Compliance Calendar

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Compliance Calendar for January 2019

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Updates to Evaluation Notices and Solicitation Letters

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Fannie Mae   Servicing Guide Announcement SVC-2018-06 →
Tags: Foreclosure, Delinquent Loans, Disaster
View Details

In alignment with Freddie Mac and at the direction of the Federal Housing Finance Agency, we have updated several letters that servicers use to solicit the borrower or communicate a decision to the borrower in connection with a workout option. We have updated these letters and notices to simplify the language and overall form, as well as to align with our current workout options. Specifically, we have updated the following letters and notices:

 Borrower Solicitation Letter (Form 745)
 Flex Modification Solicitation Cover Letters
 Evaluation Notices

We have also updated references to these letters and notices in the Guide as necessary to the extent that the titles were updated.
As a reminder, all communications with borrowers must comply with applicable law.

Updated Servicing Guide Topics

 D2-3.2-01, Forbearance Plan
 D2-3.2-07, Fannie Mae Cap and Extend Modification for Disaster Relief
 D2-3.2-09, Fannie Mae Flex Modification

 F-4-01, References to Fannie Mae's Website

Effective Date
Servicers are encouraged to begin using these letters immediately, but must implement these updates by January 1, 2019.

Liability and Fidelity Insurance Updates and Guide Alignment

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Fannie Mae   Servicing Guide Announcement SVC-2018-06 →
Tags: Insurance, Condominiums
View Details

Policies related to project fidelity and liability insurance have been consolidated from the Servicing Guide B-7-01, Liability Insurance Requirements for Project Developments and B-7-02, Fidelity Insurance Requirements for Project Developments into the Selling Guide. Servicers are directed to Selling Guide B7-4-01, Liability Insurance Requirements for Project Developments, and B7-4-02, Fidelity/Crime Insurance Requirements for Project Developments for all requirements.

As part of the consolidation, the following changes have been made to align with the Selling Guide, resulting in servicers no longer having to verify fidelity and liability coverage annually under certain conditions:

  • Planned Unit Development (PUD) projects and condo and co-op projects processed under a limited project review at the time of origination no longer require either fidelity or liability insurance; and
  • Mortgage loans eligible under a waiver of project review at the time of origination per Selling Guide B4-2.1-01, General Information on Project Standards no longer require fidelity/crime coverage.

NOTE: Forbearance Type “A” (a term no longer used in the Selling Guide), or “established condos” as defined in Selling Guide B4-2.1-01, General Information on Project Standards, will require annual verification of fidelity/crime coverage unless subject to noted exceptions in Selling Guide B7-4-02, Fidelity/Crime Insurance Requirements for Project Developments.

Other miscellaneous clarifications and updates have been made in the Selling Guide to align with industry
practices:

  • The terminology for liability policies was updated from “comprehensive” to “commercial” to reflect current industry terminology;
  • The liability policy was clarified to indicate that co-op projects must provide coverage for all areas under the HOA’s supervision when required;
  • Added an insurance trustee as a party to receive carrier notifications on liability policies;
  • Clarified the required fidelity/crime coverage for a management agent; and
  • Removed the mandate for notice to be given to each first lien mortgage loan holder.

Effective Date
Servicers may implement these policy changes at their discretion and at a time of their choosing, but must implement the verification of liability and fidelity/crime insurance for Type “A” established condos no later than January 1, 2019 if not already doing so.

2019 Loan Limits

Effective: January 1, 2019
Industry: Mortgage Lending
Source: Freddie Mac   Freddie Mac Selling Guide Bulletin 2018-24 →
Tag: Underwriting
View Details

As announced in our November 27, 2018 Single-Family News Center article, the FHFA has increased the maximum base conforming and designated high-cost area loan limits effective January 1, 2019. Freddie Mac super conforming Mortgages are subject to the loan limits for designated high-cost areas. The loan limits, effective for Mortgages with Freddie Mac Funding or Settlement Dates on or after January 1, 2019, are as follows:

Maximum Loan Limits


On and before December 31, 2018 On and before December 31, 2018

On and after January 1, 2019

On and after January 1, 2019

Property type

Maximum Base Conforming Loan Limits1 Maximum Super Conforming Loan Limits1, 2

Maximum Base Conforming Loan Limits1

 Maximum Super Conforming Loan Limits1, 2

Mortgages secured by 1-unit properties

$453,100 $679,650

$484,350

$726,525

Mortgages secured by 2-unit properties

$580,150 $870,225

$620,200

$930,300

Mortgages secured by 3-unit properties

$701,250 $1,051,875

$749,650

$1,124,475

Mortgages secured by 4-unit properties

$871,450 $1,307,175

$931,600

$1,397,400

1 Except for Mortgages secured by properties in Alaska, Hawaii, Guam and the U.S. Virgin Islands

2 Actual loan limits for specific counties in high-cost areas, as determined by the FHFA, may be lower than the maximum permitted loan limit listed above. Visit the FHFA loan limits web page for specific loan limits for each high-cost area.

The maximum base conforming loan limits for Mortgages secured by properties in Alaska, Hawaii, Guam and the U.S. Virgin Islands will be 50% higher than those listed above. There are no properties in Alaska, Hawaii, Guam and the U.S. Virgin Islands with loan limits higher than the applicable base conforming limits for 2019. As a result, there are no super conforming limits specific to Alaska, Hawaii, Guam or the U.S. Virgin Islands for 2019.

For super conforming Mortgages, notwithstanding the maximum loan limits shown in the above chart, Sellers must review the 2019 loan limits permitted for the specific county in which the property is located. The FHFA provides this information on its web site.

Loan Quality Advisor® was updated on December 3, 2018 so Sellers may begin evaluating Mortgages with these new original loan amounts immediately. Loan Product Advisor was updated on December 1, 2018 so Sellers may begin originating Mortgages with these new loan amounts immediately. However, Mortgages meeting the 2019 limits are not eligible for sale to Freddie Mac until on or after January 1, 2019.

Loan Selling Advisor® was updated on December 3, 2018. Mortgages originated with loan amounts that meet the 2019 loan limits, but are not eligible under the 2018 loan limits, must not have a Freddie Mac Funding Date or Settlement Date earlier than January 1, 2019.

