On July 22, MCUL & Affiliates responded to the CFPB’s request for comment regarding their amendments to the 2013 Mortgage Rules. MCUL was generally supportive of the revisions proposed for the mortgage rules. In its letter to the CFPB, the MCUL requested further clarification on the financing of credit insurance, loan originator compensation and provided suggestions for the proposed loss mitigation changes including a reduction in the 120-day pre-foreclosure period. MCUL also took this opportunity to comment on the small servicer exemption that was finalized on July 10, which requires credit unions with affiliated CUSO relationships to aggregate their mortgage loans with their own to determine if the exemption applies. MCUL proposed that the CFPB only require including in the aggregation for exemption, the amount of loans the CUSO services specifically for that particular credit union, as opposed to all of the loans the CUSO services.
The CFPB’s request for comment can be found here.