Survey on DFS’ Force-Placed Insurance Proposal

Thank you for participating in this survey! Your responses to the following questions will enable the Association to assess the potential impact of this proposal on New York credit unions.

Within the DFS’ proposal, key definitions include:

· Affiliate: Any company that controls, is controlled by, or is under common control with an insurer or insurance producer.

· Servicer: A person or entity engaging in the servicing of mortgage loans in New York State.

· Insurer: An insurer that is licensed or required to be licensed to do business in this state.

The proposed regulation requires that if an insurer, insurance producer or affiliate mails notices to a borrower on behalf of a servicer, they must mail written notices complying with CFPB regulations that don’t take effect nationally until January 2014. For example, the notice must give the homeowner 45 days’ notice that: the borrower’s hazard insurance is expiring or has expired; hazard insurance is required on the borrower’s property; and the servicer has purchased or will purchase, as applicable, such insurance at the borrower’s expense. This requirement is imposed on mortgage servicers by CFPB rule 1024.37, which takes effect Jan.10, 2014.