Compliance News Alert: Nebraska Net Tangible Benefits Disclosure
Feb 17, 2021
Today, FNMA announced new Automated Underwriting System (“AUS”) messages impacting both the legacy and redesigned Uniform Residential Loan Application (“URLA”), essentially stating that loans started in the legacy format prior to March 1, but not submitted by then, will not receive an “Out of Scope” message (or “critical edit” message, for FHLMC) on new loans submitted using the legacy format in AUS until May 1, 2021 (see https://singlefamily.fanniemae.com/news-events/uniform-residential-loan-application-march-1-mandate).
Interestingly, FNMA also announced the following regarding the March 1st mandate to use the new URLA:
“The mandate for implementing the redesigned URLA is March 1, 2021. The GSEs fully expect that new loan applications started on or after March 1 will be submitted using the redesigned form and DU MISMO v.3.4/LPA v.5.0.06 file formats.
The GSEs have not described how a lender should determine the ‘loan application start date.’ However, the expectation is that the lender will apply its chosen definition consistently.”
This suggests that the “loan application start date” is subjective to each lender, rather than based on a universally accepted, objective method (e.g., when the creditor has received an application in accordance with 12 C.F.R. § 1026.19[e] through [g]).
We would like to remind clients that the legacy URLA (Cx4193) and redesigned URLA (Cx20667) are configured to print (or not print, in the case of Cx4193) using field “Print Redesigned 1003 Loan Application” (FI 123494), which is set based on information sent by clients (a mapping, or data imported from an LOS, etc.). Further details about our support for the redesigned URLA can be found at our URLA Resource Center.
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.