December 2019 Compliance Roundup: CCPA, URLA Implementation Timeline and More

There wasn’t a lot of investor activity in December, as you might expect, given the holidays. The states were likewise fairly quiet last month. But our compliance team was quite busy.

In this post, you’ll find links to some of the work our experts were engaged in last month to keep our clients up to date and fully compliant. We bring you all the news in this month’s compliance update.

Remember that you will always be up to date, up to the minute, by following the posts in our compliance blog.

State and Investor Compliance News

Just a few major compliance updates to announce in December. We’ll continue to monitor all of these changes and bring you details as they develop.

California. The new California Consumer Privacy Act of 2018 (CCPA) went into effect on January 1, 2020, but the Attorney General has not published final rules under its rulemaking authority. This law, as discussed previously, formalizes rights that consumers have concerning the collection and use of their personal information. To answer some of the common questions, our compliance department provided a brief set of FAQs. Learn more.

Fannie Mae and Freddie Mac. The GSEs have issued a joint “URLA Implementation Timeline,” which indicates that the new URLA must be used beginning on November 1, 2020. Industry participants may begin using the new URLA as soon as September 1, 2020, and pre-approved participants may begin using it as soon as June 1, 2020. Learn more.

MERS. After a recent compliance review, we are updating our “From MERS” Assignments to better match the appropriate terminology to refer to the Mortgage Electronic Registration Systems, Inc. (MERS) in the Assignment text. This impacts a number of documents. The changes are now in effect. Learn more.

Department of Veterans Affairs. We have modified a Data Integrity Warning within ConformX to trigger a warning when a Purple Heart recipient applies for a mortgage to let the lender know that the applicant can receive a waiver for the VA Funding Fee in accordance with VA Circular 26-19-30. Learn more.

Document Changes

Our compliance team was quite busy making changes to documents in our vast library during December. The changes have been summarized below with links to the full descriptions of the updates.

• HUD has updated its “Request for Acceptance of Changes in Approved Drawings and Specifications” document, so we have updated ours (Cx14872) to match. Learn more.
• Now that the CFPB has updated a number of the dollar amounts specified in various parts of Federal Regulation Z, we have updated some global mapping of field amounts to conform. Learn more.
• An addendum to the URLA we created in 2014 has now been retired as the CFPB has corrected the ambiguity that required its creation. Learn more.
• Rhode Island nonresident tax forms (Cx16920) were updated based on new forms published on the Rhode Island Division of Taxation website. Learn more.
• After HUD updated two of its forms, the corresponding documents in our library (Cx13513 and Cx15849) have now been updated to match. Learn more.
• Following an updated definition provided by the Wisconsin Department of Financial Institutions-Banking, we have updated form Cx15918. Learn more.
• To provide support for clients involved with community land trusts, we have added a new Community Land Trust Ground Lease Rider, form Cx23607. Learn more.
• The Georgia Department of Banking and Finance now requires a new document, which has been added to our document library. It’s now Cx23616. Learn more.
• Three Nevada mortgage documents were updated in December, including a compensation disclosure (Cx14279), a reasonable means disclosure (Cx12913), and employee disclosure (Cx3839). Learn more.

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