On May 31, Ginnie Mae published its APM 24-09: Updates To Digital Collateral Program Guide to clarify, update, remove and expand policies on digital products, such as notes, closing systems, vaults, applicants and registries....more
What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more
On May 20, Ginnie Mae released “APM 24-08: Mandatory Recovery Planning Requirements for Certain Issuers,” which outlined Ginnie Mae’s introduction of recovery planning requirements for issuers whose portfolios exceed $50...more
On May 20, Ginnie Mae released an All Participant Memorandum (APM) titled “APM 24-07: Commingling Digital Collateral with Paper Collateral in Ginnie Mae Pools,” which included opening Ginnie Mae’s Digital Collateral Program...more
What Happened? On March 4, 2024, Ginnie Mae issued All Participant Memorandum (APM) 24-02 to impose a new cybersecurity incident notification requirement. Ginnie Mae has also amended its Mortgage-Backed Securities Guide to...more
On January 16, Ginnie Mae announced its plans to consider the development of a new securitization product in connection with broader efforts to expand its existing Home Equity Conversion Mortgage (HECM) mortgage-backed...more
The new Ginnie Mae issuer financial requirements, first published on August 17, 2022 in APM 22-09 by joint announcement with the Federal Housing Finance Agency, are scheduled to take effect in two parts beginning September...more
Ginnie Mae advises in the report that in early 2016 it and investors in Ginnie Mae guaranteed MBS “first began to identify a wave of early loan repayments and serial refinancing as a problem with much greater incidence in VA...more
Yesterday, Ginnie Mae clarified in an industry forum that its APM 21-06 seasoning requirements for the VA IRRRL Refinance of a Modified Loan are measured from the contracted first payment due date under a modification...more
Ginnie Mae clarifies its MBS Guide with respect to seasoning of VA IRRRLs that are a “Refinance of a Modified Loan.” Issuers had challenged Ginnie Mae’s buy out demands that claimed insufficient seasoning when measured from...more
Issuers should be aware that Ginnie Mae interpreting its MBS guide in a manner that departs from VA circular 26-19-22, and the plain reading of statutory language with respect to the beginning and ending dates used to...more
Legislation requires rent payment plans, mortgage relief, and foreclosure and eviction moratoriums. Residential and many commercial landlords may not increase rent and must make rent payment plans available to eligible...more
Ginnie Mae’s newly imposed restriction on repooling of reperforming forborne loans yet again penalizes servicers acting as essential service providers in the continuing efforts to protect mortgagors facing financial hardship...more
On June 17, 2020, Governor Andrew Cuomo signed S8428/A10530 and S8243-C/A10351-B into law. Collectively, in relevant part, the legislation creates N.Y. Banking Law § 9-x, which relates to residential forbearances as a result...more
Many of you have read about the power of the president to invoke the Defense Production Act to acquire products or direct the activities of suppliers based on a finding that it is necessary for the federal government to...more
Our Finance Group explains how Ginnie Mae will be implementing the Pass-Through Assistance Program during the coronavirus pandemic. Considerations for third-party lenders - Who is eligible? How often can you request...more
In an All Participants Memo dated April 10, 2020 (APM 20-03), Ginnie Mae announced that it revised and expanded its issuer assistance programs in Chapter 34 of the Mortgage Backed Securities Guide (MBS Guide) to include a...more
The economic impact of the COVID-19 pandemic has proven substantial, especially for the mortgage finance industry. Leaders across the state and federal level have implemented foreclosure moratorium policies to alleviate the...more
Federal Reserve Revises Framework for Determining Control of a Banking Organization The Federal Reserve has adopted a final rule to simplify and clarify its regulations for determining control of a banking organization for...more
The U.S. House of Representatives recently passed H.R. 6737 to amend the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) to address a technical issue that prevented mortgage lenders from including...more
As covered earlier this week in a legal alert, the U.S. Department of the Treasury issued a report recommending sweeping regulatory changes for consumer financial services. Within the report, the Treasury also recommended a...more
In addition to the guidance regarding Hurricane Harvey disaster relief, the housing agencies and government-sponsored enterprises (GSEs) recently addressed the mortgage-related relief available to victims of both Hurricane...more
S.E.C. v. Radius Capital Corp., No. 15-12004, 2016 WL 3542235, ___ F. App’x ___ (11th Cir. June 29, 2016). The Eleventh Circuit last month explained the material similarities and differences between two kinds of...more
The depth and impact of the 2007-08 financial crisis, rooted in residential finance, have been apparent for some time. There has never been doubt that its aftermath would transform the way mortgage lending operates in the...more
Ginnie Mae recently issued All Participant Memorandum 2014-01, which clarifies its position on electronic signatures and documents. In response to the Federal Housing Administration's recent announcement (Mortgagee Letter...more