FHA Mortgagee Letters Overview: Cyber Incident Reporting, Nonjudicial Foreclosure Process, and DE Underwriter Policy Updates – Legislative Update by Alice Alvey

FHA Mortgagee Letters Overview: Cyber Incident Reporting, Nonjudicial Foreclosure Process, and DE Underwriter Policy Updates – Legislative Update by Alice Alvey

[Alice] Thanks, Dave. And hello, everyone. Today, I'm going to give you a heads up about FHA's drafting table that now has three mortgagee letters on it for you to review. The first one we have talked about. This is related to the cyber incident reporting requirements that you have until this Wednesday, October 30th, to comment about. In this mortgagee letter, it's a very straightforward change that's highlighted in yellow to allow a full 36 hours now for a cyber incident report. Please also, for those of you especially who do this for your companies, check out the definition of a reportable incident and make sure that's something you're comfortable you can write policy around. So again, that is for FHA cyber incident reporting requirements. Comments are due by Wednesday. So for those of you out at the MBA conference, you have to step out on the side and get your comments posted. Then go back in your meeting. All right. Now the second one two that FHA just posted last week. The first one is the nonjudicial foreclosure process for mortgages with secretary held liens. My brain I read this so fast. I went secondary held liens. No, wait a minute. No, it's secretary held liens. These are loans that are held by the department of housing and urban development that are a second lien, but they're not. Nonetheless, it's a secretary held lien. See, I'm even having trouble saying it here. But for all of you here, please, who are in servicing, please check this out. It has quite a bit of information and procedural items that have been added regarding non foreclosure processes when this type of secretary held lien exists. process. So please check that out make sure that it meets with processes you're comfortable with and you can follow. And if not, there's a feedback response worksheet that you fill in to tell, make any recommendations to HUD on text changes that you would recommend. So it's a different process from actually a feedback. full on comment, like you might see when something's posted in the federal register, but it's still an opportunity to provide feedback. The third one is the DE underwriter changes that FHA is proposing. This is very straightforward. They are simply going to remove the requirement that a DE underwriter needs to be full time. This is terrific. that they can now potentially be a part time underwriter. They still have to be employed just by you. They are not opening up to have a contract DE underwriter, which I'm actually in agreement with because I do believe that it's important that an underwriter understand that company's way of working with FHA's guidelines as to how that company wants to manage its risk and of course have accountability very directly in a single line to FHA through the company that is always very important. So as a DE underwriter, you are still dedicated to one company, but you would be able to work part time. So this is more of a mortgagee letter that removes wording from the current 4000. So check those out. The last two that I told you, you have up until November 25th to respond with your feedback. Please make sure to take the opportunity to let your voices heard. Have a terrific day. Thank you.
Alice Alvey - Union Home Mortgage Alice Alvey, Master CMB Vice President Partner Education and Training at Union Home Mortgage 8241 Dow Circle Strongsville, OH 44136 D: 440.420.4294 C: 248.941.1939 She handles development of their World Class Training program designed to support UHM partners and organizational effectiveness. Prior to UHM, Alice served as Senior Vice President at Indecomm leading the Indecomm-Mortgage U division, Internal QA and Compliance and SaaS technologies. Indecomm acquired Mortgage U in 2013, where Alice was President/Co-founder, providing training and consulting since 1996. Prior to MU she served as SVP of Operations at a national bank overseeing operations for wholesale, retail and correspondent from underwriting through servicing, and compliance. She has been in the trenches of mortgage lending operations from application through servicing for over 30 years. Her authoring work in training content, policies and procedures and the FHA/VA Practical guides illustrates her ability to bridge regulatory requirements with day-to-day operations. Alice has been a weekly contributor to the Lykken on Lending show since its beginning in April 2009 and has made her weekly contributions to 450+ episodes!