In response to the communique issued by CMHC on August 12 regarding several accommodations to liquidation rules for pooled loans, TAO Solutions is pleased to announce updates to the MortgageHub application to assist NHA MBS issuers with supporting these new requirements.
Enhancements to the MortgageHub application to satisfy CMHC’s requirement to maintain two separate amortization schedules in the event of default management arrangements will include the following:
- Addition of a new flag at the loan level which will denote that loan is in a default management arrangement.
- Addition of above loan flag to the Loan Dynamic Upload, allowing issuers to update any loan without requiring updates to existing servicing system feeds or individually manually updating loans.
- Modifications to the remittance processing to ignore updates to the payment amount, payment frequency and amortization for the purposes of maintaining a perfect world amortization schedule in the pooled loan records. The amortization schedule on the loan records viewable in the Mortgage Viewer screen will continue to be updated by servicing system feeds and will reflect the real world amortization schedule. In effect, this will allow issuers to provide the two separate amortization schedules as mandated.
- A new user-configurable setting on the Pool Types screen to turn on and off the above behaviour on a pool type by pool type basis, in the event that CMHC rolls back this requirement.
- Addition of above loan flag to the Loan Dynamic Upload, allowing issuers to update any loan without requiring updates to existing servicing system feeds or individually manually updating loans. If issuers wish to make changes to their existing custom interface feeds for this flag for a more integrated solution, please coordinate with your account manager.
Additionally, the policy exception surrounding 800-series NHA MBS pool liquidations will also be accommodated as follows:
- A new user-configurable setting on the Pool Types screen to configure whether MortgageHub should be auto-liquidating loans after 90+ days in arrears. To satisfy this new CMHC requirement, users should turn this setting to No.
- Modifications to NHA MBS pool compliance to ignore the arrears status of deferred loans to allow them to be pooled as the loans are paying as agreed.
The above updates are being provided as part of the MortgageHub 2020R3 general release update, available on September 18, 2020.
If you have any questions or concerns, please contact your designated account manager(s).