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CFPB Requests Input on TRID and Reverse Mortgage Disclosure Requirements: What Mortgage Industry Participants Need to Know

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On July 9, 2026, the Consumer Financial Protection Bureau (CFPB) published a Request for Information (RFI) seeking public input on potential changes to several mortgage disclosure requirements, including the TILA-RESPA Integrated Disclosure (TRID) rules and reverse mortgage disclosures. The RFI reflects the CFPB’s broader effort to identify regulatory requirements that may increase costs, create operational burdens, or unnecessarily impede access to mortgage credit while continuing to provide meaningful consumer protections. The RFI follows the President’s March 13, 2026, Executive Order (the “March EO”), which directed the CFPB to consider, as appropriate and consistent with applicable law:

(i) proposing amendments to Regulation Z that tailor the following requirements for smaller banks: ATR and QM requirements (including potentially a broader QM safe harbor for portfolio loans) and the requirements of the Truth in Lending Act, Public Law 90-321 (TILA), Real Estate Settlement Procedure[s] Act, Public Law 93-533 (RESPA), and TILA-RESPA Integrated Disclosure (TRID) rules;

(ii) replacing TRID timing rules with a materiality-based standard that preserves consumer clarity and reduces closing delays; [and]

. . . .

(vii) exempting rate-and-term refinancing (including cash-out refinancing) from rescission rights.”

For mortgage lenders, servicers, and reverse mortgage participants, this development may signal the beginning of a new round of regulatory reform in the mortgage disclosure space.

What Happened?

The CFPB issued an RFI requesting comments on whether existing mortgage disclosure requirements should be revised to reduce burdens on industry participants and consumers. The Bureau specifically seeks feedback regarding three areas:

  1. TRID disclosures;
  2. The right of rescission applicable to certain refinance transactions; and
  3. Reverse mortgage disclosures.

The comment period closes on August 10, 2026.

TRID Is Back on the Table

The TRID rules, which became effective in 2015, integrated disclosures required under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA) into two primary forms: the Loan Estimate and the Closing Disclosure. The CFPB’s RFI asks whether certain aspects of the current framework create unnecessary burdens for lenders or confusion for consumers. Areas identified for comment include disclosure timing requirements, tolerance rules, electronic delivery requirements, and whether smaller institutions should be subject to different or more tailored requirements.

Although the CFPB has amended TRID several times over the last decade, industry participants have continued to identify operational challenges associated with disclosure redisclosures, timing requirements, cure processes, and technology implementation. The RFI provides stakeholders an opportunity to raise those concerns directly with the Bureau.

Reverse Mortgages Receive Particular Attention

The RFI also focuses on reverse mortgage disclosures, an area where the disclosure regime remains largely separate from the integrated TRID framework.

Unlike most forward mortgage products, reverse mortgages continue to rely on multiple disclosure forms and calculations, including Truth in Lending disclosures, Good Faith Estimates, HUD-1 settlement statements, and the Total Annual Loan Cost (TALC) disclosure. The CFPB is seeking comment on whether these disclosures continue to serve borrowers effectively or whether a more streamlined approach would improve consumer understanding.

Among other topics, the Bureau asks whether:

  • Reverse mortgage borrowers would benefit from a single integrated disclosure framework similar to TRID;
  • TALC calculations remain useful and understandable;
  • Alternative disclosures showing projected loan balance growth in dollar terms would be more meaningful than annualized cost metrics; and
  • Consumers would benefit from reverse mortgage-specific educational materials.

These questions suggest that the CFPB may be considering a significant modernization of reverse mortgage disclosures.

Why Does It Matter?

This RFI could represent the first step toward meaningful changes in mortgage disclosure regulation.

Potential Changes to Longstanding TRID Compliance Requirements

TRID compliance remains one of the most operationally intensive areas of mortgage origination. Loan origination systems, document preparation vendors, settlement service providers, and lenders have invested substantial resources in implementing and maintaining TRID compliance. Even relatively modest regulatory changes could require system modifications, vendor updates, revised procedures, employee training, and quality-control enhancements.

At the same time, many industry participants have argued that certain aspects of the rules create costs without providing corresponding consumer benefits. The CFPB appears interested in identifying those areas and assessing whether simplification is possible.

