A&B Abstract: On December 20, 2023, the Department of Veterans Affairs (VA) issued Circular 26-23-27 (the “Circular”) to remind holders and servicers of VA-guaranteed loans about their obligation to process assumptions and how the VA will address non-compliance with its assumption requirements. The Circular became effective immediately upon issuance. The Circular Holders and servicers of […]
Mortgage Loans
Complying with the “Consider” Requirement Under the Revised Qualified Mortgage Rules
A&B Abstract: Purchasers of residential mortgage loans who are conducting audits of residential mortgages that they buy in the secondary market are struggling to determine what documentation satisfies the “consider” requirement of the revised qualified mortgage (QM) standards that became mandatory on October 1, 2022. In fact, originators of residential mortgage loans are not in […]
Correspondent Lending on the Rise: Increasing Gains Point to Increasing Risk
A&B Abstract: According to a recent edition of Inside Mortgage Finance, correspondent lending is the only lending channel that posted gains in Q3 2023. While it is always nice to see gains, it should also serve as a reminder to take a fresh look at your risk management program to ensure it is calibrated to […]
FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk Identification, Assessment, and Response (“Analytic Framework”); and (2) the updated Guidance for Nonbank Financial Company Determinations (“Nonbank Designations Guidance”). The Analytic Framework was published today in […]
HUD Seeks Comment on Proposed Notice to Change HECM for Purchase Program to Expand Funding Sources and Interested Party Contributions
A&B Abstract: On October 24, 2023, the U.S. Department of Housing and Urban Development (“HUD”) published, for public comment, a Federal Register Notice (“Proposed Notice”) to implement changes to the Federal housing Administration’s (“FHA”) Home Equity Conversion Mortgage (“HECM”) for Purchase program. The Proposed Notice expands the list of acceptable funding sources and permits additional […]