Monthly Regulatory Compliance Change Management Summary

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

Due to the COVID-19 virus, the next Regulatory Compliance Change Management conference call has been pushed back until April 2 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).

There are currently no items showing as ‘Out of Compliance’ (effective date has passed and we are beyond our standard implementation timeframe) on our February report, as all items were implemented in accordance with our program.

Noteworthy Items:

• Q5102 California SB-818 (Effective 1/1/2019):  – California is reinstating the requirements of California original Homeowner’s Bill of Rights. This item was re-opened to address changes in section 2924.18(a)(1): Loan Modification requirement to not Foreclose if complete package is received up to 5 days prior to the Foreclosure Sale date. Cenlar is updating the system coding to ensure California borrowers receive a 30 day Foreclosure hold when a loan modification complete package is received at least 5 business days prior to the Foreclosure sale date. We implemented a manual process to ensure compliance with the requirement on 2/21/20.  The manual process will remain in place until the systemic updates to the Back in the Black (BITB) system are completed. Cenlar conducted a lookback to review all foreclosure sales since the 1/1/2019 effective date and determined there were no loans found to be in violation of the law.  We are pending a letter update to the loss mitigation insufficient time to review (LM308) letter and updates to BITB and then this item will be moved to testing.