Monthly Regulatory Compliance Change Management Summary

Please find our monthly Regulatory Compliance Change Management Summary as of September 30, 2018 here.

This month’s Regulatory Compliance Change Management conference call will take place on Wednesday, October 24 at 2pm 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.  If you have already registered for a previous call there is no need to request registration again.

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 2 business days of receipt (excluding weekends and holidays).

Noteworthy Items:            

• Washington Bills: WAC 208-620 – Cenlar is compliant with WA 208-620 and no significant changes were required as a result of the legislation. For example, our denial letters were already coded to provide 30 days to appeal the decision because when this change was made for HAMP and GSE we implemented it for all borrowers in WA. That is also true regarding the system in place borrowers use to check the status of their modification. When this system was required for HAMP and GSE, we implemented it for all borrowers. We did implement changes regarding the timing for NOE/RFI, but since the change was a decrease in the timing requirement, Cenlar’s current practice was compliant as it provided additional time for the borrower.
• There were two separate Oregon laws that address numerous requirements that include a time frame for fee assessments, payment crediting, an annual statement, and a disclosure statement, which includes the contact information for the Oregon Department of Consumer and Business Services. OR SB 98 implemented the majority of the OR requirements with the exception of the disclosure statement. That disclosure is within OR Reg OAR 441-850-005 & 441-890-005-007.

• • OR SB 98 has been implemented and Cenlar is compliant with those requirements. This item is now with Post Implementation Testing.
  • OR Reg OAR 441-850-005 & 441-890-005-007 has a compliance effective date of 1/1/2019. The Regulatory Change Management team is working with the appropriate business units to update the escrow analysis and billing statements to include the new required disclosure. Cenlar anticipates compliance by the 1/1/2019 effective date.