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Financial Services Law Insights and Observations

Freddie Mac modifies non-depository seller/servicer financial liquidity requirements

Federal Issues Covid-19 Freddie Mac Non-Depository Institution Forbearance Mortgages

Federal Issues

On June 24, Freddie Mac issued Bulletin 2020-24, which modifies the financial liquidity requirements for non-depository institutions. Specifically, the liquidity requirement is amended to take into account forbearances granted in association with Covid-19. Previously, the liquidity calculation was based in part on a premium on the amount of servicing for loans that are nonperforming (at least 90 days delinquent).  The calculation now takes into account loans a lesser percentage with respect to forbearance loans that were current at the time they entered forbearance.  For purposes of the liquidity requirement, if a mortgage exits forbearance during a calendar quarter, it will continue to be treated as being in forbearance until the end of that quarter for purposes of the liquidity requirement. The liquidity updates are effective on June 30, 2020.