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 June 30, 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, July 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 companion items. Each item outlines what we are doing to achieve this, as well as the risk rating.
What it is: FHA has issued Mortgagee Letter 2023-03, to supersede Mortgagee Letter 2023-02 (Q11458), which extends the COVID-19 Recovery Loss Mitigation Options, expands the options to include additional eligible borrowers, increases the COVID-19 Recovery Partial Claims, and adds incentive payments to mortgagees. This Mortgagee Letter temporarily suspends the use of all FHA-HAMP, updates loss mitigation for borrowers in PDMDAs, updates the COVID-19 Advance Loan Modification and the COVID-19 Loss Mitigation options, and updates default reporting requirements and claims. This change item has been deemed to be medium risk because of the number of potentially impacted accounts, the complexity of the change in which five business units are impacted, and the potential regulatory scrutiny. What we’re doing: Loss Mitigation is updating the MAA. The Default Call Center will provide control report job aid and update BITB programming. Business units completed remediation and a daily control report is being utilized to ensure borrowers were offered streamlined options.
What it is: FHA has provided answers to three questions regarding their recent Mortgagee Letter 2023-03. These answers clarify the availability of loss mitigation options to Successors in Interest (SII); what “borrowers who are not on a COVID-19 forbearance” means; and how to handle borrowers currently on a Trial Payment Plan. This change item has been deemed to be medium risk because of the number of potentially impacted accounts, the complexity of the change in which four business units are impacted, and the potential regulatory scrutiny. What we’re doing: Loss Mitigation is updating the MAA. The Default Call Center will provide control report job aid, updated cover letter, and update BITB programming. Business units are performing remediation to identify potentially impacted accounts. A daily control report is utilized to ensure borrowers were offered streamline options. |