CFPB Signals December 2025 Finalization of Mortgage Servicing Rule Revisions

On September 17, 2025, the Consumer Financial Protection Bureau confirmed plans to finalize comprehensive mortgage servicing rule revisions by December 2025, following the July 2024 proposed rulemaking period. The updated regulations place increased emphasis on property preservation compliance, borrower notification requirements, and servicer documentation standards for delinquent loans and foreclosed properties. Mortgage servicers operating in Nevada communities including Las Vegas, Henderson, and Reno must prepare for enhanced compliance obligations effective upon rule finalization.

The CFPB's regulatory agenda signals heightened scrutiny of property preservation activities, with enforcement actions anticipated for servicers failing to maintain collateral protection, document preservation work adequately, or notify borrowers properly about property inspections and maintenance activities performed during delinquency and foreclosure proceedings.

Key Property Preservation Compliance Requirements in Proposed Rule

The July 2024 proposed mortgage servicing rule revisions introduce specific requirements affecting property preservation vendors and servicers managing foreclosure properties:

• Timely Property Preservation Initiation: Servicers must perform initial property inspections within specified timeframes after borrower delinquency milestones, with documentation of inspection timing and results
• Borrower Notification Standards: Enhanced requirements for notifying borrowers before conducting property inspections, winterization, securing, or other preservation activities, including notification content, timing, and delivery method specifications
• Comprehensive Documentation Requirements: Detailed records of all property preservation activities including timestamped photographs, itemized invoices, vendor certifications, and work completion verification
• Reasonable and Necessary Standard: Property preservation expenses must be reasonable in amount and necessary to protect collateral value, with servicer burden to justify costs that exceed typical market rates
• Expense Pass-Through Limitations: Restrictions on charging borrowers for property preservation costs when expenses result from servicer delays, duplicate inspections, or unnecessary work
• Third-Party Vendor Oversight: Servicer responsibility for ensuring property preservation contractors comply with federal and state consumer protection laws during borrower contact attempts and property access activities

Nevada Servicer Implications and Compliance Gaps

Nevada mortgage servicers managing delinquent loan portfolios across Summerlin, Green Valley, and Pahrump should assess current property preservation procedures against CFPB proposed requirements to identify compliance gaps requiring remediation before December 2025 finalization. Common deficiencies identified in CFPB enforcement actions include:

• Inadequate Borrower Notification: Failure to provide advance notice before property inspections or preservation activities, or notice content missing required disclosures
• Insufficient Documentation: Property preservation invoices lacking itemized expense breakdowns, missing photographs, or incomplete vendor work certifications
• Delayed Inspection Cycles: Monthly property inspections not performed within investor servicing guide timeframes, creating collateral protection gaps
• Excessive Expense Charges: Pass-through costs to borrowers exceeding reasonable market rates or including unnecessary duplicate inspections
• Vendor Compliance Failures: Third-party preservation contractors violating FDCPA, TCPA, or state consumer protection laws during door knock attempts or borrower contact

CFPB Enforcement Authority and Penalty Exposure

The CFPB maintains broad enforcement authority over mortgage servicers through the Dodd-Frank Act and Regulation X (Real Estate Settlement Procedures Act). Non-compliance with property preservation requirements can trigger enforcement actions including civil money penalties, restitution orders to borrowers, and corrective action plans requiring servicer procedure overhauls. Nevada servicers operating in Downtown Las Vegas, Sun City Anthem, and Las Vegas Strip area should prioritize compliance readiness ahead of December 2025 rule finalization to avoid enforcement exposure.

Compliance Preparation Steps for Nevada Servicers

Mortgage servicers should implement the following compliance preparation measures before December 2025 CFPB rule finalization:

• Policy and Procedure Review: Audit existing property preservation policies against proposed CFPB requirements, documenting gaps and remediation plans
• Borrower Notification Templates: Develop or revise property inspection notification letters ensuring compliance with proposed content, timing, and delivery method requirements
• Vendor Oversight Enhancement: Strengthen third-party property preservation vendor oversight including compliance training, audit procedures, and contract terms holding vendors accountable for FDCPA/TCPA violations
• Documentation Standards Upgrade: Implement enhanced documentation requirements for property preservation activities including standardized photography protocols, itemized invoice templates, and work completion certifications
• Servicing Platform Configuration: Update loan servicing software workflows to enforce inspection timing requirements, borrower notification triggers, and expense reasonableness validations
• Staff Training Programs: Train servicing personnel on updated CFPB property preservation requirements, documentation standards, and borrower notification obligations

State Attorney General Coordination and Parallel Enforcement

While the CFPB leads federal mortgage servicing enforcement, state attorneys general including Nevada AG office maintain independent enforcement authority under state consumer protection statutes and the Homeowner Bill of Rights. Nevada servicers should anticipate coordinated federal-state enforcement actions targeting property preservation compliance deficiencies, creating dual penalty exposure and reputational risk requiring proactive compliance readiness across Sunrise Hospital vicinity and throughout Clark County and Washoe County.

CFPB-Compliant Property Preservation Documentation Services

For Nevada mortgage servicers requiring comprehensive delinquency property inspections aligned with CFPB proposed documentation standards, Lake Mead Mobile Notary provides professional field inspection services throughout Clark County and Washoe County. Property condition assessments with timestamped photographs, detailed condition reports, and GPS-verified inspection documentation supporting servicer compliance obligations available with 24-48 hour turnaround.

Book occupancy verification services at https://lakemeadmobilenotary.com/book or call/text (702) 748-7444 for CFPB-compliant property preservation documentation meeting enhanced mortgage servicing rule requirements expected December 2025.

This content is for informational purposes only and does not constitute legal or regulatory compliance advice. Mortgage servicers should consult qualified legal counsel and compliance professionals regarding specific CFPB mortgage servicing rule requirements and implementation strategies. Information reflects proposed rule as of September 2025; final rule provisions may differ upon December 2025 issuance.