Monthly Regulatory Compliance Change Management Summary

You can find our monthly Regulatory Compliance Change Management Summary as of June 30, 2018, here.

Noteworthy Items:

• CFPB Mortgage Servicing Rules – Bankruptcy Statements – Cenlar implemented changes to comply with the new rules that were effective April 19, 2018.  Beginning May 1, 2018, bankruptcy statements were generated on active bankruptcy loans that were required to receive a statement.  A recent issue related to discharged Chapter 7 loans that had not reaffirmed was identified. Compliance worked with the Servicing Systems team to correct the bill stop flags, generate July Statements, and ensure the bill stop field is not overwritten and statements continue to generate on these loans even though the borrowers have not reaffirmed the debt.
• Wisconsin AB 822 – This legislation removes the requirement that state chartered lenders/servicers pay interest on escrow for first lien residential mortgage loans if the loan is originated after April 18, 2018.  Cenlar has updated the interest on escrow field to default to no on note dates greater than April 18, 2018.  A client advisory will be issued by July 31, 2018, that will provide information and direction to clients who wish to continue to pay interest on their loans originated after April 18, 2018.

This month’s Regulatory Compliance Change Management conference call will take place on Wednesday, August 15th at 3pm EST. To register for the monthly call, please email compliancechgmngt@cenlar.com. For your convenience, the call will be recorded and made available to clients who are unable to attend.

Any questions related to the monthly summary, overview process, or specific regulatory change items can be sent directly to compliancechgmngt@cenlar.com and the Compliance Department will respond within two business days of receipt (excluding weekends and holidays).