Subservicers may increase prices to recover those costs, but Hampel said he doesn't anticipate any potential rate hikes to be big ones. But consolidation among loan servicing firms could result from the new rules, he said.

One aspect of the rule that could affect credit unions is the requirement that servicers provide borrowers with all available options to avoid foreclosure, and that servicers hold off on foreclosure until those options are exhausted.

“That could delay the time from the initial expectation of need to the actual execution of the foreclosure,” he said, which could increase foreclosure costs and reduce recoveries.

Such a situation would probably be rare, Hampel added, and will become even more uncommon as the housing market returns to normal and foreclosures “fade back into being as rare as they once were for credit unions.”

Hampel said his methodology for determining 131 credit unions fall under the servicing rule includes counting 1^st mortgages held in portfolio, 1^st mortgages sold but still serviced, and closed-end 2^nd mortgages, which are also subjected to the rule. Those 131 credit unions represent just 2.6% of those that offer mortgage loans; however, they service 56% of total industry mortgages, $231 billion out of an industry total of $414 billion, he said. –[email protected]