Guide impacts: Sections 4203.3 and 4603.2

Document Custodian Requirements

Effective: January 1, 2019
Industry: Mortgage Lending
Source: Freddie Mac   Freddie Mac Selling Guide Bulletin 2018-24 →
Tag: Certification, Endorsement, and Delivery
View Details

Freddie Mac permits Seller/Servicers to enter into Tri-Party Agreements with up to two Document Custodians per Seller/Servicer number, provided at least one of them is a Designated Custodian.

To provide flexibility, we will allow Seller/Servicers to enter into Tri-Party Agreements with up to five Document Custodians per Seller/Servicer number and are removing the requirement that one be a Designated Custodian.

Guide impact: Section 2202.1

Assembly Bill No. 3212 California Modifies Provisions Regarding Service Member Protections

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending
Source: California   California Assembly Bill No. 3212 →
Tag: California
View Details

AB 3212 extends the length of time that service members are protected against foreclosure, eviction, repossession, and default judgments. It also extends to them interest rate protections for student loans and clarifies that students in the National Guard and Reserve have a right to academic leave when they are called to active duty. The bill updates current law to close loopholes that have been used to take advantage of service members and extends the protections of California law to cover all service members in California. Prior to this new law, some protections only applied to members of the Guard and Reserve who are called to active duty. 

See link for complete Bill text.

Foreclosure Sale Marketing and Foreclosure Auction Services

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Fannie Mae   SVC-2018-07 →
Tag: Foreclosure
View Details

Servicers are encouraged to implement these changes for all foreclosure sales scheduled on or after October 1, 2018, but must implement them for all sales scheduled on or after January 1, 2019. 

The foreclosure and third party sale program (TPS Program) applies to foreclosure sales on properties securing first lien conventional mortgage loans. To reduce expenses to both Fannie Mae and our servicers and to encourage more third party foreclosure sales, we are updating F-1-08, Managing Foreclosure Proceedings to 

1. require mandatory use of Fannie Mae vendors for foreclosure sale marketing services in certain jurisdictions, and 

2. encourage the use of Fannie Mae vendors to conduct public foreclosure auction services in certain jurisdictions. 

We have engaged Auction.com® and Altisource® as Fannie Mae vendors to provide these services in certain jurisdictions. Auction.com provides both foreclosure sale marketing and, if requested by Mortgage Default Counsel law firms, auction services. Altisource, through its auction platform Hubzu®, will provide foreclosure sale marketing services. The current process allowing the Mortgage Default Counsel law firm the option to choose whether to use a Fannie Mae vendor for foreclosure auction services will not change. For details on the jurisdictions where we have engaged these vendors, refer to the Foreclosure Sale Marketing and Auction Services Exhibit; any future amendments will be communicated.

Maryland Foreclosure Registration System

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Maryland   Link →
Tags: Maryland, Foreclosure
View Details

This bill will allow counties to receive prompt notification about the ownership of foreclosed properties within their jurisdiction. This “push” rather than “pull” system could prove very helpful to county public safety and code enforcement officials to better manage properties in transition.

  • Requires DLLR to establish a procedure for foreclosure purchasers to keep the registry information current by providing updated information within 21 days of learning of any changes
  • Requires DLLR to promptly send a copy of the initial registration and any sub
  • It creates a process for local officials to receive prompt and accurate notifications about foreclosed properties which allows them to take timely action in the interest of their communities.

Update:

Maryland Replaces Foreclosed Property Registry with Foreclosure Registration System

FHFA Guidance for Assessing Mortgage Asset Credit Risk

Effective: January 1, 2019
Industry: Consumer Lending
Source: Other   FHFA AB 2018-02 →
Tag: Banking
View Details
  • Effective, January 1, 2019, FHFA will consider a Bank’s use of models and methodology for internal assessments of mortgage asset credit risk to be satisfactory if the Bank’s use of models and methodology meets the criteria described in this Advisory Bulletin.

Servicing Guide Updates

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Freddie Mac   Guide Bulletin 2018-26 →
Tag: Foreclosure
View Details

Updated State foreclosure timelines for all States

Effective for all foreclosure sales completed on or after January 1, 2019

  • Updating our State foreclosure timeline requirements to provide that Freddie Mac will be subject
    to only one foreclosure timeline for that State
  • This applies to Mortgages already in foreclosure, where the foreclosure sale is held on or after January 1, 2019 as well as new foreclosure referrals
  • We are also revising the State foreclosure timelines in many States

Servicers should review Guide Exhibit 83 in its entirety for the revised requirements.

Updates to Compensatory fees

Effective for all foreclosure timeline compensatory fees assessed on foreclosure sales completed on or after January 1, 2019

  • Freddie Mac is making significant changes to the way State foreclosure timeline compensatory fees are calculated, assessed, and, when applicable, billed
  • Freddie Mac will no longer aggregate a Servicer’s performance for determining State foreclosure timeline compensatory fees on an intra-state basis each month. Instead, beginning with foreclosure sales on or after January 1, 2019, Freddie Mac will aggregate a Servicer’s performance on a national/portfolio basis each calendar year (i.e., the performance of all Mortgages subject to foreclosure timeline compensatory fees for which a Servicer completes a foreclosure sale in a calendar year will be aggregated).

[Please see guide bulletin for complete details]

Updates to the Servicer Success Scorecard

  • Revising how Servicers are segmented into rank groups, and introducing an annual ranking, as applicable
  • Amending weights for the default management metrics

Updates to our Document Custodian requirements

  • We will now allow Seller/Servicers to enter into Tri-Party Agreements with up to five Document Custodians per Seller/Servicer number, and are removing the requirement that one be a Designated Custodian.

Capitalization and Extension Modification for Disaster Relief Evaluation Notice

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Freddie Mac   Freddie Mac Servicing Bulletin 2018-22 →
Tag: Disaster
View Details

Servicers are encouraged to begin using the revised evaluation notice immediately, but must use the revised version by January 1, 2019.

