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The CFPB recently entered into consent orders with several Citibank subsidiaries attacking their mortgage servicing practices during the early days of the Mortgage Servicing Rules despite the CFPB’s assurances that early examinations would focus on efforts to comply rather than the technical aspects of compliance. The consent orders require CitiMortgage to pay $17 million to affected consumers and a $3 million civil penalty and require CitiFinancial Services to pay $4.4 million to affected consumers and a $4.4 million civil penalty.
The Consent Order requires that upon requests for deferments, CitiFinancial must:
Mortgage servicers should take note that examiners, despite contrary earlier indications, are taking a hard look at mortgage servicing practices from the effective date of Reg X forward. Mortgage servicers should continue to review their practices and procedures for compliance with Reg X.
Caren Enloe is a partner who concentrates her practice in consumer financial services litigation and compliance, bankruptcy, and commercial litigation with an emphasis on creditor’s rights. She has a deep understanding of the complex compliance environment surrounding the financial services industry and regularly advises financial service companies on licensing and compliance issues involving state and federal consumer protection and finance statutes. Caren is the author of a daily blog titled: Consumer Financial Services Litigation and Compliance where she posts timely and informative updates regarding the CFPB, FTC, and a host of topical litigation issues involving consumer protection law....LEARN MORE