b'Mortgage Actions by Year (with Recoveries) Number of Actions Amount of Recovery68 49$1,336.2M $3,642.4M 49$863.9M22$1,154.8M 27$174.1M13$99.6M2015 2016 2017 2018 2019 2020guidelines are all qui tam suits where the governmentPresident Trump in March and extended by President declined to intervene.Biden, borrowers are protected from foreclosure State enforcement actions also continued to decline,on federally backed loans until March 2021 and on with only six publicly reported actions in 2020 (one ofGSE-backed loans until February 2021. A number of which was a joint effort with the CFPB). The continuedstates and localities issued similar directives, among winding-down of Great Recession-era litigation likelythem California, Massachusetts, New York and the contributed to this decline, with only one actionDistrict of Columbia, who passed laws or executive relating back to that period. The majority of stateorders providing geographic-based moratoriums actions reflected an increasing focus on debt collectionon foreclosures and evictions. The CARES Act also practices. Of the six actions, the majority focusedprovides that borrowers have the right to request and on mortgage servicer compliance with state debtobtain a forbearance for up to 180 days. The CFPB collection statutes.also published an Interim Final Rule releasing servicers from certain Regulation X requirements when providing Several key policy changes also occurred in 2020,loss mitigation services to borrowers under the CARES including the CFPBs rescission of the 2015 Real EstateAct. The CFPB and the Conference of State Bank Settlement Procedures Act (RESPA) Marketing ServicesSupervisors (CSBS) also issued a joint statement about Agreement (MSA) Bulletin. The rescission was welcomemortgage loan forbearances issued under the CARES news to the industry, as the 2015 Bulletin viewed MSAsAct. The statement indicated that during upcoming with disfavor, but the CFPB provided little additionalexaminations the CFPB and state bank regulators guidance as to how to structure a compliant MSA.would likely focus on issues relating to servicer and Instead, the CFPB outlined its primary concerns withoriginator communications with borrowers about their MSAs, and emphasized that the legality of an MSA isrights. The handling and unwinding of forbearance case-specific. Nonetheless, the Bureaus change inrelief and foreclosures will likely draw the scrutiny of tone is a welcome development for the industry.regulators and enforcers alike in 2021; to date, however, The COVID-19 pandemic has also shaped federal andthere have been no publicly announced enforcement state agency priorities this year, at least in the regulatoryactions related to mortgage servicers compliance with space. Under the CARES Act, signed into law byCOVID-19 relief provisions.15'