Page 329 – Safeguard Properties

FHA INFO #17-03: Changes to HECM Claim Type 22 Assignment Requests; IT Security and Data Privacy Protocols

Posted on September 13, 2018 by Safeguard

Investor Update
January 18, 2017

Consolidated and New Guidance on HECM Claim Type 22 Assignment Requests

Today, the Federal Housing Administration (FHA) published Mortgagee Letter 2017-05, Home Equity Conversion Mortgage (HECM) Claim Type 22 Assignment Requests. This Mortgagee Letter consolidates policy found in various existing Mortgagee Letters and Handbooks for mortgagees submitting HECM assignment requests by initiating a Claim Type 22 (CT-22) in HUD’s Home Equity Reverse Mortgage Information Technology system. By consolidating this information into one source, FHA is making it easier for mortgagees to locate the information needed to submit a HECM assignment request. This, in turn, may help improve accuracy of HECM claim submissions and improve processing times for claim requests; thus, contributing to the overall goal of making it easier to do business with FHA.

This Mortgagee Letter does not contain new policy specific to assignment eligibility; however, the stacking order of items needed for the various documentation packages has changed. As noted in the Mortgagee Letter:

Mortgagees submitting documentation packages in support of their Assignment Request must look closely at the requirements and ensure ALL documents required are included, and that they are in the correct stacking order.
If any documents are missing and/or are not in the correct stacking order, the assignment request will be denied and the mortgagee will have to resubmit the request.

Servicers are able to implement guidance in Mortgagee Letter 2017-05 as early as the publication date for all new HECM CT-22 Assignment Requests, but no later than 90 days after the publication date.

Quick Links

View Mortgagee Letter 2017-05 on HUD.gov at:
https://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/letters/
mortgagee

New FHA FAQ Describes Information Technology Security and Data Privacy Protocols

The Federal Housing Administration (FHA) has made available on its Resource Center’s FAQ site, a new frequently asked question (FAQ), “Does FHA have specific information technology (IT) security and data privacy requirements for FHA-approved mortgagees?” The new FAQ response describes the requirements for communicating IT security and consumer data privacy issues to FHA by all FHA-approved mortgagees and lenders.

Quick Links

View the FHA FAQ page on HUD.gov at: https://portal.hud.gov/hudportal/HUD?src=/FHAFAQ

Resources

Contact the FHA Resource Center:

Visit our online knowledge base to obtain answers to frequently asked questions 24/7 at:
www.hud.gov/answers.
E-mail the FHA Resource Center at: answers@hud.gov. Emails and phone messages will be
responded to during normal hours of operation, 8:00 AM to 8:00 PM (Eastern), Monday through
Friday on all non-Federal holidays.
Call 1-800-CALLFHA (1-800-225-5342). Persons with hearing or speech impairments may reach
this number by calling the Federal Relay Service at 1-800-877-8339.

Source: HUD (FHA INFO #17-03 full version)

FHA INFO #16-80: Single Family Housing Policy Handbook 4000.1 December Update

Posted on September 13, 2018 by Safeguard

Investor Update
December 30, 2016

Today, the Federal Housing Administration (FHA) published the quarterly update to its Single Family Housing Policy Handbook 4000.1 (SF Handbook). This update incorporates previously published Mortgagee Letters into both the online and portable document format (PDF) SF Handbook.

This update does not include any new policy. The SF Handbook’s December 30th Transmittal, available in FHA’s Online Housing Policy Library, provides additional details. In conjunction with today’s update, FHA published a revised FHA Single Family Housing Claim Filing Technical Guide that updates several hyperlinks within the document.

Today’s publication is the latest in a series of SF Handbook quarterly updates. FHA intends to maintain this quarterly schedule whenever possible, so that mortgagees and other stakeholders will know when to expect and can plan for updates.

Revised Pre-Foreclosure Sale Forms
In addition, mortgagees should note that FHA revised the following forms, referenced in the SF Handbook, that support existing pre-foreclosure sale policy:
— Form HUD-90035, Information Sheet, Pre-foreclosure Sale Procedure;
— Form HUD-90041, Request for Variance, Pre-foreclosure Sale Procedure;
— Form HUD-90045, Approval to Participate, Pre-foreclosure Sale Procedure, Property Sales Information, Property Occupancy & Maintenance;
— Form HUD-90051, Sales Contract Review, Pre-foreclosure Sale Procedure; and
— Form HUD-90052, Closing Worksheet, Pre-foreclosure Sale Procedure.