Bulletin 2018-14 announced multiple revisions to our Borrower evaluation notices in Guide Exhibit 93 and solicitation letters in Exhibits 1145, 1191, 1191A and 1191B. 

We are announcing similar changes to the Capitalization and Extension Modification for Disaster Relief Evaluation Notice, which is exclusive to Freddie Mac’s evaluation notices inventory, and aligning our responses to the “Frequently Asked Questions” section of the evaluation notice to the current requirements in Section 9206.4. 

Guide impact: Exhibit 93

Foreclosure Time Frames and Compensatory Fee Requirements

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Fannie Mae   Fannie Mae Servicing Guide Announcement SVC-2018-10 →
Tags: Foreclosure, Fees
View Details

This Announcement describes policy changes related to foreclosure time frames and compensatory fee requirements.

These changes are not applicable to reverse mortgage loans.

Foreclosure Time Frames and Compensatory Fee Requirements

At the direction of the Federal Housing Finance Agency (FHFA) and in alignment with Freddie Mac, we are

  • revising our allowable foreclosure time frames, and
  • updating our policy related to assessing compensatory fees for delays in foreclosure.

Date of Servicing Guide Update

We have posted a revised Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit and will update A1-4.2-02, Compensatory Fees for Delays in the Liquidation Process and F-2-01, Compensatory Fee Calculation Examples to reflect these policy changes in the February 2019 Servicing Guide update.

Allowable Foreclosure Time Frames

First, we have revised the maximum number of allowable days within which routine foreclosure proceedings are to be completed in twenty jurisdictions as described in the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit.

  • The maximum number of allowable days has been increased for the following jurisdictions: Alabama, Arizona, Idaho, Maine, Maryland, Michigan, Missouri, Nebraska, New Jersey, New York, New York City, Nevada, Tennessee, Utah, Virginia, Vermont, and West Virginia.
  • In the following jurisdictions, the maximum number of allowable days has been decreased: Connecticut, Delaware, and Oregon.

Compensatory Fees for Delays in the Liquidation Process

Next, we are replacing the current monthly compensatory fee process, which involves issuing compensatory fees for failure to comply with foreclosure time frames, with a process that focuses on identifying and resolving root causes of performance issues utilizing our Servicer Total Achievement & Rewards (STAR™) Program performance management framework.

As outlined in the Servicing Guide, we may select compensatory fees as the appropriate remedy for delays in connection with a completed foreclosure. We may assess a compensatory fee if the entire period from the date the delinquency began (the last paid installment (LPI) date) through the foreclosure sale date is longer than our maximum number of allowable days in the applicable jurisdiction in the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit.

Additionally, we leverage our STAR Program performance management framework to evaluate a servicer’s overall performance based on operational assessments and scorecards. Effective with this Announcement, we will leverage the STAR Program to manage foreclosure time frame risks. As part of this process change, we are updating our compensatory fee policy.

Through the STAR Program, we will measure by servicer the magnitude and severity of mortgage loans that exceed allowable foreclosure time frames. A servicer will be subject to a mortgage loan-level review, as described in A2-4-01, Quality Control Reviews, if for three consecutive months either:

(1) more than 25% of its greater than or equal to 90 day delinquent mortgage loan portfolio exceeds Fannie Mae allowable foreclosure time frames, or 
(2) the average number of days beyond Fannie Mae allowable foreclosure time frames is greater than 650 days for its mortgage loan portfolio that exceeds Fannie Mae allowable foreclosure time frames. 

Compensatory fees will be assessed if, after identification of a chronic issue with a servicer’s compliance with foreclosure time frames and completion of a performance improvement plan, the servicer does not meet the terms of a performance improvement plan designed to remediate the issue as described in A1-1-03, Evaluating a Servicer’s Performance.

NOTE: Servicers may be exempt from compensatory fee assessments based upon the number of mortgage loans serviced as well as the number of mortgage loans in excess of the allowable foreclosure time frame. These specific thresholds are determined as part of the STAR Program servicer inclusion criteria for foreclosure time frame management. 

Calculating Compensatory Fees for Delays in the Liquidation Process

Compensatory fees will be applied based on the unpaid principal balance (UPB) of the mortgage loan, the applicable pass-through rate (PTR), the length of the delay, and any additional costs that are directly attributable to the delay. We assess the servicer’s foreclosure time frame performance on a monthly basis at the mortgage loan level using the process in the following table.

Step

Calculating Compensatory Fees

1

a. Calculate the number of days the servicer took to complete the foreclosure process, from the LPI date through the foreclosure sale date. b. Determine if the days are in excess of the allowable foreclosure time frame.

2

Calculate the compensatory fee for each mortgage loan using

  • the UPB of the mortgage loan,
  • the applicable PTR, and
  • the number of days the mortgage loan exceeded the allowable foreclosure time frame.
NOTE: The total compensatory fee amount billed will be adjusted based on the results of the mortgage loan-level review as described in A2-4-01, Quality Control Reviews and the servicer’s implementation of remediation under the performance improvement plan as described in A1-1-03, Evaluating a Servicer’s Performance. 

Effective Date

Servicers must implement these policy changes by January 1, 2019.

California Deferment of Financial Obligations for Reservists

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: California   California Assembly Bill 2521 →
Tags: California, Loss Mitigation
View Details
  • Deletes the requirement to provide a letter signed by the reservist, under penalty of perjury, requesting a deferment of financial obligations, in order for the obligation or liability to be subject to the provisions of the act.
  • Instead, requires the reservist or his or her designee to deliver a written request by the reservist for a deferment of financial obligations to the obligor.

Threshold for Smaller Loan Exemption from Appraisal Requirements for Higher-Priced Mortgage Loans (HPML)

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending
Source: CFPB   Announcement →
Tag: Underwriting
View Details

The threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2019 will increase from $26,000 to $26,700.

The threshold amount will be effective January 1, 2019, and is based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2018.

