July 2018 Compliance Recap

Summer typically sees fewer compliance updates, and this summer is no different. That said, we did see some changes in California and from the nation’s largest secondary market investor.

All of these changes were detailed on our compliance blog. Subscribe to learn about all of the industry’s compliance news before anyone else.

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State and Investor Compliance News

California’s regulators were busy in July, sending down two items that were covered by our compliance professionals.

California: In early July, the California Department of Business Oversight announced that it had posted translated mortgage disclosure forms to its website. Specifically, new disclosures were made available in Spanish, Chinese, Tagalog, Vietnamese, and Korean. The forms are used for the modification of any of the terms of a loan or extension of credit secured by residential real property. Find out more here.

Also in California: Governor Brown signed “The California Consumer Privacy Act of 2018” at the very end of June.  The Act’s scope as it relates to consumer privacy is broad and has a tentative effective date of January 1, 2020. More.

Fannie Mae: The nation’s largest mortgage investor published Lender Letter LL-2018-03 in July. The letter provides for revisions to Fannie’s requirements concerning PMI termination. Servicers are required to implement these changes by March 1, 2019, but may optionally begin complying with these changes on January 1, 2019. More.

Also Fannie Mae introduced “Enterprise-Paid Mortgage Insurance” (“EPMI”) on July 10. EPMI is an alternative to the more traditional borrower-paid and lender-paid private mortgage insurance plans.  Fannie Mae is rolling out EPMI in a pilot program for testing, which may eventually turn into a program which all lenders may use. More.

Document Changes

In July, we saw a number of required document updates that we then handled for our clients. Following is a short summary with links to the full descriptions of the changes.

  • PMI Disclosure Modifications for Construction Loans (Cx29, Cx14292, Cx14293). More.
  • Retired: Illinois Private Mortgage Insurance Disclosure (Cx1311). More.
  • New: NC Prepared By Certification (Cx22402). More.
  • Retired: FHA Negative Equity Positions Disclosure (Cx15200) and FHA Negative Equity Positions Borrower Certification (Cx15175). More.
  • New: Preapplication Credit Report Authorization (Cx22437). More.
  • PIN has been added to recordable documents for Fulton County, GA. More.
  • New: Washington Student Loan Refinance Disclosure (Cx22454). More.
  • Several generic documents have been modified to support three or four trustees and settlors. More.
  • PMI on the New York Lock-In Agreement (Cx5099). More.

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