Late last week, the CFPB issued a formal proposal building on the outline previously announced for a wide-ranging set of reforms to mortgage servicing.  As we said in our assessment of the initial proposal, the scope of these reforms poses not only new costs to servicers, but also sweeping change in servicing that advantages borrowers and investors.  For servicers, though, not so good, forcing many to accelerate strategic planning for sharply reduced securitization operations.

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