Brought to You By - considerchapter13.org · 2 The CARES Act and Mortgage Forbearance On March 27,...

9/3/2020

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Brought to You By

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9/3/2020

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The CARES Act

and

Mortgage

Forbearance

On March 27, 2020, President Trump signed into law H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”).

As an emergency act, the CARES Act takes immediate effect but expires on March 26, 2021.

A copy of the CARES Act, as enacted, may be found here.

The CARES Act and Mortgage Forbearance

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https://www.congress.gov/bill/116th-congress/house-bill/748

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Modification of a Chapter 13 Plan due to Coronavirus Related Financial Hardship:

Section 1329 of the Bankruptcy Code, which sets forth the requirements for modification of a chapter 13 plan after confirmation, is amended to include new section (d). This section provides that a plan may be modified at the request of the debtor, after notice and hearing, if the “debtor is experiencing or has experienced a material financial hardship due, directly or indirectly, to the coronavirus disease 2019 (COVID–19) pandemic.”


Any plan modified under this provision may be extended up to seven years from the date that the first payment under the original confirmed plan was due. Accordingly, this provision extends chapter 13 plans by up to two years beyond the previous five year limit allowed under the chapter 13.


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Any modification of the plan under this new section (d) shall be made subject to the requirements of Section 1322(a)-(c) and Section 1325, meaning that, except for the length of the plan, any modified plan must comply with the traditional requirements of a chapter 13 plan.



This new modification provision only applies to cases where plans were confirmed before enactment of the CARES Act on March 27, 2020.

This provision automatically expires one year after the date of enactment of the CARES Act.

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Finally, Section 4022 of the CARES Act provides relief from foreclosure as to “Federally Backed Mortgage Loans.”

These covered loans include Freddie and Fannie Mae owned loans, HUD Loans, Veteran Home Loans (VA), FHA, Rural Housing, USDA, and other federally guaranteed loans.


For any covered loan, upon the request of a borrower who attests that she or he is suffering financial hardship due to the COVID-19 Pandemic, and so long as the Federal National Emergency relating to the COVID-19 Pandemic is in place, the borrower is entitled to a 180 day forbearance period without providing further documentation.

During this time, no legal fees, late fees, costs, or additional interest can be charged to the loan.


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The CARES Act also appears to prohibit foreclosure on loans already in default so long as the borrower properly requests a forbearance. The borrower may request the forbearance even if the loan is in default.

This 180 day forbearance period may be extended one time for an additional 180 day period at the request of the borrower so long as the Federal Emergency is still in place (President could end the Emergency by Executive Order).


Because most borrowers do not know who the owner of their mortgage loan is, research may be required to determine if an individual borrower is eligible for the relief under this act.

If the servicer is unable to informally disclose whether the loan is a covered loan, a Request for Information under 1024.36 of Regulation X of RESPA may be necessary to determine the borrower’s eligibility for forbearance.

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FHFA Extends Foreclosure and REO Eviction Moratoriums

On August 27, 2020, the Federal Housing Finance Agency issued the following announcement:


Today, to help borrowers at risk of losing their home due to the coronavirus national emergency, the Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac (the Enterprises) will extend the moratoriums on single-family foreclosures and real estate owned (REO) evictions until at least December 31, 2020.

The foreclosure moratorium applies to Enterprise-backed, single-family mortgages only.

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The REO eviction moratorium applies to properties that have been acquired by an Enterprise through foreclosure or deed-in-lieu of foreclosure transactions.

The current moratoriums were set to expire on August 31, 2020.


“To help keep borrowers in their homes during the pandemic, FHFA is extending the Enterprises' foreclosure and eviction moratoriums through the end of 2020," said Director Mark Calabria. “This protects more than 28 million homeowners with an Enterprise-backed mortgage."

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Currently, FHFA projects additional expenses of $1.1 to 1.7 billion will be borne by the Enterprises due to the existing COVID-19 foreclosure moratorium and its extension.

FHFA will continue to monitor the effect of coronavirus on the mortgage industry and update its policies as needed.


To understand the protections and assistance offered by the government to those having trouble paying their mortgage, please visit the joint Department of Housing and Urban Development, FHFA, and the Consumer Financial Protection Bureau website at cfpb.gov/housing.

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CARES Act Section 4022


(b) FORBEARANCE.—(1) IN GENERAL.—During the covered period, a borrower with a Federally

backed mortgage loan experiencing a financial hardship due, directly or indirectly, to the COVID–19 emergency may request forbearance on the Federally backed mortgage loan, regardless of delinquency status,

(A) submitting a request to the borrower’s servicer; and (B) affirming that the borrower is experiencing a financial hardship

during the COVID–19 emergency.


