On January 7, 2025, the Federal Housing Administration (FHA) officially revised its Defect Taxonomy (Final Defect Taxonomy) with the publication of Mortgagee Letter (ML) 2025-01 and the related attachment detailing those changes. The changes are effective as of January 15, 2025, and will be implemented in Appendix 8.0 of FHA Handbook 4000.1 at a later
On December 19, 2024, the Fair Housing Administration (FHA) and the U.S. Department of Housing and Urban Development (HUD) published a draft Mortgagee Letter proposing a new Optional Reimbursement Claim Alternative (ORCA) program. ORCA is intended to allow mortgagees to seek reimbursement for property tax and insurance payments the mortgagee advances on behalf of forward
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) rulemaking board proposed new recordkeeping rules intended to bolster the FDIC’s ability to make deposit insurance determinations for accounts that are the product of a partnership between an FDIC-insured depository institution (IDI) and a financial technology company (fintech). However, despite the proposed rule’s focus on
Over the past month, the Federal Housing Administration (FHA) has enacted and proposed several changes to its Defect Taxonomy. The Defect Taxonomy is contained in Appendix 8 to FHA Handbook 4000.1. The Defect Taxonomy was originally designed to allow FHA to characterize underwriting related errors in FHA mortgages. Now, if these recent changes are
Following a long wait, the U.S. Department of Housing and Urban Development (HUD) published a revised version of the Fair Housing Administration’s (FHA) handbook governing the origination and servicing of FHA loan products, including Home Equity Conversion Mortgages (HECMs, which are more commonly known as “reverse mortgages”). While the revisions in the new handbook are
Based on a recent report from the Financial Stability Oversight Council (FSOC), nonbank mortgage companies (NMCs) need to prepare for additional regulatory scrutiny from both state and federal regulators. In the report, FSOC identifies NMCs as critical participants in both the residential mortgage origination and servicing industries. And in recognition of this distinction, FSOC believes
On April 22, 2024, the Department of Housing and Urban Development (HUD) published its final rule regarding updated flood insurance requirements in certain areas of the country: Floodplain Management and Protection of Wetlands; Minimum Property Standards for Flood Hazard Exposure; Building to the Federal Flood Risk Management Standard. The new rule implements the
This week, in line with the CFPB’s ever-increasing focus on fair lending, Fannie Mae issued a Fair Servicing Best Practices Guide to promote “servicer awareness of fair servicing best practices.” Taking a big picture approach, the guide states that servicers should ensure that “all borrowers are treated consistently and fairly throughout the loan servicing
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a seemingly more inclusive and flexible approach to how financial entities can contest supervisory findings. The appeals process is intended to promote
In an October 2023 advisory opinion, the Consumer Financial Protection Bureau (CFPB) put large banks and credit unions on notice that the use of chatbots and other technologies could increase the risk of violating federal law if those services are ineffective. As we have previously written about, the CFPB’s advisory opinion interprets Section