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Brace Receives CFPB No-Action Letter Template for its Loss Mitigation Platform

Brace, a best-in class enterprise loss mitigation platform for lenders and servicers, announced that the Consumer Financial Protection Bureau (Bureau) has granted its application for a No-Action Letter Template covering Brace’s innovative loss mitigation platform under the Bureau’s Policy on No-Action Letters.

The company provides solutions for loss mitigation, which is what the mortgage-servicing industry refers to as the process where borrowers and their servicer work together to avoid a foreclosure.

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Brace works behind the scenes as a white-labeled loss mitigation customer- and servicer-workflow automation platform. The company’s digital borrower solicitation packets help servicers streamline the information and document gathering process using automated financial integration and intelligent workflow. Brace’s platform then takes that borrower-provided information, servicer system data, and proprietary investor waterfalls to quickly and accurately assist loss mitigation decisions while also ensuring servicers adhere to the Real Estate Settlement Procedures Act (RESPA) timelines.

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Because Brace’s digital loss mitigation application is the first of its kind, Brace engaged the Bureau with respect to the certain provisions of RESPA and the Fair Debt Collection Practices Act (FDCPA). Mortgage servicers can now leverage Brace’s No-Action Letter Template to obtain a Bureau No-Action Letter that removes any ambiguity.

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The United States is facing another potential housing crisis and borrowers need a way to digitally submit a request for forbearance and additional loss mitigation outcomes. Before Brace, an exhaustive digital option did not exist. Following a forbearance, mortgage servicers are required to review borrowers for a permanent loss mitigation solution. In order to complete that review, servicers may request financial information and documentation from borrowers. In a constantly changing regulatory environment, it is challenging to collect all the necessary information while also maintaining compliance with RESPA requirements.

“An end-to-end loss mitigation platform which facilitates efficient communication between borrowers and servicers is crucial in this environment and we are grateful to the Bureau for issuing the No-Action Letter Template in response to our application,” said Eric Rachmel, CEO of Brace.

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