March Regulatory Compliance Change Management Summary

Below you’ll find our Regulatory Compliance Change Management summary as of February 28, 2023.

To provide you more information, as well as an opportunity to ask questions, we also host a monthly conference call. The next call will take place on Thursday, March 30, 2023 at 3 p.m. ET. To register or send a question to be addressed on the call, please email compliancechgmngt@cenlar.com. If you have registered for a previous call, you do not need to request registration again. This call will be recorded and posted to CenAccess as well, so that you may listen at your convenience.

Any questions not for the call but related to the monthly summary, overview process or specific regulatory change items also can be sent to compliancechgmngt@cenlar.com. Our compliance department will respond to you within two business days of receipt (excluding weekends and holidays).

We’re currently working to reestablish compliance with our regulatory change management program on the following item. The item outlines what we are doing to achieve this, as well as the risk rating. 

Q11279 MPF Announcement 2022-64: MPF Program Insurance Loss Settlement Updates and Reminders (Effective 12/12/2022):
What it is: Servicers are no longer required to submit an SG342: Property Insurance Loss Draft Notification form for all losses. Servicers must only submit an SG342 to the MPF provider under specific scenarios outlined in the bulletin. As a reminder, if the mortgage loan is current or less than 31 days delinquent at the time of the loss event, the Servicer must disburse the Insurance Proceeds as described by MPF. This change item has been deemed to be low risk because of the number of potentially impacted accounts, the complexity of the change in which one business unit is impacted, and the potential regulatory scrutiny.
What we’re doing: Escrow Hazard is updating procedures, working with Assurant on their updated procedure, and creating new letters. Currently, the SG342 is sent for all initial disbursements of insurance proceeds.

Noteworthy Items: 

• Q11444 FNMA Servicing Transfer Approvals – Quick Exchange Enhancements (Effective 2/02/2023): Fannie Mae has updated the Quick Exchange application used for requesting servicing and subservicing transfers (via Form 629 data submission) with new functionality. The updates are as follows:
  • The Custodian Matrix has been updated to include Bank of America, N.A. and Computershare Trust Company, N.A.
  • Users will be prompted with a pop-up notification if they try to edit a transfer date for an approved transfer. The notification states that agreeing to a new transfer date will make the prior approval null and void and require a new transfer request to be made.
  • The approval letter has been updated to include new language if a sale or transfer date is changed.

Cenlar is aware of the FNMA form 629 requirement, however, sending this form is a client responsibility and not a servicing requirement.