PAChamber
Difference Between IASB And FASB conceptual framework Ro'ya Abd Elhafez
This paper clarifies the difference between the conceptual framework issued by IASB and issued by FASB, as many differences between them have been shown.
The following are areas of review that retirement plan
fiduciaries may want to consider when fulfilling their
fiduciary responsibilities. Plan sponsors and plan officials
are encouraged to consult their ERISA counsel for
additional guidance and information.
MBA Compliance Essentials TILA RESPA Integrated Disclosure (TRID) Resource GuideMBAMortgage
The TILA RESPA Integrated Disclosure (TRID) rule represents a sea-change in our industry. Much broader than a set of requirements that bring along new forms, compliance with the new TRID rule demands major systems and business operations changes that extend beyond your company and impact all arrangements with third-party settlement services providers. The deadline for compliance with these new requirements is fast approaching, and will be here on October 3, 2015.
The MBA Compliance Essentials TRID Resource Guide addresses the key areas on which your company needs to be working in order to operationalize these new requirements into your business and ensure compliance by October 3. The Resource Guide covers not only the new Loan Estimate and Closing Disclosure in detail, but also outlines top issues with the rule, and provides a set of model policies and procedures along with checklists for implementation and working with technology providers.
MBA Compliance Essentials Unfair, Deceptive or Abusive Acts or Practices (UDA...MBAMortgage
The MBA Compliance Essentials Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) and FTC Mortgage Acts and Practices Advertising (MAP) Rule Resource Guide™ is intended to serve as a base for the development of your company's policies and procedures in this area.
MBA Compliance Essentials CFPB Exam ManualMBAMortgage
The Consumer Financial Protection Bureau (CFPB) Examination process is expansive and violations can cost your business money and reputation. With many new and previously existing rules to comply with, the process can seem daunting. This nearly 100-page resource guide, written by attorneys seasoned in the examination process, provides an essential background as to what to expect from this process, as well as an overview of what is expected of your Compliance Management System (CMS). Additionally, the guide contains detailed procedures for both mortgage origination and servicing examinations. Finally, the guide includes nearly 40 pages of useful checklists to help ensure that your company is exam ready.
The CFPB Exam Resource Guide, including its practical tools and resources, was developed by Donald C. Lampe, Partner, Financial Services Group, along with other staff at Morrison & Foerster, LLP.
MBA Compliance Essentials Anti-Money Laundering (AML) and Suspicious Activity...MBAMortgage
The MBA Compliance Essentials Anti-Money Laundering (AML) and Suspicious Activity Reports (SAR) Resource Guide™ is intended to serve as a base for the development of your company's policies and procedures in this area.
MBA Compliance Essentials ATR/QM Resource GuideMBAMortgage
This 115-page resource guide which has more than 80 pages dedicated to practical tools and resources was developed by Mitchel H. Kider, Managing Partner, along with other staff at Weiner Brodsky Kider P.C. Learn more at http://www.mbaeducation.org/CE-AbilitytoRepay/QualifiedMortgage.htm
MBA Compliance Essentials: RESPA I Resource GuideMBAMortgage
MBA Compliance Essentials RESPA I Resource Guide addresses RESPA's anti-kickback and fee splitting prohibitions, and provides details on how to meet RESPA's exemption provisions. Learn more here http://www.campusmba.org/ComplianceRESPA.htm
MBA Compliance Essentials: Vendor Management Resource GuideMBAMortgage
The MBA Compliance Essentials Vendor Management Resource Guide™ is a part of the MBA Compliance Essentials Program, which includes deep-dive webinars and comprehensive resource guides to serve as base for the development of your company's policies and procedures in these important areas. This is only a sample purchase the full Resource Guide at www.campusmba.org
The KA Housing - Catalogue - Listing TurkeyListing Turkey
Welcome to KA Housing, a distinguished real estate development nestled in the heart of Eyüpsultan, one of Istanbul’s most promising districts.
Just 10 minutes from the bustling city center, Eyüpsultan offers a serene escape with the convenience of urban living. The direct metro line ensures seamless connectivity to all parts of Istanbul, making it an ideal location for residents who seek both tranquility and vibrancy.
KA Housing boasts unparalleled accessibility, with proximity to Istanbul Airport only 30 minutes away, facilitating easy international travel. Effortless city access is guaranteed by direct metro and transportation links to Istanbul’s cultural and commercial hubs. Quick access to key metro lines connects you to every corner of the city within minutes, making commuting and exploring the city hassle-free.
The development offers luxurious living spaces with a range of unit layouts from 1+1 to 4+1, designed with meticulous attention to detail. Each unit features balconies or terraces, providing stunning vistas of Istanbul and enhancing the living experience. High-quality materials and superior craftsmanship ensure durability and elegance, while sound-proof insulation and high ceilings (2.95 m) offer comfort and sophistication.
