November and December Compliance Roundup

The end of 2018 brought several regulatory updates lenders will need to prepare for in the New Year. Here’s a look at the topics we featured in our compliance blog in November and December. For more details, check out our compliance website here. And, if you are not already receiving updates, take advantage of our free subscription service and have compliance updates delivered directly to your email.

The most important change is a tweak to TRID 2.0. TRID 2.0 provides specific guidance for cases where the first column of the “Projected Payments Table” reflects the amounts payable during both the construction- and permanent-phases of a construction-to-permanent loan. Lenders that follow the CFPB’s guidance could end up with a calculation possibly leading to an erroneous disclosure to the borrower.

Several changes were made to ConformX in the past couple of months. Our compliance blog has more information on the new ConformX System Default “Include MI And Escrow In Minimum Total Even If They Do Not Apply.”

In addition, we added or modified several documents for Texas construction-to-permanent loans because Texas structures those loans differently from other states. You can read all about that in this post.

State and Investor Compliance News

We saw some modifications and updates from the federal agencies as well as investors over the past couple of months. The changes are outlined below, and more details can be found on our compliance blog by following the links.

Fannie Mae. FNMA recently updated the Uniform Underwriting and Transmittal Summary (Form 1008) for manually underwritten loans. We are currently reviewing how this may impact our own documents, and any changes we make will be announced on our compliance blog. More.

Pennsylvania. The Pennsylvania Department of Banking and Securities has updated the “base figure” amount. More.

Rhode Island. The repealed appendices promulgating some disclosure forms have not been re-implemented. Instead, the Rhode Island Department of Business Regulation will issue bulletins to promulgate these forms. More.

District of Columbia. Congress has approved an act adopting a new “Revised Uniform Law on Notarial Acts Act of 2018.” More.

Federal Register. A new rule has been added increasing the exemption threshold for higher-risk mortgages. More.

And finally, our compliance experts have received a number of questions regarding what to do in preparation for the ending of the LIBOR and COFI indices. You can find out more about that on our compliance blog in this post.

Document Changes

The document library saw a variety of new forms and revisions these past few months. They’ve been summarized below with links to the full descriptions of the updates.

• New generic FNMA Homestyle documents have been created. More.
• Cx15312 has been updated to include the most recent revisions of credit score graphs. More.
• VA Principal Reduction Disclosure (Cx 21542)’s configuration has been updated. More.
• Citations have been added to the DE Broker Agreement (Cx3583). More.
• MT and WA Inter Vivos Revocable Trust Documents (Cx21130, Cx21131, Cx21132) have been modified. More.
• Texas Home Equity ARM documents have been updated. More.
• W-9 Taxpayer ID form (Cx22) has been updated. More.
• NJ Commitment Letter and Rate Lock-In Agreement (Cx4479, Cx4480) have been updated based on recent amendment. More.
• Cx2283 For Your Protection Get a Home Inspection has been updated More.
• Support for cooperative loans is being added for a variety of states. Many new documents have been created as part of this support. More.
• NJ Broker Agreement (Cx17071) has been modified. More.
• To prevent incorrect printing of the W-9 form, the document will no longer be triggered to print by a SSN value. Rather, only the permanent resident/qualified alien status will determine the printing of forms W-9 or W-8BEN. More.
• LA Mortgage Documents Cx327, Cx485, and Cx19376 have been modified to reflect the current FNMA model. More.
• Step rate decrease, IO life of loan ARMs, and balloon payment ARMs for documents Loan Estimate (Cx18565) and Closing Disclosure (Cx18566) have been modified. More.
• MA Assignment of Mortgage documents (Cx1531, Cx4327, Cx4467) have been updated to include the Property Address. More.
• Some language has been modified in NY Signature/Name Affidavits (Cx865, Cx7965). More.
• NY Section 22 Affidavit (Cx14622) has been reformatted. More.
• Several DC and RI Security Instruments documents have been modified. More.
• A new “upon request” document has been created for requesting for a notice or default of sale in Nevada. More.
• California, Connecticut, and Washington PMI disclosures (Cx999, Cx1029, Cx18541) will be updated to reflect FNMA’s cancellation changes. Compliance can begin in 2019 but will not be required until September. More.
• Print configuration for FL Notice to Purchaser (Cx4131) and TN Title Insurance Disclosure (Cx4167) have been modified. More.
• A balloon payment disclosure has been added to URLA (Cx4193). More.
• Data integrity updates have been made to USDA/RD loans. More.
• A number of new generic FNMA construction documents have been created. More.

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Current information is the only way to ensure that every document you deliver is always fully compliant. Our experts are standing by to support you and we all wish you the very best in 2019.