November Compliance Roundup: Laying the Foundation for 2020

November was a relatively quiet month on the rules side, with only a couple of states making any changes of note. However, Fannie Mae is previewing its plans for early 2020, and between URLA and new ARM products, we expect to see several significant new regulations in the first quarter of the year. November was busy on the document update side, however.

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State and Investor Compliance News

Just a few major compliance updates to announce in November. Fannie Mae announced new plans for ARM products and two states announced changes that may lead to future document modifications. We’ll continue to monitor these changes and bring you details as they develop.

Fannie Mae. FNMA has announced pending plans to modify their ARM products in the first half of 2020 to conform to the guidance issued by the FHFA and in coordination with FHLMC. Some new language will be added into the uniform notes and other legal documents. New ARM products are also planned. While no changes are finalized at this time, we will continue to monitor this transition and provide alerts as actions are finalized. Learn more.

Pennsylvania. The Pennsylvania Department of Banking and Securities has announced that they will be adjusting the “base figure” from $256,023 to $260,404. The “base figure” is a factor in determining what types of loans certain mortgage lending rules apply to. We are currently reviewing this change to determine any impact to our document library. Learn more.

Texas. The Finance Commission of Texas adopted proposed amendments to various sections the state code, as well as amendments to the “Conditional Letters” published within such codes and on their website. We are currently reviewing these changes to determine any impact to our document library. Learn more.

Document Changes

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

• We have updated the logic for form Cx20336, HUD/VA Addendum to Uniform Residential Loan Application. The changes went into effect December 4. Learn more.
• A number of Fannie Mae and Freddie Mac interest-only notes and riders were modified based on instructions from the FHFA in connection with the new ATR/QM rules. Learn more.
• FHA Loan Underwriting and Transmittal Summary (Cx13513) was modified to match the latest copy published on HUD’s website, but retained the previous form’s formatting. Learn more.
• VA Request for a Certificate of Eligibility (Cx3957) was modified due to VA Circular 26-19-30, granting Purple Heart recipients a waiver from certain fees. Learn more.
• Verification of VA Benefits form Cx3952 has been updated on the VA website and has led us to update our form accordingly. Learn more.
• More documents have been changed in the library to allow them to be printed on letter size paper instead of legal sized. Learn more.
• The Taxpayer First Act has led to a new MISMO form, which has now been created and added to the library. It will be triggered to print when the “Print Taxpayer Consent Form” flag is set to “Yes.” Learn more.
• Washington State’s Interest Rate Lock Agreement (Cx2792) has been updated to match the latest form from the state’s Department of Financial Institutions. Learn more.
• Two Illinois forms have been updated. Both the “First Payment Letter Enhanced Fees” (Cx7606) and Notice of Servicing Transfer (Cx17905) have both been updated in the library to match the state’s requirements. Learn more.
• New logic has been added to two Florida forms. A set of global standard value mappings have been added to the “Rescindable Loan” (Field 42761). Learn more.
• The logic has been adjusted that triggers the AP Table on the Loan Estimate and Closing Disclosure. The same logic now will trigger both the AP Table and the AP reference. Learn more.
• Form Cx15312 includes a graph to disclose a range of credit scores by a particular credit reporting agency and the percentage of consumers with scores in a particular range. Since those graphs have been updated by the credit reporting agencies, the form has also been updated. Learn more.
• Mappings for two fields associated with community property states have been updated to trigger a corresponding checkbox on the redesigned FNMA 1003 to show whether the property is located in such a state. Learn more.

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