Residents of KA Housing enjoy exclusive on-site amenities, including a state-of-the-art gym, outdoor swimming pool, yoga area, and walking paths. Entertainment options abound with a private cinema, children’s playground, and a variety of dining options including a café and restaurant. Security and convenience are paramount with 24/7 security, a dedicated carpark garage, and an IP intercom system.
KA Housing represents a prime investment opportunity with limited availability in a high-demand area, ensuring enduring value and potential for lucrative returns. Homes in this development provide exceptional value without compromising on quality, offering affordable luxury for discerning buyers. The construction is of the highest quality, built to the latest seismic and disaster resistance standards, ensuring safety and resilience.
The community and surroundings of KA Housing are enriched by close proximity to prestigious universities such as Haliç University, Bilgi University, and Istanbul Ticaret University, making it an ideal location for students and academics. The development is adjacent to the Alibeyköy stream leading into the Halic waters, offering serene natural escapes amidst lush greenery. Residents can enjoy the cultural richness of the area, surrounded by historical and cultural landmarks that blend leisure, nature, and culture seamlessly.
https://listingturkey.com/property/the-ka-housing/
Urbanrise Paradise on Earth - Unveiling Unprecedented Luxury in Exquisite Vil...JagadishKR1
Immerse yourself in the epitome of luxury living at Urbanrise Paradise on Earth. These opulent 4 BHK villas, nestled off the prestigious Kanakapura Road in Bangalore, redefine elegance and sophistication. With meticulous craftsmanship, breathtaking design, and unparalleled amenities, Urbanrise Paradise on Earth offers a sanctuary where every moment is infused with luxury and serenity. Experience a life of grandeur and indulgence at this exclusive residential enclave.
500 acres of brilliance await you here at Riverview City which offers modern living, effortless convenience, and a beautiful natural setting. It is a mega township by Magarpatta City in Loni Kalbhor, Pune. Enjoy easy access to work, schools, and fun while experiencing a perfect work-life balance.
Visit - magarpattacity.developerprojects.in
Torun Center Residences Istanbul - Listing TurkeyListing Turkey
THERE IS LIFE IN ITS CENTER!
The most energetic spot of the city that will add utterly different pleasures to your life, with a park that will make Istanbul breathe, delighting indoor and outdoor bistros, cafes, restaurants, the brand-new Food Hall concept, where dozens of unique tastes are served together, market area, cinema, theater, fitness club, SPA and event venue...
All the pleasures that will enrich your lives are awaiting you on the most beautiful side of the city, at Torun Center Residences. In Mecidiyeköy, where the heart of Istanbul beats, business, life and entertainment opportunities are located at the exact center, at Torun Center, the most beautiful side of the city.
Penthouse apartments and different styles of flats from 1 + 1 to 4 + 1, from 100 to 425 square meters in a 42-story residence tower, have been designed for those who want to live in the center of magnificence. Torun Center is the redefinition of a better life with specially landscaped floor gardens, apartment options with private balconies, and automatic glass systems equipped with Trickle Ventilation that offers clean air comfort.
Business and life in the same place
Excellent service
Torun Center has many delightful details, from a swimming pool to sunbathing and resting terrace. With 24/7 concierge services, 24/7 security, valet, technical service, closed-circuit camera system (CCTV), central heating and cooling system, it makes your life easier.
Delightful details
The two-story Torun Center Lounge, with its indoor and outdoor seating areas, children's playroom, private dining and TV lounge, promises unforgettable memories to you and your loved ones with its unique Istanbul view.
Neighboring to the most pleasant square of Istanbul
A few steps from the Torun Center Residences, you can reach the city's most modern city square and open the doors of a quality city life. Torun Center Residences brings together on the same project the long-awaited city life for Istanbul and gourmet restaurants, cafes, gym and SPA, and state-of-the-art cinema and Artı Stage, hosting the most famous plays of the season.
Located at the intersection of alternative public transportation options such as the metro and Metrobus, Torun Center comes to the fore as the most accessible office for both sides of Istanbul. With a central location and rich transportation lines, Torun Center offices make life easier for employees and increase productivity.
Keep Your Home Naturally Cool and Warm Out Change in Seasons
Vinra Construction is a private limited company registered under the ROC. The management has an experience of over 15 years of understanding the needs and delivering apt solutions to the end users We are providing turnkey solutions in construction fields. like Construction, Interior Designing Facility Management, Plantation Management, etc..
