Regulatory Compliance Change Management conference call will take place on Tuesday,
November 26th at 3pm EST.
To register for the
call, please email firstname.lastname@example.org. For your
convenience, the session will be recorded and made available to clients who are
unable to attend. If you registered for a call in the past, you will be
automatically registered for this call and do not need to register again.
questions related to the monthly summary, overview process, or specific
regulatory change items can be sent directly email@example.com. The
Compliance Department will respond within two business
days of receipt (excluding weekends and
Q5840 CFPB issues 2019 HMDA
Final Rule (Effective 1/1/2020): CFPB has issued
a final rule to extend the current temporary 500 open-end lines of credit
threshold for HMDA reporting.
current temporary rule, an insured depository institution or insured credit
union is exempt from HMDA reporting as to open-end lines of credit if the
entity originated fewer than 500 open-end lines of credit in each of the two
preceding calendar years. Additionally, this final rule incorporates into
Regulation C the interpretations and procedures from the 2018 HMDA Rule and
section 104(a) of the Economic Growth, Regulatory Relief, and Consumer
Protection Act (ECGRRCPA), which were previously communicated in Q4930 and
aware of this CFPB Final Rule and its requirements. While Cenlar is not
responsible for direct HMDA reporting, Clients who receive HMDA reporting for
Assumptions must make the determination as to what data points they are
required to report under HMDA.
The item listed below, while showing as “Out of Compliance”
(effective date as passed and we are beyond our standard implementation
timeframe) on our October report, has been deemed low risk. The rational
for the risk rating is included below and was implemented.
5756 VA Circular 26-19-24 – The VA is
providing guidance for sending loss mitigation letters to borrowers. The
required loss mitigation letters should be sent to the borrower as required by
preexisting regulatory requirements. The letter shall include specific verbiage
as provide by the VA. Servicers are also required to report to the VA that the
letter has been mailed to the borrower and the date of mailing. There were two (2) pending action items associated with this change
that include letter and procedure updates. This is low risk as there were
minor updates to letter verbiage and until the system updates were? completed, Cenlar was manually reporting to the VA that
Loss Mitigation letters were mailed. Although this reported as Out of Compliance
as of this report, it has since been implemented with an implementation date of