State regulators are proposing a set of Baseline Prudential Regulatory Standards, which will be applied across the board to all non-bank mortgage servicing companies licensed by and operating in the states. The Baseline Prudential Regulatory Standards cover the following eight specific areas of prudential regulation: capital; liquidity; risk management; data standards; data protection; corporate governance; servicing transfer requirements; and change-of-control requirements. Additionally, the state regulators also propose a set of Enhanced Prudential Standards, which would be applied to larger, more complex non-bank mortgage servicing companies. Such enhanced measures include prudential regulations requiring additional planning, modeling, metrics and audit for: capital, liquidity; stress testing; and living will/recovery and resolution plans.
The press release from the CSBS and AARMR, including a link to the full set of Baseline and Enhanced Prudential Standards can be found here.
Locke Lord has a dedicated team of compliance and litigation lawyers who have significant experience handling various aspects of consumer finance, including mortgage servicing. Locke Lord lawyers regularly advise financial institutions on regulatory compliance matters, new product development and represent clients in regulatory enforcement matters, class actions and various lawsuits in the U.S. and abroad. Visit our Consumer Finance Regulatory Practice Group website at or contact any members of the practice group below:
Thomas J. Cunningham | 312-443-1731 | firstname.lastname@example.org
Simon A. Fleischmann | 312-443-0462 | email@example.com
Robert T. Mowrey | 214-740-8505 | firstname.lastname@example.org
Thomas G. Yoxall | 214-740-8683 | email@example.com
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