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(2) DURATION OF FORBEARANCE.—Upon a request by a borrower for forbearance under paragraph (1), such forbearance shall be granted for up to 180 days, and shall be extended for an additional period of up to 180 days at the request of the borrower, provided that, at the borrower’s request, either the initial or extended period of forbearance may be shortened.

(3) ACCRUAL OF INTEREST OR FEES.—During a period of forbearance described in this subsection, no fees, penalties, or interest beyond the amounts scheduled or calculated as if the borrower made all contractual payments on time and in full under the terms of the mortgage contract, shall accrue on the borrower’s account.


(c) REQUIREMENTS FOR SERVICERS.—(1) IN GENERAL.—Upon receiving a request for forbearance from a

borrower under subsection (b), the servicer shall with no additional documentation required other than the borrower’s attestation to a financial hardship caused by the COVID–19 emergency and with no fees, penalties, or interest (beyond the amounts scheduled or calculated as if the borrower made all contractual payments on time and in full under the terms of the mortgage contract) charged to the borrower in connection with the forbearance, provide the forbearance for up to 180 days, which may be extended for an additional period of up to 180 days at the request of the borrower, provided that, the borrower’s request for an extension is made during the covered period, and, at the borrower’s request, either the initial or extended period of forbearance may be shortened.


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Section 4021 Credit Protection During COVID-19 – Amends 15 USC 1681S-2(a)(1) of the Fair Credit Reporting Act as follows:

‘‘(ii) REPORTING.—Except as provided in clause (iii), if a furnisher makes an accommodation with respect to 1 or more payments on a credit obligation or account of a consumer, and the consumer makes the payments or is not required to make 1 or more payments pursuant to the accommodation, the furnisher shall—


‘‘(I) report the credit obligation or account as current; or‘‘(II) if the credit obligation or account was delinquent before the

accommodation—‘‘(aa) maintain the delinquent status during the period in

which the accommodation is in effect; and‘‘(bb) if the consumer brings the credit obligation or account

current during the period described in item (aa), report the credit obligation or account as current.

‘‘(iii) EXCEPTION.—Clause (ii) shall not apply with respect to a credit obligation or account of a consumer that has been charged-off.’’.


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COVID-19 Forbearance Script for Servicer Use with Homeowners



Step 1: Determine Nature of Hardship ▪ Let’s get started. ▪ Are you calling because of a problem you’re having with making your monthly

mortgage payments?

If the Homeowner answers “yes”: ▪ Tell me about your situation and how it is affecting your financial

circumstances.

➢ NOTE TO SERVICER: Ask appropriate questions to elicit details about the Homeowner’s situation.

▪ Is the financial hardship directly or indirectly related to the COVID-19 National Emergency?

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If the Homeowner answers “yes,” proceed to Step 2. o If the Homeowner has experienced a financial hardship directly or indirectly

related to the COVID-19 National Emergency (e.g., unemployment, reduction in regular work hours, or illness of a Homeowner/co-Homeowner or dependent family member), the Servicer should proceed to Step 2.

o If the Homeowner has a hardship that has impacted their ability to make their monthly mortgage payment, but the hardship is not directly or indirectly related to the COVID-19 National Emergency, the Servicer should proceed with normal loss mitigation scripting.

o If the Homeowner has no hardship, the Servicer should use customary exit language.


Step 2: Follow this script if the Homeowner has a financial hardship related directly or indirectly to the COVID-19 National Emergency. ▪ Thank you for sharing this information. I’m so sorry to hear about your

financial hardship. ▪ We have mortgage relief solutions to help homeowners facing a financial

hardship because of COVID-19.

➢ NOTE TO SERVICER: Check guidelines to confirm whether the homeowner is eligible for a forbearance program. o If the Homeowner is eligible, proceed to Step 3. o If the Homeowner is not eligible, servicer should proceed with normal loss

mitigation scripting.

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Step 3: Introducing Forbearance ▪ Special programs are available and designed for homeowners who are

experiencing a temporary income loss, or even longer-term financial hardships attributed to COVID-19.

▪ [Fannie Mae] —the investor in your loan—has a number of assistance programs to help you keep your home even when you are having difficulty making your monthly mortgage payment.

▪ Based on what you have told me about your current situation, you are eligible for a forbearance plan. Let me tell you about forbearance and please feel free to ask me any questions as we go along.


▪ Forbearance is when we allow you to temporarily reduce your mortgage payment or suspend or pause making your mortgage payment for a period of time.

▪ You will still be required to pay back the missed payments eventually, but there will be no additional fees or penalties added to your account during the forbearance period.

▪ Forbearance can help you deal with temporary financial hardships by reducing or suspending your mortgage payment for a short period of time, for example, pausing payments for a 3- or 6-month period while you regain your financial footing.

