CFPB Presentation

2016 CFPB Servicing Amendments

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Example – A borrower who is 60 days delinquent submits an incomplete loss mitigation application. Within 5 business days, the servicer provides an acknowledgment notice stating the additional documents and information the borrower must submit to complete the application. The notice also includes a reasonable date by which the borrower should submit the documents and information. No documents or information submitted by the borrower will be considered stale within the next 30 days. The "reasonable date" can be 30 days from the date the servicer provides the notice because it will not be later than any milestone. In this scenario, 30 days is before the date that is the 120th day of the borrower's delinquency (and therefore 90 days and 38 days before a foreclosure sale). If however, the borrower is already 95 days delinquent, 30 days after provision of the notice is not a reasonable date, as it could be after the loan passed the 120 day milestone. In this case, the servicer might select 15 days as a reasonable date for return of the needed documents or information. 19 Reasonable Date Example

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