Fair Credit Reporting Act Disclosures from CRA to Consumers

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending, Mortgage Servicing
Source: CFPB   Final Rule →
Tag: Credit Reporting
View Details
  • Where the consumer is not entitled to a free file disclosure from the nationwide consumer reporting agencies and nationwide specialty consumer reporting agencies, section 612(f)(1)(A) of the FCRA provides that a consumer reporting agency may impose a reasonable charge on a consumer for making a file disclosure
  • The Bureau is issuing a final rule to add a provision to Regulation V (Fair Credit Reporting) Section 1022.141 and Appendix O to codify a maximum allowable charge for disclosures by a consumer reporting agency to a consumer pursuant to FCRA section 609 and to announce the annual maximum allowable charge
  • For 2019, the ceiling on allowable charges under section 612(f) of the FCRA will be $12.50

California Translated Loan Modification Forms

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: California   Alert →
Tag: Loss Mitigation
View Details
  • The DBO has posted to its website translated mortgage disclosure forms in Spanish, Chinese, Tagalog, Vietnamese, and Korean
  • These forms can be used by a financial organization that negotiates primarily in any of the above languages the [sic] modification of any of the terms of a loan or extension of credit secured by residential real property
  • The forms are available for download at DBO’s Master Forms page under Form # DBO-CRMLA 8019
  • The forms available are the CFPB Closing Disclosure Form, Fannie Mae Loan Modification Form (for fixed and variable rates), and the Fannie Mae Mortgage Modification, Re-amortization or Extension Form
  • (a)(2) A supervised financial organization that negotiates the modification of any of the terms of a loan or extension of credit secured by residential real property primarily in Spanish, Chinese, Tagalog, Vietnamese, or Korean, and that offers a borrower a final loan modification in writing, shall deliver to that borrower, at the time the final loan modification offer is made, one of the forms described in paragraph (4) of subdivision (i) summarizing the modified terms of the loan in the same language as the negotiation

First Payment Date

Effective: January 1, 2019
Industry: Mortgage Lending
Source: Fannie Mae   FNMA SEL-2018-06 →
Tags: Underwriting, Closing
View Details

We are clarifying that for both MBS and whole loans the maximum amount of time permitted to occur between the final disbursement date and the first payment date is two months. For single-close construction-to-permanent loans, the two month period begins at the time of the conversion to permanent financing. If the difference is greater than two months, the loan will not be eligible for purchase by Fannie Mae. For example, if the final disbursement date is in January, the first payment date must be no later than March.

Effective Date
Lenders can take advantage of this change immediately, but must do so for loans with disbursement dates on or after January 1, 2019.

Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold

Effective: January 1, 2019
Industry: Mortgage Lending
Source: CFPB   Rule →
Tags: HMDA, Reg C HMDA
View Details
  • The exemption threshold is adjusted to increase to $46 million from $45 million. The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. 
  • Therefore, banks, savings associations, and credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019.

Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold

Effective: January 1, 2019
Industry: Mortgage Lending
Source: CFPB   Rule →
Tags: Escrow-Impounds, Reg Z TILA
View Details
  • The exemption threshold is adjusted to increase to $2.167 billion from $2.112 billion. The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. 
  • Therefore, creditors with assets of less than $2.167 billion (including assets of certain affiliates) as of Dec. 31, 2018, are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2019. 
  • This asset limit will also apply during a grace period, in certain circumstances, with respect to transactions with applications received before April 1 of 2020.  

Fair Credit Reporting Act Disclosures - Maximum Charge

Effective: January 1, 2019
Industry: Mortgage Lending, Mortgage Servicing
Source: CFPB   Rule →
Tags: Reg V FCRA, Credit Reporting
View Details
  • The Bureau of Consumer Financial Protection (Bureau) announces that the ceiling on allowable charges under section 612(f) of the Fair Credit Reporting Act (FCRA) will increase from $12.00 to $12.50, effective for 2019.

New Jersey 2019 High-Cost Home Loan Dollar Adjustment

Effective: January 1, 2019
Industry: Mortgage Lending
Source: New Jersey   Bulletin No. 19-02 →
Tags: Underwriting, Closing
View Details

The New Jersey Department of Banking and Insurance issued a bulletin addressing its annual review regarding the definition of a "high-cost home loan" under the Home Ownership Security Act of 2002.

The amount of $498,610 shall be effective for all completed applications on loans that may be subject to the Act received by the lender on or after January 1, 2019.

2019 TILA Asset-Size Exemption Threshold

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending, Mortgage Servicing
Source: CFPB   Final Rule →
Tags: Underwriting, Closing, Escrow-Impounds
View Details
  • This final rule updates the asset-size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan
  • Creditors with assets of less than $2.167 billion (including assets of certain affiliates) as of December 31, 2018, are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2019

Effective date: This rule is effective February 4, 2019. Applicability date: This rule is applicable on January 1, 2019, consistent with relevant statutory or regulatory provisions.

Home Mortgage Disclosure Act (HMDA)

Effective: January 1, 2019
Industry: Mortgage Lending
Source: CFPB   Regulation C →
Tag: Reg C HMDA
View Details
  • Report new data to new tool

Liability and Fidelity/Crime Insurance for Projects

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending
Source: Fannie Mae   Fannie Mae - Announcement SEL-2018-07 →
Tags: Insurance, Condominiums
View Details

We have updated the Selling Guide to reflect the following:

  • Two- to four-unit condo projects do not require a project review, so further reference to these projects has been removed from B7-4-01, Liability Insurance.
  • We also clarified that fidelity/crime coverage is not required for projects that meet the criteria for a waiver of project review in accordance with B4-2.1-02, Waiver of Project Review.
  • Both liability and fidelity/crime insurance have been updated to remove the requirement for the policies to provide a provision for notification to the condo association or co-op corporation when a policy is substantially modified. However, ten days’ notification is still required when the policies are being cancelled.
  • Miscellaneous other clarifications and updates have been made. 

California Assembly Bill No. 1526 Ch. 247 - Amendments of Section 1788.14 of the Civil Code and Section 337 of the Code of Civil Procedure

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: California   Amendments of Section 1788.14 of the Civil Code and Section 337 of the Code of Civil Procedure →
Tags: California, Foreclosure, Loss Mitigation
View Details

AB 1526, Kalra. Debt collection.