Reverse Mortgage Reform Could Be Significant

The reverse mortgage portion of the RFI may prove especially noteworthy. Reverse mortgage disclosures are governed by requirements that predate TRID and often present information differently than consumers encounter in forward mortgage transactions. Critics have long questioned whether the TALC disclosure is useful or understandable to borrowers. The CFPB’s willingness to revisit those requirements suggests that the Bureau may be open to a broader redesign of the reverse mortgage disclosure framework.

If the CFPB ultimately pursues a more integrated disclosure model for reverse mortgages, lenders and technology providers may face substantial implementation projects but could also benefit from a more streamlined and consumer-friendly framework.

The RFI May Signal Broader Deregulatory Efforts

The RFI was issued as part of a broader federal initiative—announced in the March EO—focused on promoting access to mortgage credit and evaluating regulations that may increase lending costs. As a result, stakeholders should view this development not simply as a disclosure review, but as part of a potentially larger conversation regarding mortgage regulation, operational burden, and consumer protection.

What Do I Need to Do?

Mortgage industry participants should not assume that regulatory changes are imminent, but they should take the RFI seriously.

Consider Submitting Comments

Lenders, servicers, investors, settlement service providers, and technology vendors should evaluate whether they have operational experience or data that could inform the CFPB’s review. The most persuasive comments will typically identify specific compliance burdens, quantify costs where possible, and propose practical alternatives that preserve consumer protections.

Identify TRID Pain Points

Organizations should take inventory of recurring compliance challenges, including: disclosure timing issues; redisclosure triggers; tolerance cure processes; electronic delivery requirements; secondary market impacts; and vendor and system implementation costs.

These issues may become particularly relevant if the CFPB moves beyond the information-gathering stage and begins considering proposed rule changes.

Reverse Mortgage Participants Should Engage Early

Reverse mortgage lenders, investors, and servicers should pay particular attention to the CFPB’s questions regarding TALC disclosures, integrated disclosure concepts, and consumer education. Stakeholders with direct experience observing borrower confusion—or disclosure practices that work particularly well—may have a meaningful opportunity to influence future policy.

Monitor for Next Steps

The RFI is only the beginning of the process. Following the comment period, the CFPB may decide to take no action, issue additional guidance, propose targeted amendments, or pursue broader rulemaking initiatives. Stakeholders should continue monitoring developments closely, particularly given the potential implications for mortgage origination systems, disclosure platforms, and compliance management programs.

For now, the message is clear: after more than a decade of living with TRID—and decades of operating under the current reverse mortgage disclosure framework—the CFPB is actively considering whether these requirements should be modernized. Industry participants have a limited window to help shape what comes next.

The California Financial Protection Bureau? California Moves to Fill the CFPB Void

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What Happened?

On May 12, 2026, California Governor Gavin Newsom announced the appointment of former Consumer Financial Protection Bureau (“CFPB”) Director Rohit Chopra as Secretary of the newly created California Business and Consumer Services Agency (“BCSA”).

The BCSA is a cabinet-level reorganization that will officially launch on July 1, 2026, consolidating a wide range of licensing, regulatory, and enforcement functions across numerous consumer-facing sectors of the California economy. These include oversight bodies such as the Department of Financial Protection and Innovation (“DFPI”), Department of Consumer Affairs, and other key regulators impacting financial services, real estate, and technology markets.

Governor Newsom framed the move explicitly as a response to the federal government’s retrenchment in consumer financial protection under the Trump administration, positioning California to “strengthen the state’s efforts to protect consumers and honest businesses” as federal enforcement is scaled back.

Chopra, who previously led the CFPB and served as a Federal Trade Commission commissioner, is widely known for aggressive enforcement initiatives targeting “junk fees,” repeat offenders, and unfair or abusive practices in consumer finance.

Why Does It Matter?

The creation of the BCSA—and the selection of Chopra to lead it signals a deliberate effort by California to function as a state-level analogue to a weakened CFPB. As federal consumer protection oversight contracts, California is positioning itself to step into the resulting regulatory vacuum.

This mirrors broader state-level trends, where states are expanding their authority and enforcement posture to address unfair, deceptive, and abusive acts and practices (“UDAAP”) in the absence of robust federal oversight. For example, as we have noted in prior posts, New York has moved to modernize its UDAAP framework in anticipation of increased enforcement and oversight of the financial services industry. California now appears poised to follow a similar path, albeit through a different structural approach.

