Letter to CFPB on Reg X Proposal on Borrower Protections During COVID Pandemic

Comment Intake
Bureau of Consumer Financial Protection
1700 G Street, NW
Washington, DC 20552

Dear Sir or Madam:

The American Bankers Association (ABA) appreciates the opportunity to comment on this notice of proposed rulemaking (NPR) from the Consumer Financial Protection Bureau (Bureau or CFPB) to amend the Regulation X servicing rules in response to the continuing COVID-19 pandemic.

ABA supports the Bureau’s objectives of ensuring that servicers communicate timely and accurate information to borrowers about their loss mitigation options and ensure that borrowers receive fair assessments of their foreclosure avoidance options. We also appreciate the Bureau’s efforts to clarify the complex Regulation X provisions. There are, however, elements in the proposal that require further attention and several critical improvements that should be made to promote fair and efficient treatment of borrowers by their mortgage servicer. ABA offers recommendations intended to ensure that the servicing rules provide appropriate protection for those borrowers who need it the most, reduce the risk of borrower confusion and frustration, and are appropriately limited in scope so that servicer resources can be dedicated to working with consumers—not on implementing the final rule.

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