Advocacy Comments on Consumer Financial Protection Bureau Request for Information Regarding 2013 Real Estate Settlement Procedures Act Servicing Rule Assessment
July 10, 2017
The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the Consumer Financial Protection Bureau (CFPB or the Bureau) Request for Information Regarding 2013 Real Estate Settlement Procedures Act Servicing Rule Assessment.[1] Advocacy encourages the CFPB to consider less burdensome alternatives for small entities as part of the assessment process. Specifically, Advocacy believes that the threshold for the small servicer exemption is too low and some of the foreclosure requirements are too burdensome for small entities. Advocacy also believes that the assessment of the rule would benefit from further outreach to small entities.