source:
  type: regulation
  id: cfpb-reg-x-servicing-nprm-2024
  authority: CFPB Proposed Rule — Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties (Regulation X)
  status: proposed
  description: PROPOSED RULE (NPRM, 89 FR 60204, July 24, 2024; comment period closed Sept 9, 2024; status uncertain under the diminished CFPB and the March 2026 mortgage EO). Would remove most of the §1024.41 application framework and replace it with a request-triggered loss-mitigation review cycle and foreclosure procedural safeguards, broaden the loss-mit request definition to any oral/written ask, hold foreclosure and suppress fees for the entire cycle, and require Spanish-language translations of certain communications. NOT in force — for readiness mapping only.
obligations:
- id: cfpb-reg-x-servicing-nprm-2024-streamline-procedural-safeguards
  canonical_id: cfpb-reg-x-servicing-nprm-2024-streamline-procedural-safeguards
  section: 'CFPB NPRM §1024.41 — PROPOSED: replace the application framework with foreclosure procedural safeguards'
  description: PROPOSED. The rule would remove most §1024.41 incomplete/complete-application requirements and replace them with a foreclosure-procedural-safeguards framework.
  type: proposed
  audit_question: Has [LENDER] assessed how removal of the §1024.41 application framework (replaced by procedural safeguards) would change its loss-mit P&P?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: The CFPB is proposing to streamline and simplify Regulation X's loss mitigation procedures by removing most of the existing requirements regarding incomplete and complete loss mitigation applications and replacing them with a new framework based on foreclosure procedural safeguards.
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec (CFPB NPRM 2024). Proposed streamlining of §1024.41.
  program_review: Does the program track the proposed §1024.41 overhaul (application model → procedural safeguards) and map where the current loss-mit P&P would need to change?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
- id: cfpb-reg-x-servicing-nprm-2024-review-cycle-on-request
  canonical_id: cfpb-reg-x-servicing-nprm-2024-review-cycle-on-request
  section: 'CFPB NPRM §1024.41(f)(2) — PROPOSED: loss-mit review cycle begins on a request >37 days before sale'
  description: PROPOSED. A loss mitigation review cycle would begin when a borrower requests loss-mit assistance more than 37 days before a foreclosure sale, gating foreclosure until a procedural safeguard is met.
  type: proposed
  audit_question: Has [LENDER] mapped how a request-triggered loss-mit review cycle (vs the current complete-application trigger) would change its foreclosure-hold logic?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: Under proposed § 1024.41(f)(2), a loss mitigation review cycle begins when a borrower makes a request for loss mitigation assistance more than 37 days before a foreclosure sale.
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec. Proposed §1024.41(f)(2) review-cycle trigger.
  program_review: Does the program map the shift from application-based to request-triggered foreclosure holds (the proposed loss-mit review cycle)?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
- id: cfpb-reg-x-servicing-nprm-2024-request-any-oral-or-written
  canonical_id: cfpb-reg-x-servicing-nprm-2024-request-any-oral-or-written
  section: 'CFPB NPRM §1024.31 — PROPOSED: "request for loss mitigation assistance" = any oral or written ask for relief'
  description: 'PROPOSED. A new defined term: any oral OR written communication through usual servicing channels whereby a borrower asks for mortgage relief triggers the review cycle.'
  type: proposed
  audit_question: Has [LENDER] assessed whether its intake can recognize an ORAL or written request for relief through any usual channel as the trigger (not just a written application)?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: The CFPB proposes to add request for loss mitigation assistance as a new defined term in § 1024.31 to mean any oral or written communication, occurring through any usual and customary channel for mortgage servicing communications, whereby a borrower asks a servicer for mortgage relief.
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec. Proposed §1024.31 definition.
  program_review: Does the program account for the broad oral-or-written request definition — would intake/training catch an oral request as the trigger?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
- id: cfpb-reg-x-servicing-nprm-2024-no-advance-foreclosure-during-cycle
  canonical_id: cfpb-reg-x-servicing-nprm-2024-no-advance-foreclosure-during-cycle
  section: 'CFPB NPRM §1024.41(f) — PROPOSED: no begin/advance of foreclosure during the review cycle'
  description: PROPOSED. During a loss mitigation review cycle the servicer may not begin or advance foreclosure, and borrowers are protected from accrual of certain fees.
  type: proposed
  audit_question: Has [LENDER] mapped the proposed foreclosure-hold-for-the-whole-cycle protection against its current dual-tracking controls?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: During a loss mitigation review cycle, the servicer may not begin or advance the foreclosure process and borrowers would also be protected against the accrual of certain fees.
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec. Proposed cycle foreclosure/fee protection.
  program_review: Does the program map the proposed full-cycle foreclosure hold against current §1024.41(g) dual-tracking controls?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
- id: cfpb-reg-x-servicing-nprm-2024-fee-protection-during-cycle
  canonical_id: cfpb-reg-x-servicing-nprm-2024-fee-protection-during-cycle
  section: 'CFPB NPRM §1024.41(f)(3) — PROPOSED: no fees beyond on-time-payment amounts during the cycle'
  description: PROPOSED. During a loss mitigation review cycle, no fees beyond the amounts that would have accrued had the borrower paid on time and in full shall accrue.
  type: proposed
  audit_question: Has [LENDER] assessed whether its fee logic could suppress non-contractual fees for the entire proposed review cycle?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: during a loss mitigation review cycle, no fees beyond the amounts scheduled or calculated as if the borrower made all contractual payments on time and in full under the terms of the mortgage contract shall accrue
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec. Proposed §1024.41(f)(3) fee provision.
  program_review: Does the program map the proposed cycle-long fee suppression against current fee-assessment systems?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
- id: cfpb-reg-x-servicing-nprm-2024-spanish-translations
  canonical_id: cfpb-reg-x-servicing-nprm-2024-spanish-translations
  section: 'CFPB NPRM — PROPOSED: Spanish-language translations of certain written communications to all borrowers'
  description: PROPOSED. Servicers would be required to provide Spanish-language translations of certain written early-intervention and loss-mit communications to all borrowers.
  type: proposed
  audit_question: Has [LENDER] assessed its readiness to provide Spanish-language translations of the required early-intervention and loss-mit notices to all borrowers?
  workflow_phase: default_servicing
  owner_role: default_servicing_director
  secondary_owner_role: cco
  cadence: monitor-until-final
  consequence: If finalized, the §1024.41 application model is replaced; an unmapped P&P cannot pivot quickly.
  tags:
  - cfpb
  - reg-x
  - servicing
  - loss-mitigation
  - PROPOSED
  - nprm
  - default
  - watch
  primary_source:
    tier: 1
    authority: CFPB NPRM — Streamlining Mortgage Servicing (Regulation X), 89 FR 60204 (proposed July 24, 2024)
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x
    snapshot_id: 02f57f0ca2866fec
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: the proposed rule would require mortgage servicers to provide Spanish-language translations of certain written communications to all borrowers.
    drafter_attestation: Verbatim from FR snapshot 02f57f0ca2866fec. Proposed LEP/Spanish-language requirement.
  program_review: Does the program account for the proposed Spanish-language translation requirement on early-intervention and loss-mit notices?
  file_review: 'PROPOSED rule — no in-force file duty yet. The review is a program-level readiness map: where would the current loss-mit P&P have to change if this finalizes?'
  judgment: false
