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 August 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, September 28, 2023 at 3 p.m. EST. To register or send a question to be addressed on the call, please email firstname.lastname@example.org. 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 email@example.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 items. The items outline what we are doing to achieve this, as well as the risk rating.
• Q11997.1 HUD DLL 2023-04 (Effective 5/31/2023): What it is: The HUD Section 184/184A Programs have indicated with this Dear Lender Letter their intentions regarding loss mitigation options. This DLL temporarily suspends the loan modification and partial claim options for Section 184 loans and the loan modification option for Section 184A loans. These options are suspended until October 30, 2024. 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 two business units are impacted, and the potential regulatory scrutiny. What we’re doing: Loss Mitigation is updating BITB, procedures, completing a look back, documenting the interim 184/184A review process, and updating the plan code matrix. The Default Call Center is updating scripting, smart buttons, and creating a new letter. A daily control report is utilized to ensure borrowers were offered streamline options. The business units are completing a lookback and manually reviewing 184/184A loans prior to finalizing underwriting decisions.
• Q11561.2 FHLMC Bulletin 2023-06 (Effective 7/15/2023): What it is:Freddie Mac is updating their information security and privacy requirements to be more consistent with industry standards. They are making updates to their information security minimum requirements, with the addition of requirements tied to incident management; mobile computing; and auditing, logging, and monitoring of activities within information systems. This includes new requirements related to unauthorized access to or acquisition of information that may compromise the security, confidentiality, availability or integrity of Freddie’s information. This also includes updates to expectations related to servicer’s business continuity. 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 two business units are impacted, and the potential regulatory scrutiny. What we’re doing: Compliance Advisory has processes in place and are finalizing procedures.