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 October 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, November 30, 2023 at 3 p.m. EST. 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.
•Q12512.1 RCM VA Circular 26-23-12 – VA’s COVID-19 Home Retention Waterfall and COVID-19 Refund Modification (Effective 7/1/23):
What it is: The purpose of this Circular is to update servicers of VA-guaranteed loans on how to assist homeowners following the termination of the COVID-19 National Emergency. Specifically, this Circular announces updates regarding VA’s COVID-19 Home Retention Waterfall and VA’s temporary home retention options—loan deferment and COVID-19 Refund Modification. Prior Circular 26-21-13 (Q9177) outlined parameters within which a servicer has VA’s consent for offering the COVID-19 Refund Modification. Through this Circular, VA is reiterating these parameters with two changes: VA is lowering the minimum payment reduction target outlined in paragraphs 7.a.(1) and (2) of this Circular from 20 percent to 10 percent; and VA is eliminating the requirement in paragraph 7.b.(1) of this Circular that the interest rate on the modified loan be no more than 1 percent higher than the existing interest rate on the loan.  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 one business unit is impacted, and the potential regulatory scrutiny.
What we’re doing: Loss Mitigation is completing a lookback of loans in active loss mitigation and loans that may have been eligible from 5/15/23 when the COVID-19 Refund Modification option was retired in order to comply with Circular 26-21-13 through 9/29/23 when the COVID-19 Refund Modification option was reinstated. Loans will be reviewed to determine if the homeowners would have qualified for the Covid-19 Refund Modification, and if so, if the COVID-19 Refund Modification would have been a more beneficial option for the homeowner.