In a significant move for mortgage servicers and mortgage loan borrowers impacted by the COVID-19 pandemic, the CFPB issued an interim final rule this week that will, among other things, enable servicers to offer a payment deferral option. The rulemaking provides specific parameters for what qualifies as a COVID-19 payment deferral and, provided that those criteria are satisfied, a servicer will be able to offer it without first collecting a complete loss mitigation application or risking a violation of Regulation X’s anti-evasion clause. With the Fannie Mae and Freddie Mac COVID-19 deferral options set to become effective in a matter of days, time is of the essence to understand what is required. This webinar will explain what is in the CFPB’s interim final rule so that you can effectively implement a deferral option for GSE and portfolio loans alike.
- Begin building out the GSE and non-GSE process, including the contents of an offer letter:
- Are you going to include short-term offer verbiage and/or acknowledgment verbiage?
- How will you require a borrower to accept?
- How will you record and prove a COVID-19 hardship permitting an IFR exception?
- Time is of the essence.
- Ensure that the parameters of deferral options comply with all IFR conditions.
- Consider how, if at all, the IFR impacts loans that were severely delinquent pre-COVID-19.
- Consider appropriate marketing in a post-forbearance world.
- Remember that the issue of execution/recordation of COVID-19 deferrals remains.