crfs releases summary on recent Fannie Mae Servicing Guide, LoanSphere Invoicing, and Servicer Expense Reimbursement Job Aid updates

In April 2019, Fannie Mae updated its Servicing Guide, LoanSphere Invoicing, and the Servicer Expense Reimbursement Job Aid.  SVC-2019-02 provides the updated Servicing Guide Topics and a brief description of the updates.  The LoanSphere Invoicing 19.3 Release Notification provides the updates to LoanSphere Invoicing.  CRFS has conducted a thorough review of all of the updates made.  A majority of the updates do not represent a change to CRFS procedures.

Below are topics we have identified that require changes to CRFS procedures, as well as topics of note that clarify Fannie Mae requirements.

Procedure Updates:

We have identified that the following require changes to CRFS procedures:

1.  Allowable Foreclosure Attorney Fees Matrix update

The maximum allowable attorney fee limit increased for the following states, effective for loans in active FC on or after April 10, 2019.

  • New Hampshire
    • Non-Judicial FC allowable increased from $1,450.00 -> $1,725.00
  • Maine
    • Judicial FC allowable increased from $2,750.00 -> $3,950.00
    • An additional $200 allowable fee for processing a third-party foreclosure sale added
  • Washington
    • New allowable Judicial FC allowable of $3,050.00 for e-Note foreclosure actions; these do not need prior approval from FNMA. All other FC actions need prior approval

2.  New Vacant Property Registration Admin Fee

Fannie Mae added the Vacant Property Registration Admin Fee to LoanSphere to claim municipality admin fees related to listing a property on a database of local vacant properties. This line item is available as of April 10, 2019.

3.  New fields on line items

New fields were added to LoanSphere on April 7, 2019:

  • Paid Date field – Added on all line items, and is an optional field. Effective June 15, 2019, this field is required for Tax Expenses and Insurance Expenses
  • Tax Paid Amount field – Added on all Tax Expenses, and is an optional field
  • Tax Parcel field – Added on all Tax Expenses, and is an optional field

4.  Pending Submitter Review (PSR) Status

Effective May 1, 2019, Claims remaining in PSR status for 60 days, which are not locked and do not have a Pending Validation or a Failed to Validate tag, will be auto-denied.

  • All line items set to pay on the claim will be changed to zero
  • The denial comment and reason will be “Denied – Failure to respond within Fannie Mae guide timelines

Clarified Items:

1.  Foreclosure Sale Date Clarifications

Multiple Guide Topics were updated to clarify that:

In applicable jurisdictions, when a foreclosure is completed by court order without a foreclosure sale (such as a foreclosure-by-consent or a strict foreclosure), the date of the court’s order is entered on the docket, or the estimated court order docket date when applicable, must be used in place of the foreclosure sale date.

This may be implemented immediately, but must be implemented by July 1, 2019.