Vinra Construction Tech Enabled Company for Eco-Friendly Home Construction
Contact With Vinra for a Greener Future >>> Call us @ 888 4898 765
The SVN® organization shares a portion of their new weekly listings via their SVN Live® Weekly Property Broadcast. Visit https://svn.com/svn-live/ if you would like to attend our weekly call, which we open up to the brokerage community.
Brigade Insignia offers meticulously designed apartments with modern architecture and premium finishes. The project features spacious 3,3.5,4 and 5 BHK units, each thoughtfully planned to provide maximum comfort, natural light, and ventilation.
https://www.newprojectbangalore.com/brigade-insignia-yelahanka-bangalore.html
Sense Levent Kagithane Catalog - Listing TurkeyListing Turkey
Sense Levent offers a luxurious living experience in the heart of Istanbul’s vibrant Levent district.
This cutting-edge development seamlessly integrates modern design with natural elements, featuring live evergreen plants maintained by an advanced irrigation system, ensuring lush greenery year-round.
The building’s elegant ceramic balconies are both stylish and durable, enhancing the overall aesthetic and functionality. Residents can enjoy the 700m Sky Lounge, which provides breathtaking views of Istanbul and a perfect space to relax and unwind.
Sense Levent promotes a healthy and active lifestyle with a full gym, swimming pool, sauna, and steam room, all available in the building. The interiors are crafted with high-quality materials, ensuring a luxurious and inviting living space.
Designed with young professionals in mind, Sense Levent features 1+1 and 2+1 units with smart floor plans and balconies. The project promises high investment returns, with an expected annual return of 6.5-7%, significantly above Istanbul’s average ROI.
Located in the rapidly growing and highly desirable Levent area, the development benefits from ongoing urban regeneration projects. Its prime location offers proximity to shopping malls, municipal buildings, universities, and public transportation, adding immense value to your investment.
Early investors can take advantage of discounted units during the construction phase, with an expected capital appreciation of +45% USD upon completion. Property Turkey provides comprehensive rental management services, ensuring a seamless and profitable investment experience.
Additionally, robust legal support and significant tax advantages are available through Property Turkey’s licensed Real Estate Investment Fund. Levent is a dynamic urban hub, ideal for young professionals with its numerous corporate headquarters and shopping malls.
Sense Levent is more than just a residence; it’s a place where dreams and opportunities come to life. Contact us today to secure your place in this exclusive development and experience the best of Istanbul living. Sense Levent: Sense the Opportunity. Live the Dream.
https://listingturkey.com/property/sense-levent/
Need MCA leads? No sweat! MCAs are great for small biz funding. Learn how to snag top-notch leads: businesses needing cash, with repayment ability, decision-makers, and accurate contacts. Use content, social ads, lead platforms, partnerships, and capture processes for quality leads.
https://www.leadgeneration.media/blog/b/streamline-your-mca-sales-process-with-pre-qualified-leads
Referans Bahcesehir which is being constructed, in the center of the most regional destination as Bahçeşehir, shines out with its central location and unique landscape including social facilities such as a fitness center, sauna, sports facilities, children’s playground and recreational areas.
Not only drawing attention for immediate surroundings including commercial centers and private schools but also providing the easily accessible location with closeness to Tem Highway and connection roads, ongoing construction of 3rd Bridge Connection roads and Metro Projects
Bahcesehir is a rising value in the great city of Istanbul… Located at a new transportation junction in the northwest of the City… Located at such a spot that the access roads for the 3rd bridge and for the 3rd Airport will reach the region in 2016. The Marmaray and the Subway will extend all the way to Referans Bahcesehir respectively in 2018 and 2019.
465 flats and 34 stores are designed with an outstanding approach and arranged with a unique perspective offering the following options: 1 plus 1, 2 plus 1, 3 plus 1, 3.5 plus 1, 4 plus 1, and 4.5 plus 1. It is planned so as to safeguard you and your loved ones based upon a modern, technological safety approach. As you experience the joy and luxury here, you will be content and feet at ease.
It is worth seeing both inside and outside with heart-warming cafes, tasty restaurants and elegant stores… And it is ready to offer a vivacious social life with a warm and cozy space design.
A folding swimming pool and indoor swimming pools, playgrounds, Turkish bath, sauna… It has them all. Everything you need for your well-being and for having a pleasant time will be at your service. You simply need to align the rhythm of life with the rhythm of Referans Bahcesehir.
https://listingturkey.com/property/referans-bahcesehir/
BricknBolt Understanding Load-Bearing Walls and Their Structural Support in H...BrickAndBolt
Load-bearing walls are the backbone of any home construction, providing crucial structural support that carries the weight of the house above. For companies like Brick and Bolt Mysore and Bricknbolt Faridabad, understanding and properly implementing these elements are key to constructing safe and durable buildings.
