Monthly Regulatory Compliance Change Management Summary
Please find our monthly Regulatory Compliance Change Management Summary as of August 31, 2020 linked for your reference.
This month’s Regulatory Compliance Change Management conference call will take place on Thursday September 24th 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 unable to attend. If you have already registered for a previous call there is no need to request registration again. Please submit any questions related to the regulatory change management mailbox prior to the call.
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).
Six items, listed below, are showing as “Out of Compliance” (effective date has passed and we are beyond our standard implementation timeframe) on our August report. The rational for the risk rating is included and these items continue to be implemented.
- Q6854 VA Circ. 26-19-17 Change 2 Funding Fee Guidance to Lenders and Servicers (Effective 5/22/2020): – This update to the VA Circular provides guidance regarding funding fee refunds. The funding fee refunds must be paid to the Veteran by the VA through FFPS. The servicer must change the refund destination from “Lender/Vendor” to “Primary Veteran” in the refund setting section. If the loan is in default, the Veteran will be advised that he or she may wish to use the refund to help bring the loan current. This change item has been deemed a low risk as a process is being finalized for making minor updates to procedures regarding the VA funding fee and pre-discharge claims for assuming loans in our Special Products Area.
- Q6718 RHS PN 536 Changes to HB-1-3555 (Effective 4/30/2020): – This update to the VA Circular provides guidance regarding funding fee refunds. The funding fee refunds must be paid to the Veteran by the VA through FFPS. The servicer must change the refund destination from “Lender/Vendor” to “Primary Veteran” in the refund setting section. If the loan is in default, the Veteran will be advised that he or she may wish to use the refund to help bring the loan current. This change item has been deemed a low risk as a process is being finalized for making minor updates to procedures regarding the VA funding fee and pre-discharge claims for assuming loans in our Special Products Area.
- Q7000 New York AB 8243 & Q7001 New York SB 8428 (Effective 6/17/2020): New York has passed a bill to add a new section 9-x to Article 1 of the New York Banking Law to require New York regulated institutions to grant 180 days of forbearance, with the option to extend an additional 180 days, to residential mortgagors who can demonstrate financial hardship as a result of the COVID-19 pandemic. This new section also allows for any mortgagor granted forbearance to choose to extend their loan for the length of the forbearance, have the arrears accumulated during the forbearance period payable on a monthly basis for the remaining term of the loan, or to defer the arrears as a lump sum payment due at the maturity of the mortgage or when the loan is paid off. This change item has been deemed to be medium risk because we are still working with the business units and BKFS to operationalize the repayment plan options. This law only applies to NYDFS regulated clients. We are pending responses from clients regarding who is regulated by the NYDFS so that we can updated plan codes accordingly for clients doing business in NY.
- Q6950 State of Montana’s Emergency Housing Assistance Program (Effective 5/7/20): Montana has released an Emergency Housing Assistance program to provide rent, security deposit, mortgage payment, and/or hazard insurance assistance as needed for Montanans who have lost a job or had a substantial income loss due to COVID-19. This change item has been deemed to be a low risk because the borrower population impact is low. The bank account has been set-up to accept the ACH payments from the various States. DCC has set-up a mailbox specific to receive State requests and has implemented a process of notating the account and forwarding any physical checks to Payment Services.
- Q7020 Pennsylvania PMAP (Pandemic Mortgage Assistance Program) (Effective 7/6/20): Renters and homeowners who were financially impacted by the economic slowdown related to the coronavirus pandemic became eligible to apply for rent and mortgage relief beginning June 29, 2020. PHFA is developing detailed programs for distributing this financial assistance quickly to people in need while following legislative requirements. The agency will begin accepting completed applications for rent and mortgage assistance on July 6. This change item has been deemed to be a medium risk because of the impacted borrower population. The bank account has been set-up to accept the ACH payments from the various States. DCC has set-up a mailbox specific to receive State requests and has implemented a process of notating the account and forwarding any physical checks to Payment Services.