The revisions to these forms were described in FHA’s 30-Day Notice of Proposed Information Collection (Docket Number FR-5909-N-33) published in the Federal Register on May 4, 2016. The revised forms were posted on December 13th and are available on the Forms Resource pages on HUD.gov.

Quick Links

Review the December 30th SF Handbook Transmittal available at: http://www.allregs.com/tpl/public/fha_freesite.aspx
Access the online or portable document format SF Handbook from HUD’s Client Information Policy Systems’ Housing Handbooks web page at: http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/hsgh

Resources

Contact the FHA Resource Center:

Visit our online knowledge base to obtain answers to frequently asked questions 24/7 at:
www.hud.gov/answers.
E-mail the FHA Resource Center at: answers@hud.gov. Emails and phone messages will be responded to during
normal hours of operation, 8:00 AM to 8:00 PM (Eastern), Monday through Friday on all non-Federal holidays.
Call 1-800-CALLFHA (1-800-225-5342). Persons with hearing or speech impairments may reach this number by
calling the Federal Relay Service at 1-800-877-8339.

Source: HUD

Fannie Mae: Standard Modification Interest Rate Exhibit

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 6, 2017

The Fannie Mae Standard Modification Interest Rate is subject to periodic adjustments based on an evaluation of prevailing market rates. The servicer must use the current Fannie Mae Standard Modification Interest Rate indicated below when evaluating a borrower for a conventional mortgage loan modification, excluding Fannie Mae HAMP Modifications.

NOTE: As a reminder, the interest rate used to determine the final modification terms must be the same fixed interest rate that was used when determining eligibility for the Trial Period Plan and calculating the Trial Period Plan payment.

Source: Fannie Mae (full exhibit)

Additional Resource:

Freddie Mac (Freddie Mac Standard Modification Interest Rate)

Fannie Mae: Servicer Webinar and Forums; Updated Project Insurance Requirements FAQs

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 5, 2016

January All-Servicer Forums: Fannie Mae Changes to Investor Reporting

Please plan to attend one of our upcoming Fannie Mae Changes to Investor Reporting-All Servicer Forums.

Transition Month Overview
January 26, 2017 from 2 – 3 p.m. ET

Loan Activity Processing (Transaction Type 96) Forum — January 17, 2017 from 2 – 3 p.m. ET

Overview of Interest Rate/Payment Changes and MI Discontinuation — January 18, 2017 from 2 p.m. – 3 p.m. ET

Loan Re-class and Loan Modifications — January 19, 2017 from 2 p.m. – 3 p.m. ET

Who should attend?
Every servicer who does business with us. Register today via one of the links above, or via our web page. Be sure to forward this message to others in your organization who would also benefit from these forums.

Learn More
Visit the Fannie Mae Changes to Investor Reporting page to register for a forum and receive the latest information and resources. Questions? Contact your Servicer Integration Lead or email call-in_information@fanniemae.com.

Updated Project Insurance Requirements FAQs

Fannie Mae’s Project Insurance Requirements FAQs have been updated to reflect recent policy changes. Sellers and Servicers can find information related to Fannie Mae’s property, flood, and liability insurance requirements for projects, and related requirements for individual units in condo, coop and planned unit development (PUD) projects, including HO-6 coverage.

Source: Fannie Mae

Fannie Mae: Lender Letter LL-2017-01

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 4, 2017

This Lender Letter contains updates to the following:

United Guaranty Corporation Acquired by Arch U.S. MI Holdings, Inc., and
Approved Mortgage Insurance Forms.

United Guaranty Corporation acquired by Arch U.S. MI Holdings, Inc.
Fannie Mae has approved the acquisition of United Guaranty Corporation, including mortgage insurers United Guaranty Residential Insurance Company and United Guaranty Mortgage Indemnity Company, by Arch Capital Group, Ltd. These United Guaranty entities are wholly-owned direct subsidiaries of Arch U.S. MI Holdings, Inc. At this time, there is no change to the use of MI Code (“12”) or the ULDD Enumerated Value (”UGI”) delivered by lenders to identify loans insured by either of these United Guaranty entities. If we change our delivery requirements in the future, we will provide advance notice to sellers and servicers.

