crfs provides updates to pandemic-related forbearance and foreclosure guidelines

HUD ML 2020-13

Extends the foreclosure and eviction moratorium through 6/30/2020. Vacant and abandoned properties are now excluded from the moratorium.

  • The COVID-19 Forbearance must be reported as 06 – Formal Forbearance
    • If a different code was previously reported, mortgagees should stop immediately and begin reporting code 06
  • Default Reason code 055 – Related to National Emergency Declaration is available May 1st and must be used no later than the July 2020 reporting cycle


HUD ML 2020-14

Extends the exception to allow exterior only appraisals for origination and servicing through 6/30/2020


FHLMC Bulletin 2020-15 and FNMA LL 2020-07

  • Introduces the COVID-19 Payment Deferral Option. This provides expanded eligibility then the previous Payment Deferral Option announced in March
  • The loan must be current or less than 31 days delinquent as of 3/1/2020 and no more than 12 months past due as of the date of evaluation
  • This can begin July 1, 2020
  • Up to 12 months of payments can be deferred into a non interest bearing balance that becomes due at maturity, property transfer or refinance
  • FHA, VA and RHS loans are ineligible
  • A claim can be filed for expenses such as recordation fees, title costs and notary fees
  • Incentive fee information will be provided at a later date


FHLMC Bulletin 2020-16 and FNMA LL 2020-02

  • Extends the foreclosure moratorium through 6/30/2020 excluding vacant or abandoned properties
  • Servicers must not complete property inspections when the borrower is experiencing a hardship related to COVID 19 or during the forbearance unless the loan was already delinquent or vacant and abandoned