Mortgagee Duties Under NFIP and HPA Policy Manual
The CFPB, empowered by Dodd-Frank and the Consumer Financial Protection Act, mandates lender compliance with all consumer protection laws, including the Homeowner's Protection Act, which addresses automatic termination of private mortgage insurance and borrowers' rights to request cancellation. The Federal Emergency Management Association (FEMA) sets mortgagee requirements for flood insurance under the National Flood Insurance Protection Act and subsequent amendments, which regulate allowable fees and proper notification to consumers.
All lenders must establish and monitor compliance with property and risk insurance requirements. Do you have your policies in place? Look no further than AllRegs' Mortgagee Duties Under NFIP and HPA Policy Manual. This policy is designed to aid mortgage lenders and servicers with proper implementation of flood insurance requirements, private mortgage insurance termination, and other insurance requirements mandated through regulatory action, including force-placed (lender-placed) insurance and the prohibition of credit insurance. This document reviews the federal regulations calling for implementation, reviews notification requirements, and addresses penalties for noncompliance.
The following agencies and organizations require the implementation of this policy:
- Fannie Mae
- Freddie Mac
The plan features the following benefits:
- Complete Mortgagee Duties Under NFIP and HPA Policy Manual, saving you development time and resources
- The policy is delivered via email within one business day after purchase
- Meet your regulatory or internal compliance requirements
- Affordable one-time purchase fees
Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.
Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.
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|1.1||Goals and Objectives||Mandatory Review||Include the point of view or culture of your organization in this section, if applicable.|
|1.2||Required Review||Mandatory Review||Be sure this accurately reflects your company’s annual policy review process.|
|1.4||Roles and Responsibilities||Optional Enhancement||You may further refine the duties and responsibilities for the functional roles managing flood and PMI monitoring|
|2.1||Internal Controls||Mandatory Review||Include or reference related procedures in this section.|
|3||Staff and Training||Mandatory Review||Include the means by which your organization provides and tracks required training.|
|4.5||Sample Notice of Special Flood Hazards||Optional Enhancement||This section includes sample content. If your organization uses a customized notice, insert or reference it here.|
|4.7||Agency Requirements||Recommended Best Practice||This section includes the requirements of Fannie Mae, Freddie Mac, FHA, VA, Rural Housing Service, and the Federal Home Loan Bank. You may choose to customize this section with the requirements for only those agencies with which you do business.|
|5.2||Borrower Requested Cancellation||Recommended Best Practice||Changes are required by September 1, 2019, but may be implemented before then. Determine if your organization has implemented these changes.|
|6.1||Force-Placed Insurance||Mandatory Review||This section references several types of required notices and provides minimum content. Review and update this by inserting or referring to the actual notices you have in place.|