Approved Mortgage Insurance Forms
We have updated the list of approved mortgage insurance forms as follows:

Replaced the previous Essent Guaranty, Inc. endorsement with: Illinois State Variation Endorsement, EGI-1003.104 (11/16);
Corrected the Radian Guaranty Inc. endorsement: No Arbitration Endorsement (for GA and MO), RAF487 12/13; and
Added a new Radian Guaranty Inc. endorsement: Florida Arbitration and Limitation of Action Endorsement, RAF507 9/16.

The updated list is available on Fannie Mae’s website.

Lenders who have questions about this Lender Letter should contact their Account Team.

Carlos T. Perez
Senior Vice President and
Chief Credit Officer for Single-Family

Source: Fannie Mae

Fannie Mae: Changes to Investor Reporting Release Notes

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 6, 2017

As announced in Lender Letter LL-2014-06, Announcement SVC-2015-07 and Lender Letter LL-2016-01, Fannie Mae is updating its Single-Family Investor Reporting requirements effective February 1, 2017. These updates include eliminating the Single-Family MBS “call-in” requirement and adjusting due dates for monthly loan reporting. These updates affect all loans and servicers. Servicers will need to adhere to these policy changes when reporting loan activity that occurs on or after February 1, 2017. Fannie Mae’s Servicing Guide and investor reporting manual will be updated and available mid-January 2017.

Outlined in this document are the Investor Reporting business process and technology changes that will occur as part of this release. More details on the process requirement changes can be found here.

Source: Fannie Mae (full Release Notes)

Fannie Mae: Announcement SVC-2017-01: Servicing Guide Updates

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 18, 2017

The Servicing Guide has been updated to include changes related to the following:

Investor Reporting Requirements*
Retirement of Non-Eligible List*
Miscellaneous Revision

* Policy change not applicable to reverse mortgage loans.

Read the Announcement for full details.

For a summary of key updates in this Servicing Guide Announcement, view the video presented by Bill Cleary, Vice President of Single-Family Servicing Policy & Solutions.

Changes to Investor Reporting: Take charge of your February 1 transition!

Have you visited the Fannie Mae Changes to Reporting page recently? Several documents were updated with new information including Process Requirements, Detailed Scenarios, FAQs, and more to support your transition. For details about the changes that must be implemented by servicers as of February 1, see the Release Notes. Review archived webinar materials (just released), and don’t forget live webinars are still open through January.

More Simple. More Certain. Learn more at the IMB!

Join us at the upcoming MBA’s Independent Mortgage Bankers Conference (January 23-27) to learn more about our Day 1 Certainty™ program, and how we’re working to help you achieve your business goals. Our team will be on hand — and easy to find — to answer questions and talk about the opportunities ahead.

Recent Tweets

Shared housholds are impacting #housing. @QuickenLoans has more:
https://t.co/FFypFmYXAR

January 17

We’re using #AI to become more efficient and improve how we deliver for our customers. Via @WSJ #technology:
http://on.wsj.com/2jFxnY0

January 17

Source: Fannie Mae

CFPB’s Final Mortgage Servicing Rule Implementation Possibly Delayed

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 25, 2017

Possibly delayed 60 days for review by Trump administration

The implementation date of the Consumer Financial Protection Bureau’s final mortgage servicing rule lies in question after the Trump administration announced a freeze on federal regulations.

After a nearly four-month delay since the CFPB finished the final mortgage servicing rule, the Office of the Federal Register finally published the rule on Oct. 19, meaning it would go into effect one year later on Oct. 19, 2017.

While the extra time to adjust to the rule isn’t a bad thing, Nanci Weissgold, a member of Alston & Bird’s Financial Services & Products Group, said, “Given the operational complexities in implementing these rules, servicers should not delay in understanding the requirements and developing an implementation plan.”

The implementation date, however, could be delayed even further due to the regulatory freeze announced by Reince Priebus, assistant to the president and chief of staff, last Friday.

Here’s the section of the announcement that pertains to the servicing rule:

With respect to regulations that have been published in the OFR but have not taken effect, as permitted by applicable law, temporarily postpone their effective date for 60 days from the date of this memorandum, subject to the exceptions described in paragraph 1, for the purpose of reviewing questions of fact, law, and policy they raise. Where appropriate and as permitted by applicable law, you should consider proposing for notice and comment a rule to delay the effective date for regulations beyond that 60-day period. In cases where the effective date has been delayed in order to review questions of fact, law, or policy, you should consider potentially proposing further notice-and-comment rulemaking.