▪ Forbearance does not mean your payments are forgiven. You will still be required to pay back the missed payments eventually, but you won’t have to repay it all at once—after your forbearance ends unless you are able to do so.

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▪ Does the forbearance program seem like an option that could be helpful to you in your current situation?

If the Homeowner answers “yes”, proceed to Step 4.

If the Homeowner answers “no”, ask her/him to tell you any concerns or questions they have.


If the Homeowner asks you to explain the repayment options first: ▪ I will explain the programs for catching you up on your missed payments later. ▪ Programs for repayment may include: o repaying the missed payments at the

end of forbearance, o setting up a repayment plan that allows you to make up the missed

payments over a period of time, o moving your missed payments into a deferred balance fully due and

payable when you sell your home (called a payment deferral), o refinance and the missed payments be due at the end of the mortgage, or o setting up a modification that may modify your loan to reduce your

monthly mortgage payment and extends the term of your mortgage. ➢ NOTE TO SERVICER: Proceed with/switch to normal loss mitigation scripting if

a forbearance is not appropriate for the Homeowner.

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Step 4: Forbearance Program Details ➢ NOTE TO SERVICER: The Servicer should educate the Homeowner on the

impact of longer forbearances and allow the Homeowner to ask questions. Use the information about the Homeowner’s individual hardship to inform the appropriate length of the forbearance term. You might start at a middle ground, 3 months for example, and work up or down, depending upon the needs of the Homeowner and applicable law. A sample script for this is provided below:

▪ The Forbearance period—which is the period of time during which your mortgage payments are reduced or paused—can vary depending on the impact of your financial hardship. You may be able to get forbearance for up to 180 days (about 6 months). You could also to request an extension for another 180 days beyond that if your hardship continues.


▪ Remember, you will have to pay back the missed payments following forbearance, but you don’t need to pay it back all at once if you are not able to do so. The longer the forbearance period and the less you pay during the forbearance, the more money you’ll owe in missed or reduced mortgage payments.

➢ NOTE TO SERVICER: The objective is to come to agreement on a reasonable forbearance period depending on the needs of the Homeowner and applicable law.

▪ Based on your situation, are you able to make partial mortgage payments, or are you not able to make any payments at all during the forbearance period?

If the Homeowner says, “partial payments,” ask the Homeowner what they would be able to pay.

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If the Homeowner does not make a specific request, the Servicer may suggest: ▪ It sounds like [___three] months is a reasonable forbearance period based on

your financial hardship. ▪ We will stay in touch with you during the forbearance period and can extend it

if your hardship is continuing. ➢ NOTE TO SERVICER: Remind the Homeowner that missed or reduced payments

will have to be repaid following forbearance, even though they won’t have to be repaid all at once unless the Homeowner is able to do so. Remind the Homeowner that the forbearance period can be extended, if needed (i.e., if their hardship is not resolved) and it can also be shortened at their request.


Once the Homeowner agrees on the length of the forbearance period, confirm that agreement. Restate the agreed upon forbearance: ▪ To summarize, you have requested to:

o pause your mortgage payments for X months beginning [next/this] month, or

o reduce your monthly mortgage payment to $xxxx.xx for X months beginning [next/this] month.

▪ Is that correct? Or Does this work for you? If the Homeowner says “no”, go back a few steps to arrive at an acceptable payment and/or term of forbearance. ▪ We will send you a written agreement that summarizes the terms of your

forbearance plan.

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Step 5: What happens next? ▪ After this initial forbearance period of _____ months, we’ll reevaluate your

situation and, if you are still financially impacted by COVID-19, we can (may) extend your forbearance period, if needed.

▪ If your situation changes and you can resume making your monthly payments before the end of the forbearance period, let us know so that if you are able to shorten your forbearance period we can do that and reduce the amount that you will need to repay following forbearance. If you can make partial payments during the forbearance period, please do so, because it will reduce the amount you will need to repay following forbearance.


▪ It’s really important to understand that the amount of your payment that is either reduced or suspended will still need to be repaid—but not until after the forbearance -- and you will not have to pay it all at once if you are not able to do so.

▪ During the forbearance, we will not charge penalties or late fees for any reduced or suspended payment.

➢ NOTE TO SERVICER: The Servicer should check if the Homeowner pays taxes, insurance or HOA/condo fees directly instead of via escrow. If that is the case, remind the Homeowner to continue making these payments directly during the forbearance period.

▪ We will send you a written agreement that summarizes the terms of your forbearance plan.

▪ Do you have any questions?

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Step 6: Forbearance repayment ▪ Let’s talk about what happens at the end of the forbearance. ▪ At the end of your forbearance you will have to repay the amount of reduced

or paused payments, but you are not required to do so all at once if you are not able to do so.

▪ The repayment options at the end of the forbearance may include: o “reinstatement”, which means paying the total amount due, if you are able

to do so, or o we can set up a repayment plan, which will let you catch up gradually

while you are paying your regular monthly payment.


