This update on the Fannie Mae Future Changes for Investor Reporting Implementation will be brief. Since Fannie Mae expects each servicer to complete Fannie Mae’s FCIR Operational Readiness and Acknowledgement Form by December 1, 2016, “Are we Ready?” is now the pressing question.
At this point, all of the pieces of this effort are beginning to fall into place. Testing is concluding, and Black Knight Financial Services (BKFS) continues to roll out test results to its Client Collaboration Site. Cenlar, like other BKFS clients, is utilizing training resources provided by BKFS. Our entire Fannie Mae Investor Reporting staff has begun participating in BKFS’s 2-day Call-in Elimination Webinar-training sessions running in November and December, which include segments on:
Reconciling Daily LARs
Balancing Daily Loan Level Cashbook
Reclass, Repurchase, and Foreclosure Removal.
As promised in our last (September) update, we are providing guidance to our Clients on completion of the FCIR Readiness and Acknowledgement Form. Because of the number of Clients for which we subservice, and the fact that each has their own business model with individual nuances, we cannot complete and sign off on your Readiness Form for you. However, we have created a model form which you may use to complete your own. We have provided directions on how to complete each field and what we believe are appropriate responses for you to use in red. Feel free to change these back to black if you are satisfied with the responses. You should also identify the officer at your company who will sign off on the form in the space designated on the last page, and have that individual sign and date the form and send it to Fannie Mae.
Please note that we have sought Fannie Mae’s and BKFS’s direction on completing the form, discussing open issues and risks with leadership from both organizations and believe that completing the form as we have recommended, with any additions you believe are appropriate, will work for Clients using Cenlar as their only subservicer. If you have multiple subservicers, you will need to determine how best to incorporate their responses as well.
Fannie Mae has expressed that they are trying to move the whole industry on February 1, and understands that every risk cannot be eliminated but expects that servicers have done what is appropriate to mitigate them. While BKFS has had two major servicing clients testing the system enhancement, the time constraints of the implementation date will not allow them to provide the enhancement to install in each of their client’s test region to allow for individual regression testing prior to installation. We have discussed this with Fannie Mae and they have acknowledged the issue. We have therefore recommended mentioning this issue in Section 2 under “Servicer Testing.” Black Knight has also advised its clients that it is appropriate to state their dependence upon BKFS for Technology Changes and Testing. Fannie Mae has also advised servicers utilizing a subservicer that it is appropriate to state this on the readiness form. Our model form reflects this.