The exceptions listed in the first paragraph include: Emergency situations or other urgent circumstances relating to health, safety, financial, or national security matters, or otherwise.

But the situation isn’t so clear-cut for the CFPB. According to the Consumer Financial Services Review blog post by Mayer Brown Lawyers Laurence Platt and Joy Tsai, “The newly announced freeze on federal regulations does not appear to apply across the board. ‘Independent regulatory agencies,’ such as the Consumer Financial Protection Bureau, the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Securities and Exchange Commission may be excluded from that moratorium.”

In a recent interview with The Wall Street Journal, “Cordray declined to answer questions about how a Trump order to freeze new regulations would affect the bureau’s planned rules. He said bureau lawyers are evaluating the directive signed Friday and how it might apply to independent agencies such as the CFPB.”

The Mayer Brown blog post noted, “It is too soon to tell if any particular ‘independent regulatory agency’ believes that it is exempt from the freeze or, even if it is, it nevertheless will honor the memorandum’s spirit.”

While there are several issues such as debt collection and payday lending that the bureau has identified as part of its rulemaking agenda, there are only two rules currently published but not yet effect in the Federal Register that this freeze applies to.

The final mortgage servicing rule is one and the other is the rule on Prepaid Accounts under the Electronic Fund Transfer Act and Truth in Lending Act, published Nov. 22, 2016 and effective Oct. 1, 2017.

Source: HousingWire

CFPB Updates Congress on Mortgage Industry Rules

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 9, 2017

Three of the initiatives by the Consumer Financial Protection Bureau (CFPB) that have had the biggest impact on the mortgage industry—the TILA-RESPA Integrated Disclosure (TRID) rule (a.k.a. the Know Before You Owe, or KBYO rule), the updated Home Mortgage Disclosure Act (HMDA) rule, and the August 2016 updates to the mortgage servicing rules were highlighted in a report on the Bureau’s activities from Q4 2015 to Q3 2016.

In its recently-released fourth report to the House and Senate Committees on Appropriations coving October 1, 2015, through September 30, 2016, the Bureau laid out some of the materials and helps it provided during that 12-month period to assist institutions implement those three initiatives.

“As the Bureau has issued regulations to implement Dodd-Frank Act requirements, it has focused intently on supporting the implementation process for these rules with both industry and consumers,” CFPB stated in the report. “The Bureau has provided substantial implementation support for these regulations, including engaging in public outreach, speaking at conferences, and publishing guides, summaries, charts, webinars, and other resources.”

The implementation of TRID, which went into effect on October 3, 2015, caused no small amount of consternation among mortgage lenders and other stakeholders in the industry. Among the helps the CFPB has provided are several implementation resources that include a plain-language guides containing an overview of TRID’s key aspects, illustrated instructions on how to complete the new Loan Estimate and Closing Disclosure Forms. The Bureau has also conducted several public webinars on TRID to answer specific questions on the implementation and/or interpretation of the rule’s requirements the Bureau has received since the rule went into effect.

In July 2016, the Bureau proposed updates to TRID aimed at providing greater clarity and certainty surrounding the rule.

“The proposed changes would augment implementation of the KBYO rule, which took effect in October 2015, and further help to facilitate compliance within the mortgage industry,” CFPB stated. “Bureau staff continues to engage in outreach and market monitoring activities to identify implementation issues as they arise, and provide informal oral guidance in response to interpretive inquiries from a myriad of stakeholders.”

The CFPB issued its updated HMDA rule in October 2015 along with resources to help industry stakeholders understand and implement the new rule, including a summary and overview of the final rule, a timeline of the rule’s effective dates, coverage charts for financial institutions to determine if they are HMDA reporters, a summary of reportable data explaining the HMDA data points that are to be collected, recorded, and reported per the updated rule, a compliance guide with a plain-language explanation of the rule, a webinar with an overview of the final HMDA rule, and a number of data submission resources for HMDA filers available on the CFPB’s website.

