Fannie Mae issued Lender Letter LL-2019-2 (Lender Letter), establishing a 2 month minimum reserve requirement for borrowers impacted by the federal government shutdown (Shutdown). Per the Lender Letter, borrowers impacted by the Shutdown must now have a minimum of 2 months of documented reserves. Lenders must, however, comply with the reserve requirements set forth in Desktop Underwriter or the Eligibility Matrix (for manually underwritten loans) if the reserve requirements exceed 2 months. The 2 month minimum reserve requirement does not apply to high loan-to-value refinance transactions. Fannie Mae also amended verification of employment and paystub age requirements for borrowers impacted by the Shutdown. In addition, Fannie Mae clarified that lenders may continue to deliver mortgage loans to Fannie Mae for borrowers who, as a result of the Shutdown, may not be receiving income at the time the loan is delivered. The 2 month minimum reserve requirement is effective for loans with application dates on or after January 16, 2019. All other requirements are effective immediately. The requirements automatically expire when the government resumes full operations.
CFPB Amends Fair Credit Reporting Act with respect to Medical Information
The CFPB adopted rules amending the Fair Credit Reporting Act (FCRA) with respect to medical information. Per the rule adoption, the CFPB removed an exception