Unlike a single regulator the BCSA is structured as a coordinating “umbrella” agency that brings together dozens of previously fragmented entities. This consolidation is designed to align enforcement priorities, streamline supervision, and enable coordinated rulemaking across industries that increasingly intersect (e.g., fintech, payments, and digital platforms).

For financial services companies, the most significant implication is the integration of the DFPI into a broader enforcement framework. The DFPI already exercises expansive authority over mortgage banking and finance lending activities and, under the California Consumer Financial Protection Law (“CCFPL”), supervises a broad spectrum of nonbank financial products, including lending, payments, and emerging fintech offerings. The new structure allows California to pursue cross-sector enforcement strategies, particularly where financial products intersect with technology platforms, data practices, or broader consumer marketplaces.

Chopra’s appointment strongly suggests that California enforcement will reflect the priorities and philosophy that characterized his tenure at the CFPB. During that time, the Bureau emphasized:

  • Aggressive enforcement against “junk fees” and pricing practices;
  • Scrutiny of repeat offenders and systemic compliance failures;
  • Focus on unfairness and abusiveness theories, not just deception; and
  • Increased attention to digital platforms, data usage, and algorithmic decision-making.

Expect these same themes to shape California’s enforcement agenda, with a particular emphasis on identifying “pattern and practice” violations affecting broad segments of consumers, rather than isolated compliance issues.

What Do You Need to Do?

In light of California’s evolving regulatory posture, financial services companies should take proactive steps to reassess their compliance frameworks with an eye toward increased state-level scrutiny.

First, companies should assume that CFPB-style UDAAP standards will remain highly relevant and ensure that policies and controls are calibrated to address unfair and abusive practices, not just deception.

Second, institutions should evaluate their operations holistically, recognizing that California regulators may take a “full lifecycle” view of consumer interactions. This includes:

  • Product design and pricing;
  • Marketing and disclosures;
  • Servicing and communications; and
  • Complaint handling and remediation practices.

Third, companies should prepare for greater inter-agency coordination within California, which may lead to:

  • More complex and multi-dimensional investigations; and
  • Parallel scrutiny across licensing, conduct, and consumer protection regimes.

Finally, organizations should closely monitor developments from the BCSA and its component agencies, particularly the DFPI, as enforcement priorities and rulemaking agendas begin to take shape under Chopra’s leadership.

Executive Order Targets Smaller Bank Participation in Mortgage Markets

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What Happened?

On March 13, President Trump issued an Executive Order titled “Promoting Access to Mortgage Credit,” addressing factors that may have negatively impacted the ability of community banks and other smaller financial institutions to participate in mortgage lending and servicing.

In order to expand access to mortgage credit, the Executive Order directs the Consumer Financial Protection Bureau (“CFPB”) and other financial regulators (the Board of Governors of the Federal Reserve System, the National Credit Union Administration, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Regulators”)) to take action to reduce regulatory burdens, modernize reporting requirements, and utilize digital mortgage processes, among other actions.

Why Does it Matter?

The Executive Order includes broad directives to the Regulators to update regulations and processes that impact the mortgage markets, including:

