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Comments: Prudential Standards for Non-Bank Mortgage Servicers

State regulators sought public input on proposed regulatory prudential standards for nonbank mortgage servicers, as the state-regulated industry covers an increasing share of this market. Public comments help inform state regulators as we continue to develop a regulatory structure for nonbank servicers.

CSBS met face to face with a handful of stakeholders to answer questions and clarify specific matters prior to comment submission. Some of these stakeholders followed with written comments included on this page. Others did not.

Additionally, CSBS has noted articles and attorney blogs, that while no submitted as formal comments, have been considered in our comment review. These are attached as well.

The proposed standards aim to:  

  • Provide better protection for borrowers, investors and other stakeholders in the occurrence of a stress event that could result in harm; 
  • Enhance effective regulatory oversight and market discipline over these entities; and 
  • Improve transparency, accountability, risk management and corporate governance standards. 


Institution Comments
American Bankers Association PDF
Alston & Bird  PDF
Community Home Lenders Association Word
Credit Suisse PDF
Freedom Mortgage PDF
Housing Policy Council PDF
Independent Community Bankers of America PDF
Manufactured Housing Institute PDF
Mayer Brown PDF
Mayer Brown PDF
Michel, Norbert Word
Mortgage Bankers Association PDF
National Consumer Law Center PDF
Quicken Loans PDF
Union Home Mortgage PDF
Urban Institute PDF
Veterans United PDF

Due Date

Comments were due by December 31, 2020


The materials for public consideration are as follows:

Contact Information

Please submit comments to

1129 20th Street, N.W., 9th Floor, Washington, DC 20036 | Tel. 202.296.2840 | Fax. 202.296.1928