CFPB: What Mortgage Lenders & Servicers Must Know

The CFPB writes and enforces most federal consumer mortgage rules—TRID, servicing (Reg X), ATR/QM (Reg Z), ECOA (Reg B), and HMDA guidance. Your must-do: keep TRID, servicing, ATR/QM, and ECOA controls current and exam-ready.

Who they are &
who they oversee

Reg X (RESPA)

Servicing requirements.

Reg Z / ATR-QM

Ability-to-repay & qualified mortgages.

TRID & HMDA

Integrated TILA-RESPA disclosures & Filing platform & guides.

Reg B (ECOA)

Nondiscrimination and related requirements.

What matters for mortgages

TRID disclosures

Loan Estimate(Closing Disclosure) & timing/tolerance rules; forms & FAQs available.

Servicing rules (Reg X)

General policies & procedures (§1024.38), early intervention, continuity of contact, and loss-mit timelines.

ATR/QM (Reg Z)

Make/retain evidence of a reasonable, good-faith ATR determination; know General QM thresholds.

ECOA/Reg B

Fair-lending requirements and adverse-action obligations.

HMDA

File via the FFIEC HMDA Platform per current FIG/exam procedures.

Top Compliance Obligations

Issue TRID forms accurately & on time

Maintain servicing policies & procedures (Reg X §1024.38)

Make/retain ATR/QM determinations

ECOA compliance

HMDA filing & edit resolution

Recent changes & watchlist

Mortgage servicing proposed changes (2024)

CFPB proposal to amend servicing rules; track Fast Facts and redline.

HMDA updates

Annual data releases & platform tools for filing/publication.

ECOA resources

Updated guidance hub for Reg B (2025).

How we help (ARC by VeritIQ)

Controls & evidence mapping

→

For TRID clocks, ECOA adverse-action timing, Reg X loss-mit deadlines, and ATR/QM documentation.

Report Scheduler

→

To auto-generate HMDA, QC, flood exceptions, and fair-lending reports.

Interactive dashboards

→

Surfacing aging RFIs/QWRs, valuation-copy timeliness, and exception trends.

Workflow queues

→

To run examination request lists and track turn-times.

Penalties & Enforcement Posture

CFPB continues active enforcement on UDAAP, servicing failures, and fair-lending issues, coordinating with prudential agencies and (for pattern/practice) DOJ.

Frequently Asked Questions

What is covered by Reg X servicing?

→

Most mortgage loans; see the scope and general servicing policies at §1024.30–41 and §1024.38.

What counts as “application” for TRID timing?

→

TRID uses a six-item application definition; you can’t require more just to issue a Loan Estimate.

How long must ATR/QM records be kept?

→

At least three years after consummation (practically, many keep longer).

Where do I file HMDA?

→

On the FFIEC HMDA Platform; follow the current year’s FIG/exam procedures.

Does ECOA apply before application?

→

Reg B prohibits discouragement on a prohibited basis; ensure marketing/sales scripts avoid discouraging statements.