Investing In The US As A Canadian… And How To Do It RIGHT!! (feat. Erwin Szet...Volition Properties
=== Investing In The US As A Canadian… And How To Do It RIGHT!! (feat. Erwin Szeto) ===
Ever been curious about Real Estate Investing in the US?? At Volition, for the past 14 years, we have been focused on helping investors invest in over $250M of real estate and generate $100M of wealth in the Toronto market, but we are always open to learning more about other business models and learning from other investors.
The US has always been an intriguing market to invest in. But the US is a big place… if you’re interested in investing in the US, you probably have a lot of questions, like:
☑️ Specifically WHERE should you invest?
☑️ What are the best markets to invest in and why?
☑️ How much are property prices there?
☑️ What are the returns like?
☑️ What is cashflow like?
☑️ Compared to investing in Toronto or other cities in Ontario, what are the benefits / tradeoffs?
☑️ What ownership structure should I use?
☑️ What are the tax implications?
☑️ Can I get financing?
☑️ What are tenants like?
Enter Erwin Szeto, a longtime friend of Volition. Since 2005, Erwin Szeto and his team have navigated the challenging landscape of being landlords in Ontario. Now, they are shifting their focus and guiding their clients' investments toward the more landlord-friendly environment of the USA. This decision comes after assisting Canadian clients in transacting over $440,000,000 in income properties. Faced with issues like affordability constraints, tenant-friendly laws, rent control, and rental licensing in Canada, Erwin sees a clear opportunity in the U.S. Here, there is a significant influx of investments leading to the creation of high-paying manufacturing jobs. Erwin and his clients are poised to capitalize on these opportunities where landlord rights are stronger and there is no rent control.
To facilitate this transition, Erwin has partnered with and become a client of SHARE, a one-stop-shop U.S. Asset Manager. Founded by Canadians for Canadians, SHARE enables as passive an ownership experience as possible for landlords in the U.S., while still maintaining direct, 100% ownership.
Erwin is “Making Real Estate Investing Great Again”!!
Website: https://www.infinitywealth.ca/
Facebook: https://www.facebook.com/iwinrealestate and https://www.facebook.com/ErwinSzetoOfficial
Podcast: https://www.truthaboutrealestateinvesting.ca/
Instagram: https://www.instagram.com/iwinrealestate/ and https://www.instagram.com/erwinszeto/
Omaxe Sports City Dwarka stands out as a premier residential and recreational destination, offering a blend of luxury and sports-centric living. Located in the thriving area of Dwarka, this project by Omaxe Limited is designed to cater to modern lifestyle needs while promoting a healthy, active living environment.
Flat available for sale
Location- Tupudana, Ranchi
Savitri enclave
Area- 3BHK
Rate- 4000/sq.ft.
Super Build Up Area-1629 sq.ft.
Build-up area-1253 sq.ft.
Rate- 65lakh16k(approx)
Floor available- Flat available in all floor(G+12)
Balcony- 2
Washroom- 2
Parking - CAR PARKING
Amenities- Joggers track,temple, children's park,gym,banquet hall (5 Lakh)
Possession year (Handover year)- Dec 2025
Outside View from the apartment and flat balcony is very beautiful.
For more information contact AASHIYANA STAR PROPERTIES
7766900371
Lixin Azarmehr, a Los Angeles-based real estate development trailblazer, co-founded JL Real Estate Development (JL RED) in 2015 and serves as its CEO. Her expertise has propelled the firm to specialize in luxury residential and mixed-use commercial projects, with a portfolio that features upscale retail spaces and sophisticated care facilities.
Presentation to Windust Meadows HOA Board of Directors June 4, 2024: Focus o...Joseph Lewis Aguirre
Presentation to Windust Meadows HOA Board of Directors June 4, 2024: Focus on Public Safety as Job #1, Engagement, Wealth of HOA, Branding, Communication, Culture, Civic Responsibility
Presentation to Windust Meadows HOA Board of Directors June 4, 2024: Focus o...
MBA Compliance Essentials CFPB's Mortgage Servicing Rules Resource Guide
1. Nanci L. Weissgold
Partner
Alston & Bird LLP
Morey Barnes Yost
Senior Associate
Alston & Bird LLP
Kendall Stensvad
Associate
Alston & Bird LLP
CFPB’s Mortgage Servicing
Rules Resource Guide
UPDATED AUGUST 2017
MBA COMPLIANCE ESSENTIALS℠
mba.org/compliance
THE TOOLS YOU WANT. THE TRAINING YOU NEED.
