Jul

Client Bulletin: July 22, 2022

A Note on the GSE-Required Review of LIBOR ARM Notes

Freddie Mac and Fannie Mae have issued directives related to their LIBOR loans, requiring a review of all LIBOR ARM Notes. The purpose of this review is to identify any Notes that have non-standard index replacement language (or no index replacement language at all), and do not contain language recommended by the Alternative Reference Rates Committee (ARRC).

The purpose of this communication is to ensure our client partners are aware of this requirement, and to have you confirm that you will be completing the Note review for your ARM portfolio. Notes without the recommended replacement language — or non-standard replacement language — are to be identified, and you are to communicate back to the GSEs as specified in the announcements.

Freddie Mac has indicated a deadline of Sept. 9, 2022 to complete this review. No deadline has been stated by Fannie Mae at this time. However, Cenlar is requesting that you confirm and provide the results of your review by Sept. 1, 2022.

We suggest that you discuss these requirements with your legal and compliance department.

Links to the Freddie Mac and Fannie Mae guidance can be located below:

Legacy LIBOR Non-Standard Note Review | Fannie Mae
https://guide.freddiemac.com/app/servicing/bulletin/2022-1(see section addressing LIBOR)

Additional Steps to Aid MoveIT Migration to the Cloud

As we shared earlier this month, Cenlar has begun preparations to migrate MoveIT, the application we use to share files with you, to the cloud. We plan to complete the migration by early October.

Your help has made our cloud migration effort seamless thus far. Just as we did with other phases of our cloud effort, we need your assistance to make this transition as smooth as possible.

Please carefully read the following instructions for whitelisting and testing information. There are two additional IP addresses not included in our last communication that you must whitelist, for a total of four.

Whitelisting IP Addresses

You will need to update IP addresses for servers impacted by the MoveIT migration before Aug. 15 to ensure security protocols do not prevent you from testing and accessing the migrated environments. The new IP addresses are listed here:

Server	New IP
Transfer Server Outbound	12.151.180.140
Automation Server Inbound	12.151.180.139
Disaster Recovery Transfer Server Outbound	12.151.180.236
Disaster Recovery Automation Server Inbound	12.151.180.235

In addition, you will need to validate the following ports and protocols:

Transfer Servers Outbound (IP Address 12.151.180.140 and 12.151.180.236)

Protocol	Port
SFTP/SCP (FTP/SCP over SSH)	22
FTPS (FTP over SSL/TLS)	20021 to 20025
HTTPS (HTTP over SSL/TLS)	443

Automation Servers Inbound (IP Address 12.151.180.139 and 12.151.180.235)

Protocol	Port
SFTP/SCP, FTPS, HTTPS	Specifically configured for your FTP host

Please note, you will also need to keep our old firewall rules active (12.26.45.84, 12.26.45.67 and 12.26.45.24) during this transition in order to maintain access to the servers. We will reach out to you once we have confirmed the migration is complete and it is safe to deactivate the legacy IP address information.

Testing

We are asking that all clients perform testing in advance of the migration date. Testing capability will be enabled in mid-August.

In the coming weeks, we will send you instructions on how to test, as well as communicate to you when the testing period begins officially.

We are looking forward to completing this migration, and thank you for assisting us as we continue to advance and evolve Cenlar’s technology. These efforts will enable us to better serve you and your homeowners.

Please share the information in this notice with your IT team, and if you have any questions, contact your client manager.

New Support Mailbox Established for General Ledger Clients

An updated Client Support Options Matrix has been posted on CenAccess, which includes a new Investor Reporting support mailbox for our general ledger clients.

All clients should use one of mailboxes below for any questions related to Investor Reporting. Please do not send us any questions on this issue via CCM.

New XML/NLAI Code for Some Condo Units

We have recently updated the New Loan Interface file (XML) and the New Loan Automated Interface (NLAI) with a new code for certain condo units.

Specifically, we’ve added a new code of “N” for the <HazardTypeInsrCoverageCode> field and Type Coverage Code, respectively, for when the unit owner’s condo insurance (H06) is not escrowed or has a non-escrowed loan. If the unit owner’s condo insurance is being escrowed, you would continue to use the code of “C”.

This change will take effect in the next 60 days, with a target introduction date of Monday, Sept. 19.