CFPB’s Escrow Interpretation Is Causing Confusion Amongst Servicers and Is Likely to Harm Consumers
By EsqSocial Corporation 30/10/20
In a surprising move to many, the Consumer Financial Protection Bureau (CFPB) recently put the mortgage servicing industry on notice that including certain options for repayment of a shortage in an escrow account statement may violate Regulation X. Specifically, the CFPB explained in its recent edition of the Supervisory Highlights report that one or more servicers violated Regulation X by including a lump sum repayment option — not a lump sum repayment requirement — in the escrow account...
By: Bradley Arant Boult Cummings LLP