Freddie Mac issued Guide Bulletin 2018-9 (Bulletin), setting forth servicing updates to the Single-Family Seller/Servicer Guide. Pursuant to the Bulletin, Freddie Mac: consolidated requirements for short-term, long-term and unemployment forbearance plans into a single streamlined policy; introduced NextJob re-employment services for borrowers with Freddie Mac Home Possible Mortgages in Duty to Serve high-needs areas; updated special endorsement requirements for condominium projects and planned unit developments; revised requirements with respect to the reimbursement of unearned property insurance premiums; clarified that sales tax is considered a non-reimbursable expense unless it is included within the total expense of a line item that does not exceed the related expense limits set forth in the Guide; provided clarification regarding the automatic transfer of funds from a servicer’s principal and interest custodial account to Freddie Mac; revised requirements regarding the release of documents to sellers/servicers from document custodians; and removed the requirement for certain tenant-occupied properties that a servicer report lead-based paint or health code citations in connection with forbearance plan, loan modification and short sale evaluations. The consolidated forbearance plan requirements are effective December 1, 2018 (servicers may, however, implement immediately). The expanded scenarios with respect to reimbursement of unearned property insurance premiums are effective for all reimbursement claims submitted in the Freddie Mac Reimbursement System on and after October 1, 2018. All other updates are effective immediately.
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