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Dec
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Monthly Regulatory Compliance Change Management Summary

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

As a reminder there will not be a monthly call in December. The next Regulatory Compliance Change Management conference call will take place on January 30th 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:  

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 medium risk.  The rational for the risk rating is included and this item continue to be implemented.

  • 5779 FHA ML 2019-14 (Effective 11/30/19) – FHA has made updates to its Loss Mitigation Options for Borrowers in Presidentially-Declared Major Disaster Areas (PDMDA). These changes include updates to Eligibility without Financial Evaluation, Trial Payment Plans, and Disaster Standalone Partial Claims.  There are (3) action items associated with this regulatory change. Loss Mitigation will update Back in the Black (BITB) to support the new evaluation procedures for borrowers impacted by a PDMDA, update internal procedures to align with the updates in the BITB workflow, and update the forbearance letters to provide borrowers modification options when they are at the conclusion of the forbearance period. This is medium risk as the system updates to support the new evaluation procedures were implemented 11/30/19 and we’re working on finalizing the internal procedures and to implement the letter changes in production.