Freddie Mac Updates Servicing Rules and Increases Foreclosure Timelines in 34 States
By Anna DeSimone
October 14, 2015, Freddie Mac Issued Bulletin 2015-18: Servicing. This Single-Family Seller/Servicer Guide (“Guide”) Bulletin announced:
State foreclosure time lines and compensatory fees
Increased State foreclosure time lines in 34 jurisdictions
Extension of the temporary suspension of the assessment and billing of State foreclosure time line compensatory fees announced in Bulletin 2014-19
Adjustments to the State foreclosure time line compensatory fee billing methodology for Mortgages referred to foreclosure prior to October 1, 2011 – January 1, 2016
Mortgage modifications
Updates to our notification requirements for the Home Affordable Modification Program (HAMP®) Year Six “Pay for Performance” incentive
Expansion of our simultaneous assumption and modification options to include all eligible hardships
Updates in response to the Freddie Mac Streamlined and MyCity Modification eligibility change announced in Bulletin 2015-15 – March 1, 2016
Lender-Placed Insurance
A deductible requirement for Lender-Placed Insurance policies – July 1, 2016 (New)
Reimbursement
A revision to our mortgage insurance premium reimbursement requirements – January 1, 2016
Updates to our bankruptcy attorney fee reimbursement limits – December 1, 2015
EFFECTIVE DATE: All of the changes announced in this Bulletin are effective immediately unless otherwise noted.
STATE FORECLOSURE TIME LINES AND COMPENSATORY FEES
As announced in our Single-Family News Center article dated September 3, 2015, we are increasing State foreclosure time lines in certain jurisdictions and extending the temporary suspension of the assessment and billing of State foreclosure time line compensatory fees announced in Bulletin 2014-19.
Additionally, we are adjusting our State foreclosure time line performance assessment.
State foreclosure time lines
Effective for all foreclosure sales completed on or after August 1, 2015
At the direction of the Federal Housing Finance Agency (FHFA) and in response to our periodic review, Freddie Mac and Fannie Mae are increasing the State foreclosure time lines in 34 of the 55 jurisdictions listed in Guide Exhibit 83.
Based on the data collected from foreclosure sales during the first half of 2015, we have determined that the State foreclosure time lines will remain unchanged in the following 16 jurisdictions: Alabama, Guam, Indiana, Iowa, Minnesota, Mississippi, Missouri, Montana, Nebraska, North Carolina, North Dakota, Ohio, South Carolina, Utah, Virgin Islands and Virginia. Servicers should review Exhibit 83 in its entirety for the revised requirements.
Extension of the temporary suspension of the assessment of compensatory fees
At the direction of FHFA, Freddie Mac and Fannie Mae are extending the temporary suspension of the assessment and billing of State foreclosure time line compensatory fees announced in Bulletin 2014-19 in the following jurisdictions:
- District of Columbia
- Massachusetts
- New York (including New York City)
- New Jersey
As a result of a review of foreclosure time line performance data from foreclosure sales occurring between January 1, 2015 and June 30, 2015 we have determined the temporary suspension will continue, at a minimum, for foreclosure sales occurring on or before December 31, 2015. At the completion of the State suspension, we will review and update our published State foreclosure time lines in the respective jurisdictions based on the data collected from foreclosure sales completed during the suspension period.
Please refer to the bulletin for additional announcements
About the Author
About the Author
Anna DeSimone is President and Founder of Bankers Advisory and Principal of CliftonLarsonAllen LLP. She can be reached at
Anna@bankersadvisory.com
Anna@bankersadvisory.com
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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