Introduction to Mortgage Servicing Examinations Training - March 2023
Consumer (Credit) Reporting
12. C.F.R. § 1022 – Fair Credit Reporting (Regulation V) 12. C.F.R. § 1022.42 12. C.F.R. § 1022.82 12. C.F.R. § 1022.123
Does the servicer have a consumer credit reporting policy that addresses: 1. Resolving errors and investigations to resolve disputes 2. Accuracy and integrity of the information relating to consumers that it furnishes to a consumer reporting agency 3. Correcting and updating information 4. Timing requirements for consumer responses 5. Notice requirements to consumers 6. Notification from consumer of ID Theft 7. Validating of consumer when there is an address discrepancy 8. Verification of consumer’s proof of identity Does the servicer have a policy related to consumer complaints/notices of error and requests for information that address: 1. Servicer contact information for borrower communication related to error notices and requests for information 2. What constitutes a notice of error (i.e., requirements for borrower error notice) 3. Furnishing adverse information to credit reporting agency 4. Timing and content of servicer’s acknowledgement to error notice or requests for information 5. Timing and content of servicer’s response to error notice or requests for information 6. Expedited evaluations (e.g., imminent foreclosure)
CFPB FCRA Exam Procedures
Error Resolution and Consumer Inquiries
12 C.F.R. § 1024 – Real Estate Settlement Procedures Act
12 C.F.R. § 1024.35 12 C.F.R. § 1024.36
CFPB RESPA Exam Procedures
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