  • Changes to Origination Regulations: The Executive Order directs the CFPB to consider regulatory changes including tailoring Regulation Z requirements as applicable to smaller banks (including ATR and QM, TILA, RESPA, and TILA-RESPA Integrated Disclosure (TRID) rules), updating TRID timing rules, modifying or exempting small mortgage loans from caps on QM points and fees, and amending rescission rights.
  • HMDA Modernization: The Executive Order requires the CFPB to consider proposing amendments to Regulation C to increase the asset threshold for exemption from HMDA data collection and reporting requirements for smaller banks, exclude inquiries from the scope of HMDA, and reduce burdens related to disclosures.
  • Alignment of Capital and Liquidity Standards: The Executive Order directs the Regulators to consider: (a) updating capital regulations and collateral valuation and transfer systems between the Federal Reserve and Federal Home Loan Banks; (b) expanding access to longer‑dated FHLB advances tied to residential mortgage assets; (c) creating targeted FHLB liquidity programs for entry‑level housing, owner‑occupied purchase loans, and small residential builders; and (d) modernizing collateral boarding and valuation processes.
  • Construction and Housing Supply: The Executive Order directs the Regulators to consider revising supervisory guidance to: (a) exclude one-to four-family residential development and construction lending from commercial real estate concentration guidance; and (b) ensure that supervisory expectations support responsible construction lending by community banks.
  • Appraisal Modernization: The Executive Order directs the Regulators to consider certain changes to appraisal processes, including with respect to valuations performed in connection with FHA-insured and VA-guaranteed loans and with respect to the use of alternative valuations (AVMs, desktop and hybrid appraisals, and artificial intelligence valuation tools).
  • Digital Mortgage Modernization: The Executive Order requires the Regulators to consider certain changes to facilitate digital mortgages, namely eliminating unnecessary wet signature requirements, standardizing acceptance of electronic signatures, e-notes, and remote online notarization, and promoting digital mortgage standards.
  • Servicing and Supervisory Certainty: The Executive Order directs the Regulators to consider supervisory changes relating to mortgage loan servicing, including: (a) aligning supervisory expectations to support portfolio mortgage servicing as a core community banking function; (b) extending cure‑first standards to good‑faith servicing errors; (c) simplifying loss mitigation requirements; (d) issuing a proposed rule providing exemptions from complex mortgage services for smaller banks; and (e) ensuring that supervisory evaluations of performing, prudently underwritten portfolio loans do not focus on technical defects or rely on evolving supervisory interpretations.
  • Duplicative or Unnecessary Licensing Requirements: The Executive Order requires the Regulators to consider eliminating duplicative or unnecessary requirements regarding licensing or registration (i.e., MLO licensing) for mortgage loan officers of any smaller bank.

What Do You Need to Do?

While the Executive Order does not directly impose obligations on mortgage lenders and servicers, it has the potential to significantly impact the mortgage market by changing the rules of the game, particularly for community banks and smaller banks. Industry participants appear open to the possibility of reform – for example, Mortgage Bankers Association President and CEO Bob Broeksmit issued a statement applauding the focus on “addressing costly mortgage regulations that have increased costs and limited access to credit,” and supporting efforts to address other structural factors (including valuations and construction regulations) impacting access to housing.

We will continue to monitor the Regulators’ activities to implement the directives of the Executive Order, particularly as the 21st Century ROAD to Housing Act (which includes provisions on some of the same topics) advances in Congress; we encourage mortgage market participants to do the same.

UDAAP Update: New York’s FAIR Act Signed Into Law

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What Happened?

On December 19, 2025, New York Governor Kathy Hochul signed into law Senate Bill 8416, the Fostering Affordability and Integrity through Reasonable (FAIR) Business Practices Act, (the “FAIR Act”), which updates Section 349 of New York’s General Business Law (GBL). In our prior post we explained that following the law’s passage by the legislature, the FAIR Act expands the state’s consumer protection statute beyond just deceptive practices to also prohibit “unfair” and “abusive” business acts or practices, marking a major broadening of the New York Attorney General’s enforcement powers. Notably, the final law clarifies that only the Attorney General (“NYAG”) can bring claims for unfair or abusive practices, while private lawsuits remain limited to deceptive acts. The FAIR Act will take effect 60 days after signing, on February 17, 2026.

Why Does It Matter?

The FAIR Act represents a sweeping update to New York’s consumer protection law. Previously, New York law only prohibited deceptive acts and practices. The FAIR Act amends Section 349 of the GBL to also prohibit “unfair” and “abusive” acts or practices in the conduct of any business, trade, or commerce. In practical terms, this aligns New York with the consumer protection laws of almost every other state (47 of which already outlaw unfair practices) and with federal UDAAP standards. Key elements of the new law include:

Expanded Definitions

The statute now defines an “unfair” act as one that “causes or is likely to cause substantial injury” to consumers which is not reasonably avoidable and not outweighed by countervailing benefits. This definition is modeled on the Federal Trade Commission’s standard (15 U.S.C. § 45(n)). An “abusive” act is defined in line with the federal Consumer Financial Protection Act standard (12 U.S.C. § 5531(d)), i.e., something that materially interferes with a person’s understanding of a product or takes unreasonable advantage of someone’s lack of understanding or inability to protect their interests. These broad definitions mean practices that might not be outright deceptive could still be illegal if they unjustifiably harm consumers or exploit imbalances in knowledge or power.

