As we talked about on Friday, the Bureau is trying to put the customer service back in mortgage servicing. We are proposing nine rules to address issues that consumers face when paying their mortgage loans, dealing with escrow accounts, or figuring out what to do when they have fallen behind on their loans. We want to get rid of surprises and runarounds by servicers, which are often hired by creditors and investors to manage home loans.
You may not know this, but getting comments from the public – you – is an essential part of the agency rulemaking process. Federal law generally requires that the public get an opportunity to read a proposed rule and submit comments before the rule is finalized. Agencies publish the proposed rules in the Federal Register.
All too often, this opportunity passes, and the public doesn’t weigh in. This, in part, is because not everybody skims the Federal Register every day.
We want to make it easier for consumers and small businesses to tell us what they think about the rules that we are working on. To do that, we’ve partnered with Cornell University, which has launched a project called as part of the Cornell e-Rulemaking Initiative, to get your take on our new proposed mortgage servicing rules.
is not a government website. It is operated by students and staff at Cornell, with the goal of making it easy for people to participate in the rulemaking process. They are researching how to remove barriers to public participation, and we are excited to be partnering with them.
- First, the Cornell folks realized that all too often, the public is unaware of the rule-writing process, so they are spreading the word through a social media campaign.
- Next, they realized that most members of the public are not interested in reading a Federal Register notice that may easily be 100 pages or more. They use “layering” of information so you can quickly get an overview, but have the ability to dive deeper if you are interested in a particular point or subtopic.
- Also, they realized rulemakings involve complicated issues that can benefit from dialogue rather than just one-time letter writing. Besides presenting the information, Regulation Room hosts a forum for discussion. Even better, the forum is moderated to help answer questions and get more detailed information and feedback. Feel free to say that you do or don’t like our rule, but be prepared for a moderator to ask you to be more specific: Why do you feel that way? How could it be improved?
- Finally, they realized that most members of the public are unfamiliar with the formal commenting process at (the official government site). So Regulation Room presents information and conducts a conversation right when a proposed rule first comes out, and then closes its forum down about a week before the end of the comment period so that the Cornell team can assemble all the feedback they have received into an official comment. People who have participated get one last chance to react to the summary before it is submitted formally to the CFPB through . And, like all other formal comments, we will read and consider it.
We are excited about this project for two reasons.
First: We really do want to hear what you think of our proposals on mortgage servicing.
Second: We want to learn as much as possible from this experience about how to get more public feedback in future rulemakings.