17396
2. vii
MBA COMPLIANCE ESSENTIAL RESOURCE GUIDE
TO THE CFPB’S MORTGAGE SERVICING RULES – OUTLINE
I. Introduction & Statutory Background
II. Applicability Chart
III. Policies
A. Closed-End Servicing Disclosures
B. Payment Crediting and Payoff Statement
C. Servicing Transfer
D. Force-Placed Insurance
E. Error Resolution, Information Request and QWR Policy
F. Early Intervention
G. Continuity of Contact
H. Loss Mitigation
I. Investor Reporting
J. Recordkeeping
K. Successor in Interest
IV. Internal Compliance Audit Checklists
A. Closed-End Servicing Disclosures Policy Compliance Checklist
B. Payment Crediting and Payoff Statement Policy Compliance Checklist
C. Servicing Transfer Policy Compliance Checklist
D. Force-Placed Insurance Policy Compliance Checklist
E. Written Request Policy Compliance Checklist
F. Early Intervention and Continuity of Contact Policy Compliance Checklists
G. Loss Mitigation Policy Compliance Checklist
H. Investor Reporting Policy Compliance Checklist
I. Recordkeeping Policy Compliance Checklist
J. Successor in Interest Compliance Checklist
3. i
CLOSED-END SERVICING DISCLOSURES POLICY
I. SCOPE AND PURPOSE........................................................................ A-1
1.1 Scope of Policy............................................................................ A-1
1.2 Purpose of Policy......................................................................... A-1
II. ROLES AND RESPONSIBILITIES......................................................... A-2
2.1 Board of Directors........................................................................ A-2
2.2 Compliance Department.............................................................. A-2
2.3 Internal Audit Department............................................................ A-3
2.4 Training Department.................................................................... A-3
2.5 Employees................................................................................... A-3
III. OTHER POLICIES................................................................................. A-3
IV. CLOSED-END TILA DISCLOSURES .................................................... A-3
4.1 Adjustment Notices...................................................................... A-3
4.1.1 Notice of a Rate Adjustment with a Corresponding Payment
Change ............................................................................. A-3
4.1.2 Initial Rate Adjustment Notice........................................... A-4
4.1.3 Miscellaneous................................................................... A-4
4.2 Periodic Billing Statements.......................................................... A-5
4.2.1 General............................................................................. A-5
4.2.2 Consumers in Bankruptcy................................................. A-6
4.2.2.1 Chapter 11 Bankruptcy Consumers ......A-6
4.2.2.2 Chapter 12 and 13 Bankruptcy
Consumers.......................................................A-8
4.2.3 Accelerated Loans........................................................ A-100
4.2.4 Charged-off Loans.......................................................... A-11
4.2.5 Successors in Interest .................................................... A-11
4.2.6 Loans in Temporary Loss Mitigation Programs and
Permanently Modified Loans .......................................... A-12
4.2.7 Coupon Books ................................................................ A-12
V. REVISION AND REVIEW HISTORY ................................................... A-12
4. A-1
CLOSED-END SERVICING DISCLOSURES POLICY
I. SCOPE AND PURPOSE
1.1 Scope of Policy
This Closed-End Servicing Disclosures Policy (the “Policy”) sets forth the Company’s
policies regarding the delivery of closed-end adjustment notices and periodic statements under the
federal Truth-in-Lending Act (TILA).1 This Policy reflects the requirements of the CFPB mortgage
servicing rules as amended effective October 19, 2017.2 This Policy does not address closed-end
servicing disclosures mandated by state law or the government-sponsored enterprises.
The Company delivers the adjustment notices discussed in Section 4.1 of this Policy for
any closed-end credit transaction that: (1) has a term of more than one year; (2) is secured by the
consumer’s principal dwelling; and (3) permits the annual percentage rate to increase after
consummation (a “Covered ARM”).
The following transactions are not subject to Section 4.1, however, if structured as a fixed-
rate transaction and not as an adjustable-rate mortgage based on an index or formula:
Shared-equity or shared-appreciation mortgages;
Price-level adjusted or other indexed mortgages that have a fixed rate of interest
but provide for periodic adjustments to payments and the loan balance to reflect
changes in an index measuring prices or inflation;
Graduated-payment mortgages or step-rate transactions;
Renewable balloon-payment instruments; and
Preferred-rate loans.
Except as otherwise noted, Section 4.2 of this Policy applies to any closed-end consumer
credit transaction secured by a dwelling.
1.2 Purpose of Policy
It is the purpose of this Policy to ensure that the Company:
Provides consumers with accurate and timely information; and
1
Note to Draft: As drafted, this Policy only covers disclosure requirements under the new TILA servicing
rule, but there are also separate servicing disclosure requirements in Regulation Z (e.g., the requirement to
deliver open-end billing statements). These separate requirements could be incorporated into this Policy or
addressed separately. Also note that while the creditor, any assignee, and the servicer are jointly
responsible for providing the disclosures, the Policy assumes that the servicer is the party that actually
provides the disclosures (with the exception of an initial rate adjustment notice provided by the creditor at
consummation).
