Ashley Halvorsen

Managing Associate

Los Angeles

ahalvorsen@orrick.com

Read full biography at www.orrick.com

Ashley Halvorsen is an associate in the Structured Finance group in the Los Angeles office.

Ashley represents issuers, underwriters, servicers, lenders, and other market participants in connection with securitizations, asset financings and sales, and negotiation of lending facilities. Ashley's practice encompasses a variety of asset-backed securities, including residential mortgage-backed securities and credit and charge card receivables.

Posts by: Ashley Halvorsen

CFPB Proposes Mortgage Servicing Changes to Prevent Wave of COVID-19 Foreclosures

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On April 5, the Consumer Financial Protection Bureau (CFPB) proposed rule changes intended to prevent avoidable foreclosures as emergency federal foreclosure protections put in place due to the global pandemic expire. The rules aim to assist both borrowers and servicers to navigate an expected surge of borrowers exiting forbearance. The proposed rules (1) provide a pre-foreclosure review period that generally prohibits servicers from starting foreclosure until after December 31, 2021; (2) permit servicers to offer certain streamlined loan modification options to borrowers with COVID-19-related hardships based on the evaluation of an incomplete application; and (3) update required servicer communications to keep borrowers informed of their options. Release.

FHFA Further Extends COVID-Related Loan Flexibilities

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On February 10, Fannie Mae and Freddie Mac will extend several loan origination flexibilities until March 31, 2021, including (1) alternative appraisals on purchase and rate term refinance loans; (2) alternative methods for documenting income and verifying employment before loan closing; and (3) expanding the use of power of attorney to assist with loan closings. These flexibilities aim to support borrowers impacted by the COVID-19 pandemic. Release.

FHFA Extends Foreclosure and REO Eviction Moratoriums and COVID Forbearance Period

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On February 9, The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac (the “Enterprises”) are extending moratoriums on single-family foreclosures for Enterprise-backed, single-family mortgages. Moratoriums on REO eviction for properties that have been acquired by an Enterprise through foreclosure or deed-in-lieu-of-foreclosure transactions are also extended. These moratoriums are extended until March 31, 2021. Further, borrowers with a mortgage backed by Fannie Mae or Freddie Mac may be eligible for an additional forbearance extension of up to three months, and COVID-19 Payment Deferral for borrowers with an Enterprise-backed mortgage can now cover up to 15 months of missed payments. Release.

Federal Reserve Board Announces the Second Extension of a Rule to Bolster the Effectiveness of the SBA’s PPP

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On February 9, The Federal Reserve Board announced the second extension to a temporary modification of the Board’s rules that allows certain bank directors and shareholders to apply to their banks for Small Business Administration Paycheck Protection Program (PPP) loans for their small businesses. The modification is intended to improve the effectiveness of the PPP. Prior to this modification, limits on the types and quantity of loans that bank directors, shareholders, officers and businesses owned by these persons can receive from their affiliated banks prevented some small business owners from accessing PPP loans. The rule extension is effective immediately and applies to PPP loans made through March 31, 2021. Release.

Federal Reserve Announces the Extension of its Temporary U.S. Dollar Liquidity Swap Lines and the Temporary Repurchase Agreement Facility

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On December 16, the Federal Reserve announced an extension through September 30, 2021, of its temporary U.S. dollar liquidity swap lines and the temporary repurchase agreement facility for foreign and international monetary authorities (FIMA repo facility). In March 2020, these facilities were temporarily established with the goal to ease strains in global dollar funding markets created by the COVID-19 pandemic and to support the supply of credit to households and businesses. These facilities were previously extended as of July 29, 2020. Release.

OCC Reports Decline in Mortgage Performance

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On December 16, the Office of the Comptroller of the Currency (OCC) reported that the performance of first-lien mortgages in the federal banking system declined during the third quarter of 2020, which accounts for 27% of all residential mortgage debt outstanding in the United States. The percentage of seriously delinquent mortgages was 5.8% in the third quarter of 2020, compared to 6.8% in the prior quarter and 1.5% a year ago. In the third quarter of 2020, servicers initiated 48.2% more foreclosures than in the previous quarter and completed 14,097 mortgage modifications. Release.

CFPB Issues Two Final Rules to Promote Access to Responsible, Affordable Mortgage Credit

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On December 10, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Final Rule, replaces current requirements for measuring a consumer’s ability to repay General QM loans based on the consumer’s debt-to-income ratio, and instead adopts a price-based approached. The second final rule creates a new category called “Seasoned QMs” for first-lien, fixed-rate covered transactions that have met certain performance requirements, are held in portfolio by the originating creditor or first purchaser for a 36-month period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. Release.

Temporary Policy Allowing Purchase of Qualified Loans in Forbearance is Extended

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On October 21, the Federal Housing Finance Agency (FHFA) extended a policy allowing certain single-family mortgages in forbearance to be delivered to Fannie Mae and Freddie Mac for borrowers who sought payment forbearance due to the impact of COVID-19 shortly after closing on their single-family loan. Normally, mortgage loans in either forbearance or delinquency are ineligible for delivery. The policy was extended for loans originated through November 30, 2020. Release.

Agencies Issue a Final Rule to Strengthen Resilience of Large Banks

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On October 20, the federal bank regulatory agencies finalized the net stable funding ratio rule, which requires large banks to maintain a minimum level of stable funding relative to each institution’s assets, derivatives, and commitments over a one-year period. The rule aims to strengthen the resilience of large banks and their ability to lend across economic conditions. Release.

Agencies Finalize Rule to Reduce the Impact of Large Bank Failures

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On October 20, the federal bank regulatory agencies finalized a rule to limit the impact of the failure of large banking organizations. The final rule requires a more stringent regulatory capital treatment for holdings of total loss-absorbing capacity (TLAC) debt, which is issued by U.S. global systemically important bank holding companies (GSIBs). This is intended to discourage large banking organizations from purchasing such debt and reduce the interconnectedness between large banking organizations. The final rule is effective on April 1, 2021. Release.