CFPB Issues Vendor Management Bulletin  - On Friday, April 13, 2012 the CFPB issued a bulletin regarding ‘guidelines’ for banks and non-bank consumer financial service companies with respect to how those companies manage and vet their 3rd party vendors. While there is not much new in the bulletin, and in fact, most of the guidance closely resembles previous guidance in OCC directives, it does in fact add another layer of bureaucracy to an already-complex system of audits and scrutiny that foreclosure trustees and law firms find themselves under.

The issue posed concerns the regulation and enforcement scope of CFPB over foreclosure law firms, including how firms falling under this regulation / enforcement are identified.  Pertinent documents concerning this matter are posted below, for your information.

• CFPB Commentary on Rule 1090  (06/23/2011)
• 12 CFR Part 1090 The Rule
• CFPB Part 1090 Questions

This document provides a listing of all of the relevant Agency Updates, associated with Mortgage Servicing, for 2010.  We hope you’ll find it useful. Thank you to Terry Ross, Director Regulatory Compliance at Barrett Daffin Frappier Turner & Engel, LLP & National Default Exchange, LP, who compiled this information, for allowing us to provide it to you.

FAILED BANK LIST - The FDIC is often appointed as receiver for failed banks. This page (link below) contains useful information for the customers and vendors of these banks. This includes information on the acquiring bank (if applicable), how your accounts and loans are affected, and how vendors can file claims against the receivership. This list includes banks that have failed since October 1, 2000.

Borrower's Guide to an FDIC Insured Bank Failure

USFN, its Members, and other contributors have prepared the information contained in the above documents as a public service and for general information purposes only. The information may or may not reflect the most current legal developments and under no circumstances should readers rely solely on this material. Readers should seek independent and competent legal counsel before acting upon any information contained herein.  This information is not provided in the course of an attorney-client relationship and is not intended to constitute legal advice or legal opinion, or to substitute for obtaining legal advice from an attorney licensed in your state. It is advisable that servicers and other readers contact local counsel familiar with the rules, practices, and interpretations of the particular jurisdiction.