Potential Postponement of Foreclosures Until 2022

[Chris Seveney]

Recently the CFPB released a notice of proposed rulemaking on that would amend Regulation X to provide a special pre-foreclosure review period prohibiting servicers from starting foreclosures until after December 31, 2021. Here is the 150 page report., some key points are it does not apply to small servicers (5,000 loans or less). Curious to your opinion.

My initial reaction is currently their is a COVID eviction moratorium but I have seen many states put a carte blanche to all evictions whether COVID or unrelated (Allegheny county PA for example). So my concern would be in the courts not taking on these cases no matter whether it does or does not apply. 

Love to hear others opinions.