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Monthly Regulatory Compliance Change Management Summary

Third party oversight is an increasing area of scrutiny within the industry. At Cenlar, we recognize the importance of greater transparency in keeping clients like you informed of identified regulatory compliance changes and Cenlar’s implementation of those changes.

The Cenlar Compliance Department has a robust change management process around identification and implementation of regulatory changes. The process, which is detailed in the attached overview document, includes coordination between the Legal Department, the Compliance Department, and the Business Units.

In an effort to further increase transparency, the Monthly Regulatory Compliance Change Management Summary has been enhanced to keep you informed of the regulatory compliance change items that have been identified and the current status of the items including all federal, state, GSE, insurer and other compliance related changes. The Regulatory Compliance Change Management Committee follows a seven (7) stage process (overview attached) that includes Legal identification and analysis, Compliance review, Operations impact analysis, Implementation strategy, Compliance/Legal review of Implementation strategy, Policy & Procedure review, Implementation and Quality Assurance Testing.

Cenlar will deliver the summary to our clients the first week of each month and will detail the following:

  • Any newly identified items during the prior month
  • The status of any outstanding items as of the last day of the prior month, any items closed during the month, and any items moved to testing during the month.

For example, the summary will detail any items identified in April, the status of any outstanding items as of April 28, 2017, any items closed with no impact in April, and any items moved to testing in April.

The summary contains the following fields:

  • Citation or ID – Name of new/amended rule, regulation, or guidance
  • Item Number – Cenlar’s tracking identification number for consistent identification
  • Rule Signing Date – Date new/amended rule, regulation, or guidance was signed or issued*
  • Rule Effective Date – Date new/amended rule, regulation, or guidance is effective*
  • Summary – Summary of new/amended rule, regulation, or guidance
  • Summary of Most Recent Update – Summary of the current status of the item
  • Stage – Current state of item in the 7 stage process
  • Projected Compliance Date – Date Cenlar is expected to be compliant and item moved to stage 7
  • Departmental Impact – Identified business units with impact at Cenlar.

The summary contains identified compliance changes related to the following:

  • Federal Items (FFIEC, FDIC, OCC, CFPB, etc)
  • State Items
  • GSE Items (Fannie Mae, Freddie Mac, Ginnie Mae)
  • General Items (FHA, VA, State Housing Authorities, USDA, MHA, MPF, MPV, MI, etc)

*The rule effective date and rule signing date are provided for easy identification of items that may be effective immediately or within a short period of time after signing or issuance.

Any questions related to the monthly summary, overview process, or specific regulatory change items can be sent directly to compliancechgmngt@cenlar.com and the Compliance Department will respond within 24 hours of receipt (excluding weekends and holidays).