This bill would prohibit a debt collector from sending a written communication to a debtor attempting to collect a time-barred debt without providing specified written notices stating that the debtor may not be sued for the debt, but that the debt, depending on its age, may be reported as unpaid to credit reporting agencies, as specified.

Existing law prescribes periods for commencement of various actions. Among others, an action must be commenced within 4 years if the action is to recover (1) upon a book account whether consisting of one or more entries; (2) upon an account stated based upon an account in writing, but the acknowledgment of the account stated need not be in writing; or (3) a balance due upon a mutual, open and current account, the items of which are in writing. Existing law provides, however, that where an account stated is based upon an account of one item, the time shall begin to run from the date of the item, and where an account stated is based upon an account of more than one item, the time shall begin to run from the date of the last item.
This bill would specify that when the 4-year period in which an action must be commenced has run, no person may bring suit or initiate an arbitration or other legal proceeding to collect the debt. This bill would provide that the period may be extended only in specified circumstances.

“The law limits how long you can be sued on a debt. Because of the age of your debt, we will not sue you for it. If you do not pay the debt, [insert name of debt collector] may [continue to] report it to the credit reporting agencies as unpaid for as long as the law permits this reporting.”

SEC. 2.

 Section 337 of the Code of Civil Procedure is amended to read:

337.

 Within four years:
(a) An action upon any contract, obligation or liability founded upon an instrument in writing, except as provided in Section 336a; provided, that the time within which any action for a money judgment for the balance due upon an obligation for the payment of which a deed of trust or mortgage with power of sale upon real property or any interest therein was given as security, following the exercise of the power of sale in such deed of trust or mortgage, may be brought shall not extend beyond three months after the time of sale under such deed of trust or mortgage.
(b) An action to recover (1) upon a book account whether consisting of one or more entries; (2) upon an account stated based upon an account in writing, but the acknowledgment of the account stated need not be in writing; (3) a balance due upon a mutual, open and current account, the items of which are in writing; provided, however, that if an account stated is based upon an account of one item, the time shall begin to run from the date of the item, and if an account stated is based upon an account of more than one item, the time shall begin to run from the date of the last item.
(c) An action based upon the rescission of a contract in writing. The time begins to run from the date upon which the facts that entitle the aggrieved party to rescind occurred. Where the ground for rescission is fraud or mistake, the time shall not begin to run until the discovery by the aggrieved party of the facts constituting the fraud or mistake. Where the ground for rescission is misrepresentation under Section 359 of the Insurance Code, the time shall not begin to run until the representation becomes false.
(d) When the period in which an action must be commenced under this section has run, a person shall not bring suit or initiate an arbitration or other legal proceeding to collect the debt. The period in which an action may be commenced under this section shall only be extended pursuant to Section 360.

See the link for full description of the new law.

Borrower Evaluation Notices and Solicitation Letters

Effective: January 1, 2019
Industry: Mortgage Servicing
Source: Freddie Mac   Freddie Mac Servicing Bulletin 2018-14 →
Tag: Foreclosure
View Details

Servicers are encouraged to begin using the revised evaluation notices and solicitation letters immediately, but must implement these updates by January 1, 2019. At the direction of the FHFA, under the Servicing Alignment Initiative and jointly with Fannie Mae, we are announcing revisions to our evaluation notices in Guide Exhibit 93 as well as our Borrower solicitation letters in Exhibits 1145, 1191, 1191A and 1191B. 

In response to industry feedback and to promote a better Borrower experience, we are improving the solicitation and evaluation processes by:

 • Reducing the content for ease of Borrower consumption

 • Simplifying and clarifying content and titles 

• Reformatting for improved Borrower readability and understanding 

• Removing redundancies and ambiguity 

• Consolidating: 

➢ Evaluation notices related to the same workout option (i.e., forbearance plans and modifications)

 ➢ Non-approval evaluation notices 

• Adding housing counseling resources for Borrowers and information on how borrowers can avoid foreclosure, including help for military servicemembers  

  • Retiring the Home Affordable Modification ProgramSM (HAMP®) evaluation notices

As a reminder, use of the evaluation notices and solicitation letters is optional; however, they illustrate the level of specificity that is deemed to be in compliance with the requirements of Guide Section 9201.2. The evaluation notices and solicitation letters may be altered in the Servicer’s discretion as it deems necessary to meet the requirements of Guide Chapters 9203, 9206, 9208 and 9209, and to comply with disclosure and other requirements under applicable federal, State or local law. Guide impacts: Sections 8404.6, 9101.2, 9101.3, 9102.4, 9102.5, 9203.5, 9203.9, 9203.12, 9206.11, Exhibits 93, 1145, 1191, 1191A and 1191B

Colorado Uniform Trust Code

Effective: January 1, 2019
Industry: Consumer Lending, Mortgage Lending, Mortgage Servicing
Source: Colorado   CO Senate Bill 180 →
Tags: Colorado, Trusts
View Details
  • Applies to express trusts, charitable or uncharitable, and trusts created pursuant to a statute, judgment, or decree that requires the trust to be administered in the manner of an express trust
  • Does not apply to a business trust, a trust created by a deposit arrangement in a financial institution, or any arrangement under which a person is a nominee or escrowee for another.
  • Establishes definitions, knowledge requirements, default and mandatory rules, common law and governing law, etc.

Please read the entire rule for details.

Temporary Requirements Related to the Federal Government Shutdown

Effective: January 3, 2019
Industry: Mortgage Lending, Mortgage Servicing
Source: Freddie Mac   Guide Bulletin 2019-1 →
Tags: Income, Assets, Underwriting, Loss Mitigation, Insurance
View Details

This guidance is effective immediately and will automatically terminate once the federal government resumes full operations.

