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Monthly Regulatory Compliance Change Management Summary

As part of our ongoing effort to keep you informed, each month we send to you a summary of the work we’re doing to ensure compliance with the ever-changing regulatory landscape.

Below you’ll find our Regulatory Compliance Change Management summary as of December 31, 2022.

To provide you more information, as well as an opportunity to ask questions, we also host a monthly conference call. The next call will take place on Thursday, January 26, 2023 at 3 p.m. ET. To register or send a question to be addressed on the call, please email compliancechgmngt@cenlar.com. If you have registered for a previous call, you do not need to request registration again. This call will be recorded and posted to CenAccess as well, so that you may listen at your convenience.

Any questions not for the call but related to the monthly summary, overview process or specific regulatory change items also can be sent to compliancechgmngt@cenlar.com. Our compliance department will respond to you within two business days of receipt (excluding weekends and holidays).

All items in December are in compliance with our Regulatory Change Management program. 

Noteworthy Items

LIBOR 2023 Sunset items Q9777 CFPB Facilitating the LIBOR Transition (Regulation Z),  Q10121 US HR 2471, & Q11316 Federal Reserve Regulation Implementing the Adjustable Interest Rate (LIBOR) Act: 
The Q4 LIBOR Client Facing Project Plan is posted to CenAccess. We also wanted to provide an update on the LIBOR Project. Cenlar has:

  • finalized and implemented a HELOC Change-in-Terms Notice;
  • advised clients of no longer boarding newly originated loans with LIBOR as of June 1, 2022;
  • provided borrowers an advance courtesy notice of the LIBOR Transition following the format of the MBA LIBOR Transition Template Consumer Letter, which was distributed to impacted borrowers at the end of September 2022; and
  • created and implemented Contact Center FAQs and tracking for handling of borrower inquiries as a result of the advance courtesy notice.

Cenlar continues to monitor the monthly volumes of loans and lines that reference LIBOR and monitor for announcements from the ARRC, the Board, Fannie, Freddie, Insurers and States. On December 22, 2022, FNMA and Freddie announced their decision for the replacement index. Also, on December 22, 2022, the Federal Reserve Board announced the publication of the LIBOR Act Final Rule, which is being tracked in Q11316. The Final Rule is still pending publication in the Federal Register and the effective date will be 30 days after it is published.

Cenlar is also continuing to prepare for the transition from LIBOR by planning to distribute Index Source Change Notices beginning in Q1 2023 through Q3 2023 depending on the timing of the borrower’s final rate change. Beginning in July 2023, Cenlar will also update the replacement indices and deactivate the LIBOR indices in the system.