CARES Act- Mortgage Servicing

Pre-Googled w/ no results: "cares act" + "bankersonline" "foreclosure moratorium" + "bankersonline"

Howdy Kids,

I realize this is a little late, so spare me the public shaming. While we did implement and monitor changes from the CARES Act, we did not institute a formal policy. I'm working on doing that now I'm looking for your help/opinions.

Using the attached as a guide: https://www.federalreserve.gov/supe...t_Exam%20Procedures_07.06.2020_final.pdf

I see that the three main categories are credit reporting, mortgage servicing (single family) and mortgage servicing (multifamily)

Here is where I'm getting hungup. For the Temporary Foreclosure Moratorium- has that since expired? If so, what was the final expiration date? The best I can see is that enterprise loans expired on 6.30.21.

If any of you have adopted a similar policy and have some tips, I'd be happy to hear them. I don't want to steal your policy.

- Norm

https://www.ccul.org/click-here-list/5266-moratoriums-extended-debt-collections-rule-date-new-tool


Maybe this link will work.

As far as I am aware, all foreclosure moratoriums are now expired. FHA ran until 7/31/21 I believe. None of this ever applied to portfolio loans. Since I would hope that you had a formal policy for foreclosures pre-COVID - you might start there.

I thought the Supreme Court struck down that extension?

(Can't tell the players without a program - too many relief measures to keep track of!) No, the Supreme Court struck down the CDC's prohibition on evictions. FNMA, FHLMC, and FHA can do whatever they want with loans they own.

https://www.reuters.com/world/us/us...idential-eviction-moratorium-2021-08-27/

Correct Randy and rainman.

Thank you all. Randy, we have a moderately sized (and growing) FHLB portfolio that we service, so these fall under that bucket.

I am not sure which FHLB you are dealing with, but each of them has issued guidance - you might try them directly for some guidance. For example Indianapolis issued this and other bulletins on the subject: https://www.fhlbi.com/docs/default-...nal-bulletin-09-20.pdf?sfvrsn=3a0e091e_2