“In addition to publishing implementation resources, the Bureau continues to engage in extensive outreach activities, including speaking at conferences and other events, to support the implementation of new HMDA mortgage lending data reporting rules and to identify and address implementation issues,” the Bureau said.

The CFPB published a number of resources along with the August 2016 updates to its mortgage servicing rules, including a summary of the new rule, a fact sheet, and a table summarizing how the rule affects small servicers, and a fact sheet explaining the definition of “delinquency” under the new rule and how the new rule applies to TILA-RESPA requirements.

“The Bureau plans provide additional support to facilitate implementation and compliance with the August 2016 amendments to the mortgage servicing rules, and to update the existing compliance guide to reflect the August 2016 amendments,” the CFPB wrote in the report.

Click here to view the CFPB’s full report.

Source: DS News

CFPB Announces Changes to Senior Leadership

Posted on September 13, 2018September 13, 2018 by Safeguard

Investor Update
January 5, 2016

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today announced leadership changes within the Bureau. The positions being announced today are: the Chief of Staff; the Chief Information Officer; the Chief Financial Officer; the Assistant Director of Consumer Lending, Reporting, and Collections Markets; and the Assistant Director for the Office for Servicemember Affairs.

“I am very excited for the new additions we are announcing today to the Bureau’s senior leadership,” said CFPB Director Richard Cordray. “The mix of experience and talent this group brings will provide great value to the Bureau as we continue to work on behalf of consumers everywhere.”

The following individuals were announced today as joining the CFBP leadership team:

Leandra English is returning to the CFPB to serve as the Chief of Staff. Ms. English has previously served in a number of senior leadership roles at the Bureau, including deputy chief operating officer, acting chief of staff, deputy chief of staff, and deputy associate director of external affairs. Most recently, Ms. English served as the principal deputy chief of staff at the Office of Personnel Management. Ms. English also served as chief of staff and senior advisor to the deputy director of management at the Office of Management and Budget. Ms. English received her B.A. from New York University and her M.S. from the London School of Economics.

Jerry Horton will serve as the CFPB’s Chief Information Officer. Before joining the Bureau, Mr. Horton worked at the Department of State where he started and led the Office of the Chief Architect for State’s global information presence. Prior to that, Mr. Horton was the chief information officer at the U.S. Agency for International Development and before that held the same role at the U.S. Mint in the Department of the Treasury. Before working in the government, Mr. Horton spent over 20 years in the private sector leading both business and technical functions for a wide variety of startups, two supercomputer manufacturers, and several large corporations. Mr. Horton received his B.S. from the University of Colorado.

Paul Kantwill will serve as the CFPB’s Assistant Director for Servicemember Affairs. Prior to joining the Bureau, Mr. Kantwill served as the director in the Office of Legal Policy, Office of the Under Secretary of Defense, Personnel & Readiness at the Pentagon. In this capacity, Mr. Kantwill was the Department of Defense’s legal policy expert on the financial industry and the effects financial products and services had on military members and their families. Mr. Kantwill had a 25 year military career as an active duty officer in the U.S. Army Judge Advocate General’s Corps, and has served in Afghanistan, and the Persian Gulf. Mr. Kantwill received his B.A. from Loyola University, Chicago and his J.D. from Loyola University, Chicago School of Law.

John McNamara will serve as the CFPB’s Assistant Director of Consumer Lending, Reporting, and Collections Markets. Mr. McNamara previously served in the same capacity in an acting role, and before that was the debt collection program manager at the Bureau. Prior to joining the Bureau, Mr. McNamara was the chief marketing officer for LiveVox, a provider of cloud contact center solutions, and was the president, chief executive officer, and co-founder of Fidelis Recovery Solutions, Inc. Mr. McNamara has over 30 years of experience working in the debt collection market. Mr. McNamara received his B.A. and M.B.A. from Kennesaw State University.

Elizabeth (Eli) Reilly will serve as the CFPB’s Chief Financial Officer. Ms. Reilly previously served as the deputy chief financial officer at the Bureau, joining as one of the agency’s first employees in 2010. Prior to joining the CFPB, Ms. Reilly was a program examiner and acting branch chief at the Office of Management and Budget. Ms. Reilly was also a Peace Corps volunteer in Guinea, West Africa. Ms. Reilly received her B.A. from Wesleyan University and her M.A.L.D. from Tufts University.

Source: CFPB