Attorney General Enforcement & Private Rights

Importantly, the law limits enforcement of the new “unfair” and “abusive” provisions to the NYAG. Private plaintiffs can continue to sue under Section 349 only for “deceptive” acts, just as before – there is no new private right of action for unfair or abusive practices. This was a critical concession to avoid opening floodgates of litigation. However, the AG can now bring enforcement actions against businesses for unfair or abusive conduct, seeking injunctions, restitution, and civil penalties. We can expect the NYAG (which has been actively advocating for this law) to launch investigations and actions under the expanded provisions once the law is effective.

“Consumer-Oriented” Standard Preserved (for Now)

A contentious aspect of the FAIR Act was whether it would eliminate the judicially-created requirement that Section 349 cases be “consumer-oriented” (i.e. directed at the public at large, not private contract disputes). The version initially passed by the legislature removed the consumer-oriented limitation entirely, which would have meant the AG (and possibly private plaintiffs) could pursue claims even for one-off transactions or business-to-business dealings. However, in approving the law, Governor Hochul noted an agreement with legislators to ensure the act “does not override” existing case law on the consumer-oriented standard. In effect, this signals that commercial transactions and purely private disputes will not suddenly all become actionable under Section 349. The statute text still says an act can be unlawful “regardless of whether or not it is consumer-oriented” in an AG enforcement, but this may be revisited by a chapter amendment. For now, compliance should assume that private lawsuits still require a consumer-facing element (as before), while the NYAG might test the boundaries of targeting misconduct affecting small businesses or other non-consumer victims in the public interest.

What Do You Need to Do?

For banks, lenders, and other financial services companies operating in New York, the FAIR Act demands a thorough compliance review beyond the traditional focus on deception/fraud. Even though private litigation risk remains mostly unchanged (as it remains limited to deception claims), the NYAG can now act as a mini-CFPB, bringing the full range of UDAAP claims at the state level. Financial services companies must proactively ensure their products and practices meet these standards and should stay aware of any further regulatory guidance issued by the NYAG.

Ohio Mortgage Rules Have Changed: Servicing Now Covered

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What Happened?

Effective September 19, 2025, the Division of Financial Institutions (“Division”) of the Ohio Department of Commerce adopted amended rules (the “Amended Rules”) under the Ohio Residential Mortgage Lending Act (“RMLA”) to add and clarify obligations for mortgage servicers.

Why Does it Matter?

The Amended Rules are largely intended to provide clarity to mortgage servicers regarding the application of the RMLA to mortgage servicing businesses, and to implement procedures to prevent servicing problems. For entities licensed under the RMLA, the Amended Rules address registration of offices, unlicensed activity, recordkeeping, prohibited practices, servicing transfers, escrow payments, payment processing, error resolution, borrower requests for information, and a servicer’s obligations upon loss of license. The Amended Rules largely mirror the CFPB’s mortgage servicing rules (i.e., 12 C.F.R. Part 1024, Subpart C (Regulation X) and, to some extent, 12 C.F.R. Part 1026 (Regulation Z)).

Notably, an entity that violates the Amended Rules may be subject to penalties under the RMLA, which are up to $1,000 per day for each day a violation of law or rule is committed, repeated, or continued (and up to $2,000 a day of there is a pattern of repeated violations of law or rule).

Below, we highlight some of the most impactful provisions of the Amended Rules.

