COVID-19

Adverse Market Refinance Fee Implementation Now December 1

 

Fannie Mae and Freddie Mac have postponed the implementation date of their Adverse Market Refinance Fee from September 1 to December 1, per direction from the Federal Housing Finance Agency (FHFA). Certain Fannie Mae and Freddie Mac loans will also be exempt from the Adverse Market Refinance Fee. The fee is intended to cover costs to Fannie Mae and Freddie Mac associated with protections extended to renters and borrowers affected by COVID-19. Release.

Rating Agency Developments (August 24 – September 1)

 

On September 1, KBRA published its Structured Finance: CMBS report titled Coronavirus (COVID-19): Affiliate of On-Demand Office Provider Regus Files for Bankruptcy—CMBS Exposure Examined. Report.

On September 1, DBRS Morningstar published its methodology titled DBRS Morningstar Global Structured Finance Related Methodologies. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Servicer Rankings. Methodology.

On August 28, DBRS Morningstar published its methodology titled U.S. Residential Mortgage Originator Rankings. Methodology.

On August 28, KBRA published its report titled CMBS/RMBS: Single-Borrower SFR Comprehensive Surveillance. Report.

On August 27, KBRA published its rating methodology titled ABS: Global Auto Loan ABS Rating. Methodology.

On August 24, KBRA published its research report titled Structured Credit: Coronavirus (COVID-19): U.S. BSL CLO Sector Exposure Map: July 2020. Report.

CFPB Issues Report on Impacts of COVID-19 on Consumer Credit

 

On August 31, the Consumer Financial Protection Bureau (CFPB) issued a report examining the early impact of the COVID-19 pandemic on consumer credit. The report noted no significant negative impact on consumer credit or delinquencies, focusing on mortgage, auto loans, credit cards and student loans, from March 2020 to June 2020, suggesting programs such as the CARES Act may have positively impacted consumer credit during this time. Report.

FHFA Extends COVID-19 Related Loan Origination Flexibilities Through August 31

 

On July 9, the Federal Housing Finance Agency (FHFA) announced that several loan origination flexibilities originally set to expire on July 31 will be extended through August 31. These flexibilities include alternative appraisals on purchase and rate term refinance loans; alternative methods for documenting income and verifying employment before loan closing; and expanding the use of power of attorney and remote online notarizations to assist with loan closings. These loan origination flexibilities are intended to ensure borrowers receive continued support during the COVID-19 pandemic. Release.

Federal Housing Administration Makes New Loan Modification Options Available for Homeowners

 

On July 8, the Federal Housing Administration (FHA) announced an expanded array of loss-mitigation tools available to mortgage servicers. These measures require servicers to assess homeowners for multiple loan-modification options before the end of their forbearance period. These new measures are intended to assist homeowners financially impacted by the COVID-19 pandemic. Release.

CFPB Issues Interim Final Rule on Loss Mitigation Options for Homeowners Impacted by COVID-19

 

On June 23, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule that amends Regulation X by temporarily permitting mortgage servicers to offer certain loss mitigation options to borrowers impacted by the COVID-19 pandemic without first obtaining a completed loss mitigation application from the borrower. Release. Interim Final Rule.

Federal Reserve Board Announces Expansion in the Number and Type of Entities Eligible to Directly Use Its Municipal Liquidity Facility

 

On June 3, the Federal Reserve Board announced an expansion in the number and type of entities eligible to directly use its Municipal Liquidity Facility (MLF). Under the new terms, all U.S. states will be able to have at least two cities or counties eligible to directly issue notes to the MLF, regardless of population. Governors of each state will also be able to designate two issuers in their jurisdictions whose revenues are generally derived from operating government activities to be eligible to directly use the facility. Release.

CFTC: Interim Final Rule – Uncleared Swaps Margin – Proposed Rule: CPO Registration Exemption

 

On May 28, the Commodity Futures Trading Commission (CFTC) approved an interim rule to grant an extension of the compliance schedule for initial margin requirements for uncleared swaps in response to operational challenges certain entities are facing due to the COVID-19 pandemic. The CFTC also approved a proposed rule that amends regulation 3.10(c)(3), which provides an exemption from registration as a CPO for certain persons located outside the U.S. who are operating offshore commodity pools that are neither offered nor sold to U.S. participants. Release.

FHFA Extends Loan Processing Flexibilities for Fannie Mae and Freddie Mac Customers

 

On May 5, the Federal Housing Finance Agency (“FHFA”) extended loan origination flexibilities offered by Fannie Mae and Freddie Mac until at least June 30th. The extended flexibilities aim to help borrowers during the COVID-19 pandemic by facilitating loan closings and include: (1) alternative appraisals on purchase and rate term refinance loans; (2) alternative methods for verifying employment; and (3) expanding the use of power of attorney and remote online notarizations. Release.

Rating Agency Developments

 

On April 3, Moody’s published its Operating Company Securitizations. Methodology.

On April 3, KBRA published a report titled CMBS: Coronavirus (COVID-19): Multifamily Update – Bracing for Forbearance. Report.

On April 2, KBRA published a report titled Structured Credit: Coronavirus (COVID-19): KBRA U.S. BSL CLO Rating Sensitivity Analysis. Report.

On April 1, DBRS Morningstar published its U.S. Residential Mortgage-Backed Securities Model and Ratings. Methodology.

On March 31, DBRS Morningstar published its U.S. ABS General Ratings. Methodology.