Monthly Regulatory Compliance Change Management Summary

The October Regulatory Compliance Change Management Summary is linked for your reference.  

November’s Regulatory Compliance Change Management conference call will take place on Tuesday, November 26th at 3pm EST.

To register for the call, please email compliancechgmngt@cenlar.com. 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.

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

Noteworthy Items:  

  • 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.
    • Under the 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 Q5077.

Cenlar is 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 11/6/19.