SELLER GUIDANCE

Mortgages made to government employees and other workers directly impacted by the shutdown are eligible for sale to Freddie Mac, even if the Borrower is not receiving pay when the Mortgage is delivered to Freddie Mac (for example, the Borrower is on furlough or is exempt from the furlough status but is experiencing an interruption in pay due to the shutdown), provided that: 

  • All Freddie Mac income and employment documentation requirements of the Seller's Purchase Documents are met, including the requirement that a 10-day pre-closing verification (10-day PCV) is obtained no more than 10 Business Days before the Note Date or after the Note Date but prior to the Delivery Date
  • The Seller has no knowledge that the Borrower will not return to work after the shutdown ends; and
  • All other requirements of the Seller's Purchase Documents are met

Note: With respect to the requirements for a 10-day PCV, our information indicates that verification of employment for government employees can often be obtained from a third-party service provider that continues to provide employment verification for government employees, including those on furlough.

Processing of Internal Revenue Service Form 4506-T

We require Internal Revenue Service (IRS) Form 4506-T, Request for Transcript of Tax Return, as applicable, to be signed by the Borrower prior to closing*; we do not require that this form be processed by the IRS prior to closing. However, we require that the Form 4506-T information be obtained as part of a Seller's in-house quality control program*.

The shutdown should not impact a Seller's ability to comply with these requirements.

*Note: This is not required under certain circumstances for automated income assessment with Loan Product Advisor®. Refer to Guide Chapter 5901 for complete details.

Eligibility for sale of Mortgages that require flood insurance

After an announced shut down of the National Flood Insurance Program (NFIP) on December 26, 2018, the program resumed normal operations on December 28, 2018 and is considered operational since December 21, 2018 with no interruption; therefore, Freddie Mac requirements on flood insurance remain unchanged.

SERVICER GUIDANCE

Forbearance

To assist Borrowers directly impacted by the shutdown, Servicers can offer forbearance to such Borrowers in accordance with Chapter 9203.

As a reminder, if a Borrower enters into a forbearance agreement, the Servicer must not accrue or collect late charges from the Borrower during the term of the forbearance plan or any subsequent repayment plan period if the Borrower is complying with the terms of such agreements.

FHA, VA and RHS Mortgages

Servicers of FHA, VA and RHS Mortgages should look to the requirements issued by those government agencies during the shutdown.

Processing of IRS Forms 4506T-EZ and 4506-T

If the Servicer is unable to obtain a tax transcript from the IRS through electronic processing of an executed Form 4506T-EZ, Short Form Request for Individual Tax Return Transcript, or 4506-T per the Guide, the Servicer must obtain a copy of the Borrower's most recent complete and signed individual federal income tax return, when required.

Servicing Mortgages requiring flood insurance

As mentioned above in the Eligibility for sale of Mortgages that require flood insurance section of this Bulletin, the NFIP has not lapsed. Servicers are reminded that Guide Section 9206.12(12) requires Servicers to obtain and/or renew a flood insurance policy in accordance with Section 8202.10 if the Mortgaged Premises is located in a Special Flood Hazard Area (SFHA) at the time of a loan modification.

Special Relief Following the Federal Government Shutdown

Effective: January 8, 2019
Industry: Mortgage Servicing
Source: VA   VA Circular 26-19-1 →
Tags: Fees, Loss Mitigation, Delinquent Loans
View Details

1. Purpose. This Circular expresses concern about Department of Veterans Affairs (VA) home loan borrowers affected by the Federal Government shutdown, and describes measures mortgagees may employ to provide relief. 

2. Direct and Indirect Impact on Borrowers. Directly affected by the Federal Government shutdown are government employees, whether furloughed or otherwise not receiving pay due to the shutdown. Many others have been indirectly affected, including those reliant on income from government employee spending or government-related contracts. 

3. Forbearance Request. VA encourages holders of guaranteed loans to extend forbearance to borrowers in distress as a result of the Federal Government shutdown. Careful counseling with borrowers should help determine whether their difficulties are directly or indirectly related to the shutdown, or whether they stem from other sources that must be addressed. The proper use of authorities granted in VA regulations may be of assistance in appropriate cases. For example, Title 38, Code of Federal Regulations (CFR), section 36.4311 allows the reapplication of prepayments to cure or prevent a default. Also, 38 CFR 36.4315 allows the terms of any guaranteed loan to be modified without the prior approval of VA, provided conditions in the regulation are satisfied. 

4. Late Charge Waivers. VA believes that many servicers plan to waive late charges on loans where the borrower(s) suffered a loss of income due to the shutdown. VA also encourages all servicers to adopt such a policy for any loans that may have been affected due to the ripple effect of the shutdown as mentioned in paragraph 2. 5. Credit and VA Reporting. In order to avoid damaging credit records of Veteran borrowers, servicers are encouraged to suspend credit bureau reporting on affected loans. VA will not penalize affected servicers for any late default reporting to VA as a result. Please contact the appropriate RLC with any questions. 

6. Rescission: This Circular is rescinded January 1, 2020. 

Origination Guidance During a Federal Government Shutdown

Effective: January 8, 2019
Industry: Mortgage Lending
Source: VA   VA Circular 26-19-2 →
Tags: Underwriting, Insurance, Income
View Details

1. Purpose. This Circular provides guidance for Department of Veterans Affairs (VA) home loan borrowers affected by the Federal Government shutdown, and describes measures regarding loan origination.

2. Employment Directly Affected by the Shutdown. For borrowers employed by the Federal Government or other individuals whose employment is directly impacted by the shutdown, a loan is not rendered ineligible for guaranty by VA solely based upon the shutdown. If a borrower is furloughed or directly impacted on or after closing of the mortgage loan due to the shutdown, the loan remains eligible for guaranty, provided that the lender has been able to obtain all required documentation (paystubs, W-2s, verbal VOEs, etc.) prior to guaranty and the loan is current.

3. Income Verification Guidelines. It is recognized that the IRS Form 4506-T may be unobtainable during the shutdown, but unavailability should not present a sole barrier to originating a purchase or refinance loan. VA guidelines for standard and alternative documentation do not include a requirement to obtain IRS Form 4506-T. This applies to both W-2 wage earners and self-employed borrowers. The VA Lender’s Handbook references IRS Form 4506-T in Chapter 4, Topic 8, Documentation for Automated Underwriting Cases (AUS). The IRS Form 4506-T requirement is sometimes listed as a condition on the AUS feedback certificate, or imposed during a manual underwrite by the lender. It is important to note that even if this condition exists, it would be considered an investor or lender overlay exceeding the guidelines established by VA.

