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Financial Services Law Insights and Observations

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  • Washington Department of Financial Institutions urges servicers to support mortgagors

    State Issues

    On March 20, the Washington Department of Financial Institutions issued guidance to Washington State regulated and exempt residential mortgage loan servicers regarding support for borrowers impacted by Covid-19. The guidance urges servicers to support adversely impacted mortgagors by, among other things, forbearing mortgage payments for 90 days from their due dates, refraining from reporting late payments to credit rating agencies for 90 days, offering mortgagors an additional 90-day grace period to complete loan modifications, waving late payment fees and online payment fees for 90 days, postponing foreclosures for 90 days, and proactively reaching out to mortgagors to explain the assistance being offered to mortgagors. Such services are also required to ensure that mortgagors do not experience a disruptions of services if the servicer closes its offices. The guidance notes that reasonable and prudent efforts to assist mortgagers will not be subject to examiner criticism.

    State Issues Covid-19 Washington Mortgages

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  • Washington DFI promotes mortgage borrower assistance

    State Issues

    On March 20, the Washington Department of Financial Institutions (DFI) issued guidance urging mortgage servicers to work with mortgage borrowers who are being impacted by Covid-19. The DFI suggests a number of ways in which servicers can help including, among other things, (i) mortgage payment forbearance; (ii) not reporting late payments to credit rating agencies; (iii) an additional 90-day grace period to complete trial loan modifications; (iv) waiving late payment fees; (v) suspending foreclosures for 90 days; and (vi) proactively communicating with borrowers regarding available assistance options. The DFI also provides additional Covid-19 resources on its website here.

    State Issues Washington Mortgages Covid-19 Mortgage Servicing

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  • Washington Dept. of Financial Institutions issues work from home guidance

    State Issues

    On March 5, the Washington Department of Financial Institutions, Division of Consumer Services issued interim regulatory guidance expressing the Department’s intent to temporarily allow licensed mortgage loan originators to work from home, whether located in Washington State or another state, even if the home is not a licensed branch provided certain conditions are met. The Department also published a website providing Covid-19 resources for DFI licensees.

    State Issues Mortgages Loan Origination Licensing Covid-19 Washington

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  • Washington regulator advises credit unions that virtual annual meetings are permitted

    State Issues

    On March 6, the Washington Department of Financial Institutions, Division of Credit Unions notified credit unions that they are permitted to conduct annual meetings virtually, although any virtual meetings would need to be authorized by the institution’s bylaws and the meeting must otherwise be conducted under board-approved rules of procedure.

    State Issues Washington Credit Union Covid-19

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  • Washington regulator requests notice of credit union closures

    State Issues

    On March 5, the Washington Department of Financial Institutions, Division of Credit Unions asked credit unions to provide notification if they temporarily close a branch or other location typically open to the public. The regulator also asked credit unions to provide notification if they otherwise limit the availability of services.

    State Issues Washington Credit Union Covid-19

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