NAMFS Submits Comments Regarding CFPB Proposal Extending Moratoriums

NAMFS appreciates the opportunity to submit comments regarding the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed amendments to Regulation X.  We are the oldest and largest Mortgage Field Service trade association.  Our members provide services at properties in delinquency/default to support the mortgage default industry. They consist of field service providers, select servicers, software companies and other ancillary services and many of these firms/companies are small and/or minority-owned businesses.  These entities have been negatively impacted financially from the extended moratoriums, directly and indirectly affecting thousands of jobs. Our organization has been supportive of the actions the Bureau has taken prior to this latest proposal.  We urge the Bureau to consider the recommendations below, which we feel balance the benefit to the economy while still accomplishing the Bureau’s goals.