July Compliance Recap: Forbearance Disclosure and Document Changes

The COVID-19 pandemic continues to change the regulatory and compliance landscape for mortgage lenders. Many states continue to pass laws requiring lenders to offer forbearance options instead of defaulting on loans, and others are trying to facilitate more remote-based options. This has required many document changes, all of which are automatically incorporated into ConformX, ensuring that your documents are compliant with state, federal and investor requirements.  

 

Follow our compliance blog to remain up to date on regulatory changes within the industry.

 

Oregon Covid-19 Related Forbearance Disclosure – On June 30, 2020 Gov. Kate Brown signed HB 4204 which “establishes temporary limitations on lenders being able to enforce default remedies on obligations secured by mortgages, trust deeds, land sale contracts or other instruments.” Learn more.

 

Missouri Amends Laws Affecting Notaries – On July 6, 2020 Gov. Mike Parson signed MO H.B 1655 which repeals laws affecting notaries under Mo. Stat. Ann 486.200 through 486.405. These were replaced with updated provisions  which will take effect on August 28, 2020. Learn more.

 

Edits to ARM and Balloon PMI Disclosures – Effective July 23, 2020, Docutech adjusted the language within our ARM and Balloon PMI disclosures to increase similarity to the language within the Homeowner Protection Act. Learn more.

 

Document Updates

 

  • CO Lock-In Disclosure. As a result of some re-codifications of various Colorado statutes, CO Lock-In Disclosure Cx13134 and CO Dual Status Disclosure Cx14905 will be updated to match the latest versions of the model forms published by the Colorado Division of Real Estate. These changes went into effect July 14, 2020. Learn more.
  • Secured Overnight Financing Rate. New Secured Overnight Financing Rate (SOFR) interest only programs and documents were added to ConformX under the “Custom Programs” investor (CSTM) on July 10, 2020. Learn more.
  • Massachusetts Covid-19 Order. On March 20, 2020 Gov. Charlie Baker of Massachusetts issued Covid-19 Order No. 12, permitting the deferment on certain inspections on home safety equipment on a conditional basis. On June 26, 2020 Gov. Baker signed Covid-19 Order No. 41, rescinding Order No. 12, effective on July 10, 2020. Learn more.
  • Massachusetts HCL Disclosure Retirements. The state of Massachusetts repealed requirements that were at one point needed for applications on high cost home loans. These have not been substantively replaced and have led to the retirement of Cx3742 and Cx3746 as generic documents as well as the removal of the disclosure usually seen just before the signature line for Massachusetts high-cost loans from Cx4193 and Cx20667. These changes went into effect on July 17, 2020. Learn more.
  • FHLMC Cooperative Loan Support. The Federal Home Loan Mortgage Corporation (FHLMC) has now promulgated, in their Single-Family Seller/Servicer Guide, their requirements for cooperative loans. Due to this transparency of their requirements, we were able to roll-out support for these loans starting on July 18, 2020. Learn more.
  • New York Recognition Agreement. We have made modifications to the salutation within our Aztech Recognition Agreement (Cx8091) which is the most widely used recognition agreement for loan secured by shares and proprietary lease of a unit in the state. The change of “Gentlemen:” to “To Whom It May Concern:” took effect July 25, 2020. Learn more.
  • Colorado UCCC updates. Cx3584 underwent some adjustments such as the print configuration of “HELOC = No” to “HELOC = Allow Any”, as well as configuring the first half of the document to print exclusively when “HELOC does not equal Yes”. This took effect July 29,2020. Learn more.
  • URLA adjustments. Changes have been made to FNMA Form 1003/FHLMC Form 65 in ConformX to allow new Cx20667 to be used by clients during the FNMA/FHLMC Limited Production Period. These adjustments are available on ConformX State servers for testing and Cx20667 was made available for use on ConformX Production August 1, 2020. Learn more.
  • Spanish Translation Aid. Similar to the URLA adjustments listed above, the Spanish Translation Aid for the URLA (Cx20668) has been modified to be used in conjunction with the new URLA (Cx20667). These changes went into ConformX Production on August 1, 2020. Learn more.
  • Copies of LE and CD. Due to guidance provided by the CFPB in their new TRID FAQs, we have created print configuration settings for the LE and CD, so that duplicate copies will print in Fulfillment Center packages when lenders require a signed copy to be returned to them. Learn more.
  • Statement of Purchaser Changes. Adjustments have been made to Cx21074 to make it more closely mirror the model form. These changes will take effect on August 4, 2020. Learn more.

 

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