2
See 81 FR 72160 (Oct. 19, 2016).
5. A-2
Otherwise complies with applicable legal requirements regarding closed-end
servicing disclosures.
II. ROLES AND RESPONSIBILITIES
2.1 Board of Directors
The Company’s Board of Directors (“Board”) is responsible for ensuring that the Company
complies with the mortgage servicing rules3 (including the topic covered in this Policy) and has
appropriate policies and procedures in place to ensure compliance with the requirements of
agencies, investors, and other relevant parties with which the Company does business.
The Board is responsible for annually reviewing this Policy and for approving any
updates.
2.2 Compliance Department
The Board delegates day-to-day oversight responsibilities for compliance with the
mortgage servicing rules and this Policy to the Compliance Department. The Compliance
Department is responsible for maintaining and updating this Policy and for ensuring its
implementation by the appropriate business unit(s) based on the direction of the Board. The
Compliance Department’s responsibilities include:
Monitoring changes in laws and in policies and procedures of investors, and
other relevant parties with which the Company does business, and assessing if
changes to this Policy should be recommended to the Board.
Ensuring management and employees are appropriately trained in and
knowledgeable of the mortgage servicing rules’ requirements and this Policy.
In accordance with the Company’s Vendor Management Program, ensuring any
Company vendors and third-party service providers with responsibilities requiring
compliance with the mortgage servicing rules’ requirements have appropriate
policies and procedures and training programs to provide for compliance with the
mortgage servicing rules and this Policy.
Assessing compliance with the mortgage servicing rules and this Policy, and
ensuring this Policy, training, and other internal controls are appropriately
updated as a result of quality control or audit findings and other applicable
concerns.
Conferring with inside and outside legal counsel as appropriate regarding the
mortgage servicing rules’ requirements.
Assisting with regulatory inquiries or audits addressing the mortgage servicing
rules.
3
The mortgage servicing rules can be found, in significant part, in Subpart C of Regulation X and Subparts
C and E of Regulation Z, and in the Federal Register at: 78 FR 10696 (Feb. 14, 2013), 78 FR 10902 (Feb.
14, 2013), 78 FR 44685 (July 24, 2013), 78 FR 60382 (Oct. 1, 2013), 78 FR 62993 (Oct. 23, 2013), 78 FR
80225 (Dec. 31, 2013), 80 FR 8767 (Feb. 19, 2015), 80 FR 43911 (July 24, 2015), 81 FR 72160 (Oct. 19,
2016).
6. A-3
Monitoring compliance with the mortgage servicing rules and this Policy through
independent audits performed by the Company or by a third party.
Periodically reporting to the Board regarding compliance with the mortgage
servicing rules and this Policy, including the results of audit findings as
applicable.
2.3 Internal Audit Department
The Internal Audit Department is responsible for periodically verifying the Company’s
compliance with this Policy (but no less frequently than annually).
2.4 Training Department
The Training Department will provide employees with information and training regarding
the Company’s obligations relating to closed-end servicing disclosures. At a minimum, this will
include applicable training regarding this Policy and the CFPB mortgage servicing rules.
2.5 Employees
All employees responsible for generating and delivering billing statements and other
periodic disclosures must adhere to the requirements of this Policy. Such employees are
responsible for understanding and complying with the requirements established in this Policy and
must participate in the applicable training as designed by the Training Department regarding the
topic covered in this Policy.
III. OTHER POLICIES
Please refer to the following Company policies and procedures for additional relevant
information:
[Open-End Servicing Disclosures Policy and Procedures]
[Electronic Transactions Policy and Procedures]
[Recordkeeping Policy and Procedures]
[Internal Audit Policy and Procedures]
[Successors in Interest Policy]
[Other]
IV. CLOSED-END TILA DISCLOSURES
4.1 Adjustment Notices
4.1.1 Notice of a Rate Adjustment with a Corresponding Payment Change
When an interest rate adjustment on a Covered ARM results in a corresponding change in
the consumer’s minimum payment obligation (including in connection with a payment change that
results from the conversion of a Covered ARM to a fixed-rate transaction), the Company will provide
the consumer with an adjustment notice that contains the information required under 12 C.F.R. §
1026.20(c). The content and format of the notice will be substantially similar4 to Model Forms H-
4(D)(1) and (2) in Appendix H to Regulation Z.
