Managing CFPB Compliance with CLARIFIRE®

Despite ongoing news of changing authority and leadership philosophy, the Consumer Financial Protection Bureau (CFPB) continues to implement and enforce federal consumer financial laws impacting banks, credit unions, and other financial institutions. Since the CFPB's creation in 2012 under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), the organization has issued extensive regulation, supervisory guidance, and enforcement actions against industry participants.

The current environment, although shifting, continues to place stress on the financial services industry. Even the most diligent and conservative businesses have a difficult time keeping up with the extent of possible impact. Under pressures of interpretation and timing of deregulation, financial institutions must be prepared to implement, change operational processes, transition, document, and revise complex rules and regulations.

CFPB Consumer Protection Bureau

Ensuring CFPB Compliance in the Post Pandemic Framework

Effective August 31, 2021, the CFPB is amending servicing provisions under Regulation X in an effort to assist borrowers facing financial hardship that has culminated from the COVID-19 pandemic. Intended to provide relief measures such as foreclosure moratoria and forbearance protections expire, these amendments are designed to stave off unpredictable foreclosure starts and transition distressed borrowers into viable loss mitigation alternatives.

As of mid-year 2021, over two million homeowners remained in forbearance, and greater than three percent of all borrowers were more than four months delinquent on their mortgage payments. The CFPB's new Mortgage Servicing COVID-19 Rule is designed to ensure servicers have strong efforts in place to help borrowers avoid foreclosure, including:

  • Creating a meaningful opportunity for borrowers to pursue loss mitigation options.
  • Enabling mortgage servicers to help borrowers quickly enter affordable payment plans.
  • Increasing borrower outreach before servicers start foreclosure efforts.

And also assist borrowers exiting forbearance avoid foreclosure, ensuring an effective transition to permanent loss mitigation alternatives. The CFPB has recommended lenders offer by ensuring there are at least three options to bring mortgage payments current:

  1. Defer missed payments to the end of the mortgage so borrowers can resume regular payments.
  2. Modify interest rate, principal balance, or length of mortgage so monthly payments are lower.
  3. Promote the sale of homes by minimizing equity erosion and helping borrowers when sufficient equity is available.

The CFPB is dedicated to fostering strong partnerships with the administration and federal agencies, as well as mortgage servicers, to facilitate and ease industry transition to a healthy post-pandemic housing market. Does your organization have the workflow automation it takes to make these changes easy?

CLARIFIRE® Benefits

CLARIFIRE® has the features and benefits necessary to navigate nearly every phase of industry complexity. With a proven track record of delivering sophisticated automated workflow that encompasses workout decisioning and loss mitigation eligibility, our focus is to help your organization effectively connect to downstream and upstream existing systems. We instill confidence and provide the capabilities to withstand operational and regulatory disruption, including:

knowledge

Deep subject matter expertise, industry experience, and dedicated support models.

devices

Workflow that manages operational processes 24/7 with borrower no-touch automation delivered through any device.

safe

Encompassing current consumer protection regulations

computer with controls

Controls over customer communication, disclosure delivery, application documentation, closing, and post-closing document management, servicing transfer, identity, and third-party affiliates.

dashboards

All CFPB metrics accessed directly from your dashboard in real time.

Increasing bar graph

The CLARIFIRE® Loss Mitigation workflow processes and workout underwriting calculator feature creates powerful efficiencies in the areas that cost servicers the most.

Learn More

See why Clarifire is a leader in delivering robust workflow automation with proven industry features such as the CLARIFIRE CALCULATOR™. A workout underwriting software for customers with fluid, ever-changing, regulatory demands and the need to implement change rapidly, with quality while preserving future capabilities to change and change again as needed. Click here to view additional details specific to:

CLARIFIRE® is truly "BRIGHTER AUTOMATION®."