4. Underwriting. For income analysis purposes, VA guidelines generally require income to be stable and reliable for 2 years. If the applicant were subject to furlough, that period should not be considered a break in employment provided they returned to work in the same status, and the applicant provides their furlough letter for verification purposes.

5. Flood Insurance Requirement. Per the VA Lenders’ Handbook, Chapter 9, Topic 10, the lender is responsible for ensuring that flood insurance, if needed, is obtained and maintained on any building or personal property that secures a VA loan. Due to the Federal Government shutdown, VA recognizes the Federal Emergency Management Administration (FEMA) and other federal entities may be unavailable for routine certifications or correspondence. In such cases, we remind lenders that non-federal flood insurance policies are acceptable provided coverage is sufficient per current VA policy. See FEMA Memorandum: Write Your Own (WYO) Company Principal Coordinators National Flood Insurance Program (NFIP) Servicing Agent for further information. https://www.fema.gov/what-write-your-own-program.

6. Rescission: This Circular is rescinded January 1, 2020. 

Credit Reporting Guidance Related to the Federal Government Shutdown

Effective: January 11, 2019
Industry: Mortgage Servicing
Source: Freddie Mac   Guide Bulletin 2019-2 →
Tags: Credit Reporting, Loss Mitigation, Delinquent Loans
View Details

EFFECTIVE DATE 

The credit reporting guidance announced in this Bulletin is effective immediately and will automatically terminate once the federal government resumes full operations.

CREDIT REPORTING REQUIREMENTS

Freddie Mac extends to Servicers the flexibility to determine the best method for reporting to a credit repository the status of a Mortgage for a Borrower impacted by the shutdown. Servicers are permitted, but not required, to suppress credit reporting in these instances for the entirety, or a portion, of the period when the Mortgage is impacted by the shutdown. As is always the case, the Servicer must conduct all Servicing actions in accordance with applicable law including, but not limited to the Fair Credit Reporting Act and similar laws governing credit reporting.

CLARIFICATION REGARDING ELIGIBLE HARDSHIPS AND FORBEARANCE PLANS

In response to questions from industry participants, we are clarifying that Borrowers impacted by the shutdown do have an eligible hardship under existing Guide requirements. Borrowers impacted by the shutdown meet Freddie Mac’s forbearance hardship requirements under the “Reduction in Income” hardship, as described in Guide Section 9202.2. While we understand that the reduction or elimination of income for Borrowers impacted by the shutdown is temporary, it is still a hardship, and Servicers must work with impacted Borrowers who are unable to make their Mortgage payments to ensure they are evaluated for a forbearance plan.

Clarification Regarding Credit Reporting for Borrowers Impacted by the Government Shutdown

Effective: January 11, 2019
Industry: Mortgage Servicing
Source: Fannie Mae  
Tag: Credit Reporting
View Details
  • Fannie Mae extends the flexibility to servicers to determine the appropriate method for reporting the status of a mortgage loan for a borrower impacted by the federal government shutdown to the credit repositories. 
  • Servicers are permitted, but not required, to suspend credit reporting in these instances. 
  • As a reminder, servicers are responsible for complying with all applicable laws when reporting a mortgage loan status to the four major credit repositories.

This guidance is effective immediately and will automatically expire when the federal government resumes full operations. 

Civil Penalty Inflation Adjustments

Effective: January 15, 2019
Industry: Consumer Lending, Mortgage Lending, Mortgage Servicing
Source: CFPB   Final Rule →
Tag: Compliance
View Details

The Bureau is adjusting for inflation the maximum amount of each civil penalty within the Bureau’s jurisdiction. These adjustments are required by the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Debt Collection Improvement Act of 1996 and further amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The inflation adjustments mandated by the Inflation Adjustment Act serve to maintain the deterrent effect of civil penalties and to promote compliance with the law. 

See Final Rule for table of adjusted penalty amounts

Impact of Federal Government Shutdown (Selling)

Effective: January 16, 2019
Industry: Mortgage Lending
Source: Fannie Mae   Lender Letter LL-2019-02 →
Tags: Underwriting, Income, Assets
View Details

These temporary requirements apply to borrowers impacted by the shutdown and will automatically expire when the federal government resumes full operations.

Liquid Financial Reserves 

For loans other than high LTV refinances with application dates on or after January 16, 2019, the borrower must have the greater of:

  • two months of documented reserves; or
  • for loan casefiles underwritten through Desktop Underwriter® (DU®), the amount of reserves required by DU (with overlays as required by the Selling Guide for certain transactions); or for manually underwritten loans, the amount of reserves required for the transaction per the Eligibility Matrix and Selling Guide.

Verification of Employment and Income

The following policies apply to all impacted loans (without regard to the application date): 

  • Lenders should continue to attempt to obtain the verbal VOE before delivery of the loan. Based on information we have received, VOEs for the majority of government employees and other workers impacted by the shutdown continue to be readily available from automated systems or third-party service providers.
  • If the lender is unable to obtain the verbal VOE due to the shutdown, we will waive the verbal VOE requirement if the lender documents the loan file with a written statement describing:
    • the steps the lender took to obtain the verbal VOE, and
    • that the requirement could not be met as a direct result of the shutdown.
  • We are waiving the requirement that the paystub be dated no earlier than 30 days prior to the initial loan application date. Lenders must obtain the most current paystub that reflects year-to-date earnings and may need to obtain the final 2018 year-to-date paystub to accurately calculate income. All other paystub requirements remain unchanged.
  • The lender warrants that the borrower is employed at the time the loan is delivered to Fannie Mae.
  • The lender must obtain all other employment documentation as required by the Selling Guide.

Selling Guidance and Requirements Related to the Federal Government Shutdown

Effective: January 16, 2019
Industry: Mortgage Lending
Source: Freddie Mac   Guide Bulletin 2019-3 →
Tags: Underwriting, Income, Assets
View Details

The temporary guidance and requirements will automatically terminate when the federal government resumes full operations.

