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 March 31, 2023.

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, April 27, 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).

We’re currently working to reestablish compliance with our regulatory change management program on the following item. The item outlines what we are doing to achieve this, as well as the risk rating.

Q11368 New York S5473-D: Foreclosure Abuse Prevention Act (Effective 12/30/2022)
What it is: New York amended the remedies available in New York for foreclosure. This legislation indicates that once a foreclosure action is barred by the statute of limitations, a servicer is prohibited from bringing any other action to recover the same part of the mortgage debt. It includes both another foreclosure action and an action to recover a personal judgment against the borrower on the promissory note. This change item has been deemed to be Very High risk because of the number of potentially impacted accounts, the complexity of the change in which more than five business units are impacted, and the potential penalties.
What we’re doing: Non-Routine Foreclosure will distribute an attorney blast. Loss Mitigation is updating workout agreements/letters, update procedures, create reporting, conduct remediation, and distribute a vendor blast. As of March 15, 2023, no loans have been identified requiring remediation. Reporting is in place to continue to identify potentially impacted loans to be reviewed with Legal and Compliance to determine appropriate remediation. Foreclosure Attorneys review and analyze all cases to identify a potential statute of limitation concern and work directly with Cenlar to address.

Q11382 AHFC Seller/Servicer Memorandum 23-01 (Effective 1/04/2023)
What it is: Updates/Revisions to the Alaska Housing Servicing Guide: Updated section title to “Release of a CO-BORROWER or CO-SIGNOR”; Changed hazard insurance coverage to be based on unpaid principal balance versus appraised value; updated requirements for cancellation of mortgage insurance; updated requirements for collection of delinquencies; updated requirements for forms SER-92 & SER-75. This change item has been deemed to be Low risk because of the number of potentially impacted accounts, the complexity of the change in which five business units are impacted, and the regulatory scrutiny.
What we’re doing: Escrow Hazard is updating procedures, creating a new letter, and performing remediation. Default Accounting is updating procedures and performing remediation.

Noteworthy Items: 

LIBOR 2023 Sunset items Q9777 CFPB Facilitating the LIBOR Transition (Regulation Z)
The Q1 LIBOR Client Facing Project Plan is posted to CenAccess. In preparation of the LIBOR sunset, Cenlar has started to send Index Source Change Notices to all impacted mortgagors to advise of the new index selected. We are providing reporting to our business partners on a weekly basis, which contains the date that the index replacement notice (Letter ID AR022) was sent. This reporting produces every Monday, and is delivered via MoveIt.

• HELOC Administration and Special Products have begun updating BKFS for the new index codes with the replacement indices.
• Contact Center FAQs have been updated to prepare our agents for inquiries related to the Index Source Change Notices.
• Special Products started sending the Index Source Change Notices for ARMs in March 2023, and will continue to deliver the notices to impacted mortgagors through Q2 and Q3.
• HELOC Administration is preparing to begin sending the HELOC Change in Terms Notices.

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. Beginning in July 2023, Cenlar will activate the replacement indices and deactivate the LIBOR indices in the system to transition the loans and lines to the selected replacement index.