Freddie Mac issued Bulletin 2019-3 (Bulletin), establishing a 2 month minimum reserve requirement for borrowers impacted by the federal government shutdown (Shutdown). Per the Bulletin, borrowers impacted by the Shutdown must now have a minimum of 2 months of documented reserves. Lenders must still, however, comply with the minimum reserve requirement set forth in Loan Product Advisor and the Seller/Servicer Guide if the reserve requirement exceeds 2 months. The 2 month minimum reserve requirement does not apply to Freddie Mac Enhanced Relief Refinance Mortgages. Freddie Mac also amended verification of employment and paystub age requirements. In addition, Freddie Mac clarified that lenders may continue to sell mortgage loans to Freddie Mac for borrowers impacted by the Shutdown as long as all requirements of the lender’s purchase documents are met. The minimum reserve requirement is effective for loans with application dates on or after January 16, 2019. All other requirements are effective immediately. These 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