04
Jun
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Monthly Regulatory Compliance Change Management Summary

Please find our monthly Regulatory Compliance Change Management Summary as of April 30, 2019 here.

This month’s Regulatory Compliance Change Management conference call will take place on Wednesday, June 5th 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. If you have already registered for a previous call there is no need to request registration again.

As a reminder, 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:

The following items are continuing to be implemented and have been deemed low risk however because the effective date has passed, and we are beyond our standard implementation timeframe, we are reporting each as out of compliance.  The rational for the risk rating is included with each item.

  • Q5304 – Delaware HB 2: is related to benefits for Delaware borrowers in the event of a federal government shutdown.  We are currently in the final stages of implementation and procedures are being finalized. This is low risk as the federal government is not currently shutdown and there are no loans impacted. 
  • Q5116 – Freddie Mac Bulletin 2018-16:  relates to a new Freddie Mac product. This is low risk as Cenlar is not currently boarding/servicing the loan product.
  • Q5238.2 – Fannie Mae Servicing Guide Update 2018-09:  is related to Fannie Mae Changes to the Servicing guide including Insurance Rating Requirements and Flood Insurance Updates. Our procedures adequately address the majority of the flood requirements within this bulletin. We are finalizing our Insurance procedures for Commercial contents coverage and the process of assessing coverage on loans with over 25% commercial space. This is low risk as we only service 35 Commercial loans none of which require contents coverage.
  • Q5238.5 – Fannie Mae Servicing Guide Update 2018-09: this item is related to Fannie Mae Changes to the Servicing guide including updating the FNMA address on specific letters. This item was fully implemented on May 6, 2019.