Today, just over two million homeowners are in COVID-19 hardship foreclosure forbearance. The Consumer Financial Protection Bureau (CFPB) recently stated that over 3% of all borrowers are now four months or more behind on their mortgages, which is the usual point when a foreclosure may be initiated. Not even during the worst of the 2009 financial crisis have so many borrowers been so far behind. In response, the CFPB issued a temporary rule under the Real Estate Settlement Procedures Act and Regulation X (RESPA), effective Aug. 31, that offers opportunities for investors and servicers to avoid foreclosures and provide better outcomes for themselves and the communities they serve by allowing evaluations of loss mitigation options based on incomplete applications.e
Moratoriums are lifting, but when?
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