Compliance Updates: April 2025 In Review
May 5, 2020
Our compliance team is hard at work monitoring any developments at the federal and state level to provide you with the information and tools necessary to continue operations amid COVID-19. We are seeing updates at both the state and national level to accommodate difficulties in this time and are working continuously to ensure our guidance reflects the latest news.
Remember that you can receive compliance-related updates as we publish them by subscribing to our compliance blog.
State and Investor Compliance News
FHLMC. FHLMC published Bulletin 2020-9, which announces FHLMC’s “eligibility, underwriting and delivery requirements for SOFR-indexed ARMs [and] the availability of new ARM Notes and riders specific to the SOFR ARM offering.” Lenders may immediately begin to underwrite borrowers for their SOFR programs and, beginning October 1, 2020, may submit them to Loan Product Advisor® (if certain conditions are met). Lenders will be able to “take out” 30-day Average SOFR contracts in Loan Selling Advisor® beginning November 16, 2020 (see Bulletin for further details). Learn more.
FNMA and FHLMC. FNMA and FHLMC have published a joint announcement and implementation timeline for the new Uniform Residential Loan Application (“URLA”) and associated MISMO® loan application submission files. The new URLA and the submission files must be used beginning March 1, 2021. The current URLA and submission files will no longer be accepted beginning March 1, 2022. Learn more.
NCUA. On April 21, 2020 the National Credit Union Administration published an interim final rule in the Federal Register to permit credit unions to defer, for up to 120 days from closing, the completion of an appraisal or written estimate of market value on “all residential and commercial real estate-secured transactions, excluding transactions for acquisition, development, and construction of real estate.” Learn more.
South Carolina. The South Carolina Department of Consumer Affairs has published their adjustments to the dollar amounts promulgated in various parts of South Carolina’s Consumer Protection Code. We are currently reviewing this change to determine any impact to our document library and/or systems and evaluating any necessary changes. Learn more.
Oklahoma. the Oklahoma Department of Consumer Credit has adjusted certain dollar amounts listed in Oklahoma’s version of the Uniform Consumer Credit Code, including the maximum amounts which can be charged for a late fee. These adjustments apply starting July 1, 2020. Learn more.
Document Changes
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The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.