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Kansas Office of the State Bank Commissioner issues work from home guidance
On March 16, the Kansas Office of the State Bank Commissioner (OSBC) issued temporary guidance allowing licensed mortgage companies, mortgage loan originators, supervised loan licensees, credit services organizations, money transmitters, credit notification registrants and their employees to work remotely due to the Covid-19 crisis. Licensed or registered individuals and entities will be allowed to work from their residences or a company designated location--even if the residence or location is not a licensed or registered branch location--providing they have temporary policies, procedures, and a plan for supervision in place. OSBC also set forth best practices for remote work to ensure that security of information is maintained.
Connecticut Dept. of Banking issues work from home guidance
On March 9, the Connecticut Department of Banking issued a memorandum indicating that individuals who work for Consumer Credit Licensees currently licensed in Connecticut may temporarily work from home even though such home location is not currently licensed by as a branch office, so long as certain criteria are met.
Arkansas Securities Dept. issues work from home guidance
On March 13, the Arkansas Securities Department issued interim regulatory guidance temporarily allowing licensed mortgage loan officers to work from home even if the home is not a licensed branch location provided that the MLO working from home is in compliance with all state and federal data security requirements.
Alabama State Banking Dept. reminds businesses on continuity planning
On March 12, the Alabama State Banking Department issued a reminder that business continuity planning should be reviewed and updated because the Department plans to maintain normal operations regarding licensure and examination amid the Covid-19 outbreak. Licensees should immediately notify the Department of any circumstances that require the closure, relocation, or remote work program and any efforts taken to work with customers.
Alaska Dept. of Commerce communicates to NMLS on MLOs
The Alaska Department of Commerce, Community & Economic Development communicated to NMLS that an Alaska mortgage loan originators’ (MLO) license is issued for a calendar year (being quarantined for 14-30 days would not be considered the “majority” of their time over the course of a year) and that a branch registration for the MLO’s home would not be required for this short period of time.
GSEs provide Covid-19 guidance
FHFA and Freddie Mac have issued reminders that borrowers impacted by Covid-19 meet forbearance hardship requirements for Fannie Mae and Freddie Mac loans, and servicers must work with impacted borrowers unable to make mortgage payments and be responsive to potential requests for assistance.
Freddie Mac also reiterated a requirement for sellers/servicers to maintain a business continuity plan as set forth in Section 1302.3 of the Freddie Mac Guide.
FHA issues partial waiver of face-to-face interviews, issues FAQs on single-family housing
On March 13, FHA issued a partial waiver of the face-to-face interviews with borrowers before three full monthly installments due are unpaid as required by 24 C.F.R. § 203.604. In lieu of an in-person meeting, servicers may establish contact by phone, email, or video calling services. The partial waiver applies for 12 months, until March 13, 2021.
FHA also issued FAQs for Single-Family Housing on March 13, noting that (i) FHA is continuing to endorse loans and process claims but there may be processing delays; (ii) if HOCs are closed, stakeholders should email the resource center at answers@hud.gov for escalated calls; (iii) the deadline for audited financial statements has been extended to April 30, 2020; (iv) CAIVRS and TOTAL Scorecard will continue to be available to lenders; (v) all on-site reviews are suspended until further notice but lender monitoring and loan reviews will continue remotely; and (vi) occupancy inspections and appraisals must continue but no physical contact with occupants is required.
FHA issues Covid-19 guidance
On March 9, FHA issued a reminder to servicers of FHA’s loss mitigation options, noting that Covid-19 could be an event negatively impacting a borrower’s ability to pay their monthly mortgage payment.
CFPB provides consumers with Covid-19 guidance
The CFPB is maintaining a website with steps consumers can take to protect themselves from the financial impact of Covid-19. The website includes guidance on steps to take in the event of difficulty meeting mortgage payment obligations, working with housing counselors, questions relating to credit reporting, and other resources.
Fed announces creation of special credit facility
On March 17, the Federal Reserve announced the creation of a special credit facility to serve as a funding backstop to facilitate commercial lending. Under the structure, the Federal Reserve Bank of New York will lend money to the newly created special purpose vehicle (SPV) on a resource basis, to be secured by the commercial loans purchased by the SPV from eligible issuers. There are limits on the maximum amount any single issuer may sell to the SPV. The SPV is scheduled to cease purchasing additional commercial paper on March 17, 2021.