Mortgage Servicing and Loan Modifications: 4.2.5.4.1 Introduction
When the CFPB first considered a rule to implement the TILA periodic statement requirements, industry commenters suggested that the rule should not apply to borrowers in bankruptcy because accounting issues related to the treatment of prepetition arrearages were problematic. The CFPB’s initial response was practical—complexity alone does not justify a complete exemption, but may warrant certain adjustments.