(RECAP: The implementation date of the Consumer Financial Protection Bureau’s final mortgage servicing rule lies in question after the Trump administration announced a freeze on federal regulations. After a nearly four-month delay since the CFPB finished the final mortgage servicing rule, the Office of the Federal Register finally published the rule on Oct. 19, meaning it would go into effect one year later on Oct. 19, 2017. While the extra time to adjust to the rule isn’t a terrible thing, Nanci Weissgold, a member of Alston & Bird’s Financial Services & Products Group, said, “Given the operational complexities in implementing these rules, servicers should not delay in understanding the requirements and developing an implementation plot.” There are only two rules currently published but not yet effect in the Federal Register that this freeze applies to. The final mortgage servicing rule is one and the other is the rule on Prepaid Accounts under the Electronic Fund Transfer Act and Truth in Lending Act, published Nov. 22, 2016 and effective Oct. 1, 2017.)
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