Amended Rules

  • Registration Requirements: The Division amended Section 1301:8-7-02 of the Ohio Administrative Code (the “OAC”) to require entities subject to the RMLA (mortgage brokers, lenders and servicers) to register each office location at which it transacts business.
  • Standards for Applications, License, and Registration: The Division amended Section 1301:8-7-03 of the OAC, to clarify that a mortgage broker, mortgage servicer, or loan originator cannot conduct business if they fail to renew their registration on or before December 31. (The Division indicated that it was amending the renewal date to correct a drafting error that incorrectly identified January 31 as the renewal date.)
  • Recordkeeping: The Division amended Section 1301:8-7-06 of the OAC, which relates to recordkeeping, to require a mortgage servicer to retain records that document actions taken with respect to a borrower’s account for four years following the date the loan is discharged or transferred to another servicer; and to maintain specified documents and data in a manner that facilitates compiling the documents and data into a servicing file within five days. (The rule does not expressly address maintenance of records of telephone calls with borrowers.) While the rule requires retention of the same records required under Regulation X (12 C.F.R. § 1024.38(c)), note that the retention period is much longer than Regulation X’s and does not exempt small servicers under Regulation X.
  • Prohibited Practices: The Division amended Section 1301:8-7-16 of the OAC, to add a list of actions specific to servicing that constitute improper, fraudulent, or dishonest dealings under Ohio Revised Code section 1322.40.  Specifically, the rule prohibits a servicer from, among other things:
    • assessing a borrower any premium or charge related to force-placed insurance unless the servicer: (i) has a reasonable basis to believe that the borrower has failed to comply with the residential mortgage loan contract’s requirement to maintain hazard insurance; and (ii) delivers or mails to the borrower a written notice at least 45 days before assessing such charge or fee;
    • misrepresenting or omitting any material information in connection with the servicing of a residential mortgage loan, including misrepresenting the amount, nature, or terms of any fee or payment due or claimed to be due on a residential mortgage loan, the terms and conditions of the servicing agreement, or the borrower’s obligations under the residential mortgage loan;
    • failing to apply payments in accordance with a servicing agreement or the terms of a note; (d) making payments in a manner that causes a policy of insurance to be canceled or causes property taxes or similar payments to become delinquent;
    • failing to credit a periodic payment to the borrower’s account as of the date of receipt, except when a delay in crediting does not result in any charge to the borrower or in the reporting of negative information to a consumer reporting agency (except where the servicer specifies in writing requirements for the borrower to follow in making payments, but accepts a payment that does not conform to the requirements, where the servicer has five days to credit the payment);
    • requiring any amount of money to be remitted by means which are more costly to the borrower than a bank or certified check or attorney’s check from an attorney’s account to be paid by the borrower;
    • charging a fee for handling a borrower dispute, facilitating routine borrower collection, arranging a forbearance or repayment plan, sending a borrower a notice of nonpayment, or updating records to reinstate a loan; or
    • pyramiding late fees.
  • Mortgage Servicing Definitions: The Division added Section 1301:8-7-35 to the OAC, which defines terms relevant for the provisions of other new sections (as discussed below), including: (a) “confirmed successor in interest,” “escrow account,” and “qualified written request,” which are consistent with Regulation X; and (b) “federal lending law” and “residential mortgage loan,” the latter of which is defined to limit the Amended Rules’ application to closed-end loans, consistent with Regulation X and Regulation Z.
  • Mortgage Servicing Transfers: The Division added Section 1301:8-7-36 to the OAC, to prohibit a transferee servicer from treating an on-time payment made to the old servicer within the 60-day period following the transfer of servicing. It also requires the old servicer to either forward the payment to the new servicer, or return it to the borrower and notify the borrower of the proper recipient. This rule generally mirrors 12 C.F.R. § 1024.33(c).
  • Escrow Accounts: The Division added Section 1301:8-7-37 to the OAC, which requires a mortgage servicer to: (i) make all required escrow payments in a timely manner, and (ii) timely return any payments due to the borrower. It also allows a servicer, if the borrower agrees, to credit any amount remaining in a borrower’s account to a new escrow account for a new loan. This rule generally mirrors 12 C.F.R. §§ 1024.34 and 1024.17(k).
  • Error Resolution Procedures: The Division added Section 1301:8-7-38 to the OAC, which establishes error resolution procedures that mirror the requirements of the CFPB mortgage servicing rules (12 C.F.R. § 1024.35).
  • Requests for Information: The Division added Section 1301:8-7-39 to the OAC, which establishes information request procedures that mirror the requirements of the CFPB mortgage servicing rules (12 C.F.R. § 1024.34).
  • Mortgage Servicer Obligations upon Loss of License: Finally, the Division added Section 1301:8-7-40 to the OAC, which provides that the revocation, suspension, or failure of a servicer to obtain or maintain a license does not affect a servicer’s obligations under a preexisting contract with a lender or borrower.

What To Do Now?

The Amended Rules significantly expand the requirements applicable to mortgage servicers subject to the RMLA. While many of the Amended Rules mirror those under the CFPB’s mortgage servicing rules, certain provisions impose additional obligations on mortgage servicers and/or apply to servicers that may otherwise be exempt from certain requirements under the CFPB’s mortgage servicing rules (e.g., small servicers). Accordingly, mortgage servicers should carefully review the Amended Rules and ensure that their policies, procedures, and controls are updated as appropriate to ensure compliance. Alston & Bird’s Consumer Financial Services Team is actively engaged and monitoring these developments and can assist with any compliance concerns regarding the changes imposed by the Amended Rules.