Compliance News Alert: Nebraska Net Tangible Benefits Disclosure
Feb 4, 2021
Freddie Mac has made the following announcements in Bulletin 2021-4:
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- They “will not purchase any CMT-indexed ARM that has an Application Received Date of July 1, 2021 or later. In addition, [they] will no longer purchase CMT-indexed ARMs on and after October 1, 2021, regardless of the Application Received Date or Note Date.”
Fannie Mae made a similar announcement yesterday (see FNMA LL-2021-05). We are currently reviewing our document library and system to determine what changes need to be made, due to these announcements.
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- They will be “updating all references to Internal Revenue Service (IRS) Form 4506-T to reflect the IRS’s revised requirement for IRS Form 4506-C. IRS Form 4506-C must be used effective March 1, 2021 by authorized Income Verification Express Service participants in order to obtain tax transcripts with the taxpayer’s consent.”
Freddie Mac’s requirements prior to this change did provide enough flexibility that Form 4506-C could be used compliantly (unlike FHA and USDA, whose requirements are in need of amending). Nevertheless, this is a welcomed change.
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- They have incorporated the same authorized change for the uniform Oklahoma Mortgage (Form 3037) as Fannie Mae did last week. Yesterday, we announced the incorporation of this and other similar changes to most of our generic Oklahoma mortgages and to the Oklahoma-version of our generic HELOC Agreement.
TW 319501, 330281, 331321
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.