4
The Company may modify the model forms to accommodate particular consumer circumstances or
transactions not addressed by the forms. For example, when the Company provides the required notice to a
7. A-4
The Company will provide such notices to consumers at least 25, but no more than 120,
days before the first payment at the adjusted level is due for: (1) Covered ARMs with uniformly
scheduled interest rate adjustments occurring every 60 days or more frequently; and (2) Covered
ARMs originated before January 10, 2015, in which the loan contract requires the adjusted interest
rate and payment to be calculated based on the index figure available as of a date that is less than
45 days before the adjustment date.
The Company will provide such notices to consumers as soon as practicable, but not less
than 25 days before the first payment at the adjusted level is due, when: (1) the first adjustment to
a Covered ARM occurs within 60 days of consummation; and (2) the new interest rate disclosed at
consummation pursuant to Section 4.1.2 of this Policy was an estimate. However, the Company
will not provide such a notice in connection with the first rate adjustment on a Covered ARM when:
(1) the first payment at the adjusted level is due within 210 days after consummation; and (2) the
new interest rate disclosed at consummation pursuant to Section 4.1.2 of this Policy was not an
estimate.
The Company otherwise will provide such notices to consumers at least 60, but no more
than 120, days before the first payment at the adjusted level is due. The Company is exempt from
the requirements of this section if the Company is considered a debt collector under Fair Debt
Collection Practices Act (FDCPA) with respect to a consumer and that consumer has exercised a
“cease communication” right under the FDCPA.
4.1.2 Initial Rate Adjustment Notice
The Company will provide an initial rate adjustment notice in connection with the initial
contractual5 interest rate adjustment on a Covered ARM. The initial rate adjustment notice will
contain the information required under 12 C.F.R. § 1026.20(d) and appear in a format that is
substantially similar to Model Forms H-4(D)(3) and (4) in Appendix H to Regulation Z. If the new
interest rate (or the new payment calculated from the new interest rate) is not known by the date of
the disclosure, the Company will disclose an estimate and label it as such. This estimate will be
based on the appropriate index value in effect within 15 business days before the date of the
disclosure.
The Company will provide the initial rate adjustment notice to consumers at least 210, but
no more than 240, days before the first payment at the adjusted level is due, except that if the first
payment at the adjusted level is due within the first 210 days after consummation, the creditor will
be responsible for providing the notice at consummation. The Company must provide this notice
even if the Company is considered a debt collector under the FDCPA with respect to a consumer,
and that consumer has exercised a “cease communication” right under the FDCPA.
4.1.3 Miscellaneous
The notices required under Section 4.1.1 and 4.1.2 of this Policy must reflect the credit
terms to which the parties are legally bound when the disclosures are provided. They also must
be made clearly and conspicuously, in writing, and in a form that the consumer may keep.
consumer whose Covered ARM is converting to a fixed-rate mortgage, it may modify the model language to
explain that the interest rate will no longer adjust.
5
Note to Draft: The Commentary to the 2016 mortgage servicing rules amendment clarifies that the notice
requirement is not triggered by an interest rate adjustment that is made for loss mitigation purposes
(although subsequent adjustments made pursuant to the revised terms of the contract could trigger notice
obligations).
8. A-5
Such notices may be provided electronically, subject to compliance with the consumer
consent and other applicable provisions of the federal Electronic Signatures in Global and National
Commerce Act. The disclosures required to appear in the notices must be grouped together,
segregated from everything else, and may not contain any additional information, other than an
acknowledgement of receipt, the date of the transaction, and the consumer’s name, address, and
account number. Further, the initial rate adjustment notice must be provided as a separate
document from all other written materials.6
4.2 Periodic Billing Statements
4.2.1 General
The Company will provide consumers7 with a periodic statement for each billing cycle of
any closed-end consumer credit transaction secured by a dwelling (other than a reverse mortgage
or a transaction secured by a consumer’s interest in a timeshare plan). The Company must
continue to provide periodic statements even if the Company is considered a debt collector under
the FDCPA with respect to a consumer and that consumer has exercised a “cease communication”
right under the FDCPA.
If a mortgage loan has a billing cycle shorter than a 31-day period (e.g., a biweekly billing
cycle), the periodic statement may cover an entire month. The Company will deliver the periodic
statement or place it in the mail within a reasonably prompt time after the payment due date or the
end of any courtesy period provided for in the previous billing cycle. Delivering, emailing, or placing
the periodic statement or coupon book in the mail within four days after the payment due date or
the end of the courtesy period generally would be considered reasonably prompt.
The periodic statements will clearly and conspicuously disclose the information required
under 12 C.F.R. § 1026.41(d). If the Company has established an address pursuant to 12 C.F.R.
§§ 1024.35(c) or § 1024.36(b) that a consumer must use to assert an error or request information,
that address must be provided in the periodic statements. The statements must be formatted to
comply with 12 C.F.R. § 1026.41(c) and in a manner that is substantially similar8 to the model
statements in Appendix H-30 to Regulation Z.9
6
When the notice is mailed, however, it may be in the same envelope as other materials. Similarly, when it
is delivered by electronic mail, it may be one of several attachments, as long as it remains a separate
attachment.
