Freddie Mac issued Guide Bulletin 2018-2 (Bulletin), setting forth servicing updates to the Single-Family Seller/Servicer Guide. Pursuant to the Bulletin, Freddie Mac updated requirements with respect to charge-off recommendations. The updated requirements: identify the scenarios that require a charge-off recommendation; revise lien release requirements upon charge-off approval; and add an example under the definition of “risk of property ownership”. Freddie Mac also updated requirements with respect to document custodians. The updated requirements: permit seller/servicers to enter into tri-party agreements with up to two document custodians (provided that one of them is a designated custodian); require seller/servicers to complete new Form 1035WF (Designated Custodial Agreement: Single Family Mortgages (Wells Fargo Bank, N.A.)) when establishing a designated custodian relationship with Wells Fargo Bank, N.A.; and no longer require seller/servicers that currently utilize Wells Fargo Bank as a document custodian (pursuant to an existing Form 1035, Custodial Agreement: Single Family Mortgages) to monitor the eligibility status of Wells Fargo Bank (as Freddie Mac now performs that function). In addition, Freddie Mac: updated Forms 16SF (Annual Eligibility Certification Report) and 1107SF (Seller/Servicer Change Notification); clarified requirements for determining the trial period payment and terms of a Capitalization and Extension Modification for Disaster Relief; and removed the requirement that a condominium homeowners association maintain certain additional liability insurance coverage. The updated charge-off requirements are effective August 1, 2018 (however, servicers may implement earlier if able). All other updates are effective immediately.
CFPB
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
January 16, 2025