INTERRUPTION IN PAY 

Mortgages made to government employees and other workers impacted by the shutdown are eligible for sale to Freddie Mac, even if the Borrower is not receiving pay at the time the Mortgage is delivered to Freddie Mac (for example, the Borrower is on furlough or is exempt from furlough status but is experiencing an interruption in pay due to the shutdown), provided that all requirements of the Seller’s Purchase Documents are met, as amended below. 

RESERVES REQUIREMENTS 

For impacted Mortgages with Application Received Dates on or after January 16, 2019, other than Freddie Mac Enhanced Relief Refinance® Mortgages, the Seller must document the greater of: 

  • Two months reserves, using the monthly payment amount as described in Guide Sections 5501.2 and 5501.3, or 
  • The minimum reserves for the Mortgage required by Loan Product Advisor® and the Guide, as applicable

VERIFICATION OF INCOME AND EMPLOYMENT 

For all impacted Mortgages, regardless of the Application Received Date: 

  • The Seller should continue to attempt to obtain the 10-day PCV before delivering the Mortgage to Freddie Mac. Our information indicates that verifications of employment for the majority of government employees and other workers impacted by the shutdown continue to be readily available, including from a third-party service provider. 
  • If the Seller is unable to obtain the 10-day PCV solely due to the shutdown, the Seller is not required to obtain the 10-day PCV prior to the Delivery Date, provided that the Mortgage file contains a written statement from the Seller documenting the steps the Seller took to meet the requirement and that the requirement could not be met as a direct result of the shutdown 
  • The Seller warrants that the Borrower is employed at the time the Mortgage is delivered to Freddie Mac 

Note: When the Borrower’s 2019 paystub reflects $0 year-to-date income due to the interruption in pay, a 2018 year-to-date paystub dated no more than 120 days before the Note Date must be obtained in order to accurately calculate income. 

GOVERNMENT MORTGAGES 

Government funded, guaranteed or insured Mortgages sold to Freddie Mac must meet the requirements of Guide Chapter 4205. Sellers of these Mortgages should look to the requirements issued by those government agencies during the shutdown. 

DU for Government Loans

Effective: January 19, 2019
Industry: Mortgage Lending
Source: Fannie Mae   Release Notes →
Tag: Underwriting
View Details

During the weekend of Jan. 19, 2019, Desktop Underwriter® (DU®) for government loans will be updated to support the VA 2019 county loan limit changes, as well as minor system changes to support the new FHA 2019 loan limits.

Loan Quality Connect

Effective: January 21, 2019
Industry: Mortgage Lending, Mortgage Servicing
Source: Fannie Mae   Learn More →
Tag: Quality Control
View Details

Ring in the New Year with a state-of-the-art system to help you manage the post-purchase review process: Loan Quality Connect™, available to lenders on Jan. 21. Loan Quality Connect drives loan quality and brings lenders simplified technology, seamless collaboration, and increased certainty. Visit the Loan Quality Connect web page for details.  

Learn More eLearning Course Job Aids

Delaware Financial Relief to Federal Employees Impacted by Shutdowns

Effective: January 23, 2019
Industry: Mortgage Servicing
Source: Delaware   Alert →
Tags: Insurance, Foreclosure
View Details

The Act states that its purpose “is to provide for the temporary suspension of judicial and administrative proceedings in Delaware that may adversely affect the civil rights of Federal workers during a shutdown.”  The Act provides for enforcement by the Delaware Attorney General and a civil penalty of up to $10,000 per violation, with that amount to be assessed daily for willful violations.

  • “Federal worker” is defined as “an employee of a Federal government agency who resides in the State of Delaware and includes an employee of a contractor.”
  • “Covered period” is defined as “the period beginning on the date on which a shutdown begins and ending on the date that is 30 days after the date on which that shutdown ends.”

Court-ordered stay

  • Provides that a Federal worker who is furloughed or required to work without pay during a shutdown “may apply to a court for a temporary stay, postponement, or suspension regarding any payment of rent, mortgage, tax, fine, penalty, insurance premium, judgment, or other civil obligation or liability that the Federal worker owes or would owe during the duration of the shutdown.” 
  • A stay can be ordered for the “covered period and 90 days thereafter, or for any part of that period” and a court “may set the terms and amounts for such installment payments as is considered reasonable by the court.”

Protection from eviction 

  • Pprohibits evictions from residential property during a covered period for nonpayment of rent without a court order.  
  • An eviction can be stayed for a period of 30 days if the court finds the Federal worker’s ability to comply with the lease has been materially affected by the shutdown and the stay can be extended for reasons of justice and equity. 

Insurance termination

  • Without a court order, a “covered insurance policy” cannot “lapse, terminate or be forfeited because a Federal worker does not pay a premium or interest or indebtedness on a premium under a policy that is due during a covered period.”

6% interest rate limit

  • Provides that “an obligation or liability bearing interest at a rate in excess of 6 percent per year that is incurred by a Federal worker, or a Federal worker and the Federal worker’s spouse jointly, before the shutdown shall not bear interest in excess of 6 percent.”  
  • The Act’s 6% interest rate limit is not restricted to consumer purpose debts.
  • If the debt is “a mortgage, trust deed, or other security in the nature of a mortgage,” the 6% rate limit applies “during the covered period and 90 days thereafter,” meaning until 120 days after the shutdown ends. 
  • To receive the benefit of the limit, the Federal worker must “provide to the creditor written notice that the Federal worker is furloughed or not getting paid as a result of the shutdown not later than 90 days after the date that the shutdown began.”

Please read the final rule for complete details. 

New Loan Details page in Loan Delivery

Effective: January 28, 2019
Industry: Mortgage Lending, Mortgage Servicing
Source: Fannie Mae   Loan Delivery Release Notes →
Tag: Secondary
View Details

The Loan Details screen in Loan Delivery will offer an enhanced user experience. Benefits include:

  1. Better performance via IE 11/ Google Chrome
  2. Upgraded support of certification data revisions
  3. Improved look and feel

NOTE: Lenders can start delivering all Uniform Loan Delivery Dataset (ULDD) Phase 3 data on 1/28/2019.