7
When two consumers are joint obligors with primary liability in the transaction, the periodic statement may
be sent to either consumer. For example, if spouses jointly own a home, the Company may send a single
statement to either spouse and need not send separate statements to both.
8
The Company may modify the model forms to accommodate particular consumer circumstances or
transactions not addressed by the forms. For example, when the Company provides the required notice to a
consumer whose Covered ARM is converting to a fixed-rate mortgage, it may modify the model language to
explain that the interest rate will no longer adjust.
9
Note to Draft: Regulation Z expressly provides that the adjustment notices discussed in Section 4.1 may
not include any extraneous information and that the initial rate adjustment notice must appear as a separate
document. However, these limitations do not apply to the periodic statement requirement. The
Commentary to Regulation Z expressly acknowledges that a servicer may include additional information on
the periodic statement and/or combine it with disclosures required by other laws, unless otherwise expressly
prohibited by applicable law. Further, where § 1026.41(d) requires disclosures to be in “close proximity to
one another,” the items should be grouped together and set off from other groupings of items. This may be
accomplished in a variety of ways, for example, by presenting the information in boxes or by arranging the
items on the document and including spacing between the groupings. However, items in “close proximity”
may not have any unrelated text between them. Text is “unrelated” if it does not explain or expand upon the
required disclosures.
9. A-6
Periodic statements must be in writing and in a form that the consumer may keep. If the
consumer agrees, the Company may, however, provide periodic statements electronically.10
4.2.2 Consumers in Bankruptcy11
(i) 4.2.2.1 Chapter 11 Bankruptcy Consumers
The periodic statement may be modified according to 12 C.F.R. § 1026.41(f) while any
consumer on a mortgage loan is a debtor in bankruptcy under Title 11 of the United States Code
or if such consumer has discharged personal liability for the mortgage loan under 11 U.S.C. §§
727, 1141, 1228, or 1328. When one of these events occurs, the Company must provide the next
modified periodic statement by delivering it or placing it in the mail within a reasonably prompt time
after the first payment due date or the end of any courtesy period for the payment’s corresponding
billing cycle. The Company is provided a courtesy period for a single billing cycle during which the
Company is exempt from providing a modified periodic statement if the payment due date for that
billing cycle is no more than 14 days after the date either the consumer becomes a debtor in
bankruptcy under Title 11 or the consumer discharges personal liability for the mortgage loan. If
this occurs for a mortgage loan with more than one primary obligor (under Chapter 11, 12, or 13),
the Company may provide the modified statement to any or all of the primary obligors, even if the
primary obligor the Company provides the modified statement to is not a debtor in bankruptcy. The
Company need not provide an unmodified statement to any of the primary obligors.
The modifications the Company may make to the periodic statement or coupon book
pursuant to § 1026.41(f) for debtors in bankruptcy under Title 11 are:
Omission of the Late Payment Fee: The Company may omit the amount of any late
payment fee, and the date on which that fee will be imposed, if payment has not been
received;
Omission of the Length of Delinquency: The Company may omit the length of the
consumer’s delinquency. Specifically, the length of a consumer’s delinquency is
measured as of the date of the periodic statement or the date of the written notice
provided under § 1026.41(e)(3)(iv) when a consumer is in bankruptcy. A consumer’s
delinquency begins on the date an amount sufficient to cover a periodic payment of
principal, interest, and escrow, if applicable, becomes due and unpaid, even if the
consumer is afforded a period after the due date to pay before the Company
assesses a late fee. Further, if the Company applies payments to the oldest
outstanding periodic payment, a payment by a delinquent consumer advances the
date the consumer’s delinquency began;
Omission of Risk Notifications: The Company may omit any notification of possible
risks, such as foreclosure, and expenses that may be incurred if the delinquency is not
cured; and
10
Note to Draft: A servicer technically is not required to obtain a formal E-SIGN consent to deliver periodic
statements in an electronic format. However, a consumer not only must consent to receive electronic
statements, but also must demonstrate the ability to access electronic disclosures in the format in which they
are to be provided. Thus, as a practical matter, a servicer may want to comply with the formal E-SIGN
consent and disclosure requirements before providing electronic statements. Note, however, that any
consumer who is currently receiving disclosures for any account (for example, a mortgage or checking
account) electronically from their servicer shall be deemed to have consented to receiving e-statements in
place of paper statements.
11
This section of the Policy reflects the requirements of the CFPB mortgage servicing rules as of April 19,
2018. See 81 FR 72160 (Oct. 19, 2016).