Manufactured Housing Institute Comment Letter on CFPB Mortgage Servicing

On Sept. 9, MHI submitted comments to the Consumer Financial Protection Bureau (CFPB) regarding their proposed changes to Regulation X Servicing rules. In the letter, MHI provided recommendations to streamline and improve the process without undermining the key objectives of protecting borrowers and maximally encouraging loss mitigation in the proposed changes. MHI addressed the open, uncertain timeline created by the proposal and suggested methods to create a more defined timeline to increase system confidence. Additionally, MHI highlighted the challenges that would result from the new requirements regarding translated disclosures and services for Limited English Proficiency borrowers if the rule was implemented as written. Withdrawing the requirements and crafting more targeted and effective processes to benefit borrowers and lenders alike was suggested. Finally, to prevent a rise in servicing costs which would hurt consumers in the pricing of new home loans, MHI requested the CFPB reconsider the prohibition against recovery of administrative and technology costs to cover higher processing expenses.

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