Monthly Regulatory Compliance Change Management Summary

The April Regulatory Compliance Change Management Summary is linked for your reference.

This month’s Regulatory Compliance Change Management conference call will take place on Tuesday, May 26th at 3pm EST.

To register for the monthly call, please email compliancechgmngt@cenlar.com. For your convenience, the session will be recorded and made available to clients who are unable to attend.  If you registered for a call in the past, you will be automatically registered for this call and do not need to register again.

Any questions related to the monthly summary, overview process, or specific regulatory change items can be sent directly to  compliancechgmngt@cenlar.com.

The Compliance Department will respond within two business days of receipt (excluding weekends and holidays).

There are currently no items showing as ‘Out of Compliance’ (effective date has passed and we are beyond our standard implementation timeframe) on our April report.

Noteworthy Items:

  • Q6622 Texas Office of the Consumer Credit Commissioner Advisory Bulletin (Effective 4/16/2020) – The Texas Office of the Consumer Credit Commissioner (OCCC) has issued the “Regulated Lender Advisory Bulletin: Coronavirus Emergency Measures.” This bulletin sets forth emergency measures that regulated lenders should consider in response to the COVID-19 pandemic.  The OCCC Regulated Lender Advisory Bulletin provides as follows:
  • Annual Report Deadline – A regulated lender may file its complete 2019 annual report with the OCCC by June 1, 2020 without enforcement action from the OCCC for failing to file a timely 2019 report.

Cenlar is aware of this emergency measure from the OCCC and its requirements.  While Cenlar is not responsible for the annual reporting to the OCCC, Clients who do report this data should be aware that annual reporting can be submitted by June 1, 2020 without enforcement action.

  • Q6600 Montana Reg 209535r (Effective 3/24/2020): The Department of Administration of the State of Montana has adopted an emergency, temporary extension of the time period for quarterly reporting by Mortgage Servicers.
    • The department is adopting New Rule I(3) to give mortgage servicers additional time to file the mortgage servicer first quarter report to allow them to address potential issues with gathering the data and filing the report.
    • The time period provided in ARM 2.59.1743(1) within which mortgage servicers shall submit the quarterly report for the quarter ending March 31, 2020, is temporarily extended to June 14, 2020.

Cenlar is aware of this emergency rule from the Department of Administration of the State of Montana and its requirements. While Cenlar is not responsible for direct quarterly reporting regarding the time period in ARM 2.59.1743(1), Clients who do report this data should be aware that an extension has been provided to submit reporting to June 14, 2020.

  • Q6733 Washington DC B23 735 – Act 23-299 (Effective 5/4/2020): The District of Columbia has enacted the COVID-19 Supplemental Corrections Emergency Amendment Act of 2020 to amend, on an emergency basis, the COVID-19 Response Supplemental Emergency Amendment Act of 2020 (D.C. Act 23-286) to include mortgage lenders as covered entities, and require notice of approved deferral applications. The COVID-19 Response Supplemental Emergency Amendment Act of 2020 (D.C. Act 23-286) was previously tracked under Q6562.
  • The COVID-19 Response Supplemental Emergency Amendment Act of 2020 (D.C. Act 23-286) is amended as follows:
    • Strikes the term “mortgage servicer” everywhere it appears and inserts the term “mortgage lender” in its place.
    • Amended to read that the 90-day deferment is for the monthly payment of principal and interest on a mortgage.  The Act currently states “mortgage payments.”
  • The following provisions have been added to the Act:
    • A mortgage lender who approves an application for deferment pursuant to this section shall, on or before May 8, 2020, provide to the Commissioner of the Department of Insurance, Securities, and Banking (Commissioner), notice of all approved applications on a form prescribed by the Commissioner and such notice shall include the percentage of mortgage deferment approved for and accepted by each borrower.
    • After the initial submission prescribed in this paragraph, a mortgage lender who approved an application for deferment pursuant to this section shall provide the Commissioner with a list of all new approvals in 15-day intervals for the duration of the public health emergency and for 60 days thereafter.
    • The Commissioner may request information on the number and nature of approvals between 15-day intervals.

Cenlar is aware of this emergency amendment act from the District of Columbia and its requirements. While Cenlar is not responsible for the above reporting to the Commissioner, Clients who do report this data should be aware that failure to comply may result in regulatory sanctions, fines, or penalties. 

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