The only rule explicitly stated by the GSEs is “forbearance does not mean payments are forgiven.” Meanwhile, the FHFA and CFPB have joined hands to protect consumers from fraudulent forbearance activities.
In an effort to support the industry during the COVID-19 pandemic, mandated use of the redesigned Uniform Residential Loan Application is now scheduled for March 1, 2021.
Some credit-risk transfer deals explicitly exempt forbearance losses due to natural disasters. Freddie Mac clarified that it considers the coronavirus a natural disaster. Fannie Mae has yet to provide guidance.
Economists at Fannie and Freddie are “relatively optimistic” about mortgage originations in 2020, despite the economic impact of COVID-19. But not if social distancing remains in place beyond May.
Regulators have acknowledged that the lack of legal clarity and the speedy implementation of the new forbearance requirements may set the stage for exploitation by unscrupulous or ill-informed servicers.
Of course, early this spring, the FHFA, in trying to aid consumers economically impacted by the pandemic, requested that servicers provide forbearance.