Freddie Mac Requires Lender-Placed Insurance Compliance Certification, Updates Foreclosure And Transfer Tax Policies


On March 17, Freddie Mac issued Bulletin 2014-3, which requires servicers to provide a certification that they are or will be in compliance with new lender-placed insurance requirements announced in Bulletin 2013-27. With regard to alternatives to foreclosure, Bulletin 2014-3 (i) makes optional requirements announced in Bulletin 2013-27 related to the processing of modifications for mortgages with pre-modification mark-to-market loan-to-value ratios less than 80%; (ii) requires servicers to provide notices on behalf of Freddie Mac in certain circumstances when Freddie Mac participated in evaluating a borrower for a workout or relief option and declined to approve the workout or relief request; (iii) reorganizes property valuation requirements for modifications; and (iv) provides additional guidance related to paystub requirements for income documentation submitted with a Borrower Response Package. Finally, Freddie Mac also (i) updated requirements for the reimbursement of transfer taxes; (ii) permitted servicers to instruct foreclosure counsel to conduct a foreclosure in Freddie Mac’s name, without obtaining prior written approval, if doing so would avoid any obligation to pay a transfer tax; and (iii) provided guidance on numerous additional servicing issues.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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