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, 2023.

To provide you more information, we also host a monthly conference call. The next call will take place on Thursday, January 25, 2024 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.

You may also submit questions related to the regulatory compliance change management program at any time 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 below outlines what we are doing to achieve compliance and the risk rating associated with the change.

What it is: This announcement incorporates updates from LL-2023-04 (Q11697) into the Servicing Guide; removes the reason for delinquency code 022 (Q12511.1 & Q12511.2); repurposes reason for delinquency code 007 (Q12511.1 & Q12511.2); and removes references to the Fannie Mae Home Affordable Modification Program (Q11267, Q11149.1 & Q11149.2). Also updated with this release is guidance regarding applying principal payments to cure a delinquency. For portfolio mortgage loans or participation pool mortgage loans, the Guide authorizes servicers to reapply principal curtailments to cure a delinquency when certain conditions are met. One of those conditions requires the borrower to submit a written request to the servicer. Fannie Mae updated the policy to permit a verbal or written request from the borrower to reapply principal curtailments when certain conditions are met. This will simplify the operational process for servicers and borrowers. 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: Compliance is working with the potentially impacted business units to develop a decision memo for presentation to the Cenlar Executive Committee.

• Q12705.1 FHLMC Bulletin 2023-20: Servicing (Effective 10/11/23): 

What it is: This Guide Bulletin announces several updates regarding charge-off recommendations through the Resolve user interface (UI), providing accurate and complete information when obtaining a property value, updates to privacy and date protection requirements including but not limited to notification and retention requirements in the event of a security breach, and a clarification on loans receiving ineligible findings in Resolve for the expanded Payment Deferral.  Freddie Mac is providing an operational clarification regarding the Servicer’s evaluation of a Payment Deferral using Resolve. Despite Resolve flagging the Mortgage as ineligible while the current month’s payment remains due because of delinquency and/or cumulative deferred payment requirements, the Servicer must send the proactive offer with the condition that a payment or payments are required to complete the Payment Deferral. Once the payment or payments have been received and the Mortgage becomes eligible, the Servicer must re-submit through Resolve to settle the Payment Deferral and may still communicate to the Borrower that they may become eligible if a payment or payments are made to meet our requirements. Once the Borrower becomes eligible, the Servicer must resubmit in Resolve to settle the Payment Deferral.  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 one business unit is impacted, and the potential regulatory scrutiny.

What we’re doing: Loss Mitigation is monitoring accounts manually to achieve QRPC or send a manual letter as it pertains to the solicitation portion of the clarification and is working with Issue Management to open an issue to track potential remediation and updates that may be necessary.

Noteworthy Items:

• Reminder: 2024 Updates and Changes
  • A new calendar invite will be provided for 2024.
  • Beginning with the January 25 call, all questions are required to be provided at least 24 hours in advance. Any questions received after 3 p.m. EST on the day before the call will not be answered during the call.
  • We will begin providing statistics regarding Cenlar’s regulatory change management items.