[wburd]

Fannie Mae is imposing an Adverse Market Fee of .50 beginning with loans purchased by Fannie Mae on 9/1/20. Since this would be an origination fee it is our view that this is not a fee that can be added once the original LE was issued regardless of whether the loan is locked or not. We also conclude that a rate lock (which requires a Loan estimate reissue) is not a change in circumstance that would allow the addition of an origination fee not present in the original LE. Bottom line is that for the loans that we have already issued an initial LE, WE(bank) will need to absorb the Adverse Market Fee imposed by Fannie Mae? Or is this actually a valid change?

[rcooper]

Yes, I tend to agree. Although differnt, a similar question that recently posted: https://mycomplianceresource.com/forums/topic/changed-circumstance-2/.

[rcooper]

FHFA issued a news release moving the adverse market refinance fee implementation date to December 1 rather than September 1.

“The Federal Housing Finance Agency (FHFA) today directed Fannie Mae and Freddie Mac (the Enterprises) to delay the implementation date of their Adverse Market Refinance Fee until December 1, 2020. The fee was previously scheduled to take effect September 1, 2020.”
https://www.fhfa.gov//Media/PublicAffairs/Pages/Adverse-Market-Refinance-Fee-Implementation-Now-December-1.aspx

[Author]

Posts