▪ If you cannot afford the increased monthly payments to catch up gradually through a repayment plan, but you can resume making your normal monthly payment, we can look at other ways of paying back the missed payments in an affordable manner.

▪ If you have a long-term reduction in income resulting from the crisis, then we can look at a “loan modification,” which actually changes some of the terms of your loan.

▪ That’s a brief summary of options that may be available after your forbearance ends.


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▪ In summary, here are the key points to remember about your forbearance plan: o You have requested and will be granted forbearance relief for X months

during which time you will make [no mortgage payments] or [a reduced mortgage payment of $XXXX.XX].

o [If applicable] You will continue making [Insurance] [property tax] [HOA or condo fees] payments directly yourself.

o We will send you a written agreement that summarizes the terms of your forbearance plan.

o You may shorten the forbearance period at any time, or you may request an additional forbearance period if needed for more time to resolve your financial hardship.


o We will reach out to you about 30 days before your forbearance plan is scheduled to end to determine next steps.

o At the end of your forbearance you will resume monthly mortgage payments and you will have to repay the amount of reduced or suspended payments – although not all at once if you are not able to do so.


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▪ While you’re in the forbearance period, there are a few things you can do to protect yourself: o Keep notes, paperwork and documentation on hand. This includes paying

attention to your monthly mortgage statements so you can ensure that your statement reflects the assistance provided.

o If you have your mortgage payment deducted automatically from your bank account, adjust or stop auto-payments for your mortgage.

o Keep an eye on your credit. It’s a good idea to routinely check your credit reports.

➢ NOTE TO SERVICER: Proceed with the process for finalizing the forbearance.

Notice of Temporary ForbearanceIn re Estes

Bankr. WD VirginiaCase No: 17-70327


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Notice of Mortgage Payment ChangeIn re RodriguezBankr. SD Texas

Case No: 20-10074



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Why should Debtor’s counsel be concerned if a Notice of Forbearance is filed in

your client’s case:

• Improper modification of confirmed chapter 13 plan

• May result in Trustee filing Motion to Modify Chapter 13 Plan

• May result in Trustee not paying mortgage in conduit case

• Confuses Debtors who actually can make payment about whether they should

do so

• May limit Debtor’s right to future forbearance if needed

• May impact Debtor trying to rebuild credit

• May impact Debtor’s ability to refinance in future

• May result in Motion for Relief


How Notices of Forbearance are typically filed in Chapter 13:

1) Via Notice on Docket

2) Rule 3002.1 Filing

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STEPS TO TAKE WHEN NOTICE OF FORBEARANCE FILED:

First, contact debtors and verify debtors did in fact ask for forbearance.

Review:A. Conduit or non-conduit planB. Current before forbearance or delinquentC. Trustee/Court position on post-filing arrearages/forbearanceD. Consider modifying plan and having trustee pay arrearage

Benefits & Detriments: o Provides clear records on how and when arrearage paido Resolves any Notice of Final Cure Issues in advanceo May require extension of plan to cureo May require increase of trustee paymento Debtor might be able to put on end of loan with no interest

and avoid plan modificationE. If plan not modified, most Courts will require approval of any subsequent “agreement or modification” on how debtor is to cure or address payments in forbearance.

Review:

A. Conduit or non-conduit plan.

B. Current local rules or practice regarding how Trustee and Court

addressing

C. Take action to protect debtor

D. File Motion to Strike or similar pleading.

E. Do not allow lender or counsel for lender to automatically

withdraw notice without verifying payment history and credit

report

F. Review debtor’s Credit Report for impact and advise debtor on

appropriate action.

G. Ask for fees if allowed in your jurisdiction. This should come from

unsecured pool or possibly creditor, as debtor was not at fault!

It is important counsel takes steps to assist debtor in objecting to the notice on the

record and asking the lender to remove the notice of forbearance. As some lenders

only allow one forbearance and some debtors may still face layoffs, you need to

preserve the right should your client need a future forbearance.

IF YES IF NO


Elizabeth Warren Letter to Wells Fargo (excerpt):

“We write to request more information about recent reports that Wells Fargo has been placing borrowers who are not delinquent on their loans in mortgage forbearance programs without their consent and putting consumers at risk of greater financial hardship amidst one of the worst economic downturns in our country’s history. This includes reports of misrepresentations to bankruptcy courts about borrowers’ requests for forbearance. These reports are highly disturbing given Wells Fargo’s recent history of illegal behavior and inappropriate treatment of customers, including over a dozen scandals involving the creation of millions of fake customer accounts, illegal repossession of servicemembers’ cars, wrongful foreclosure on hundreds of homes, illegal add-on charges to customers’ accounts, and much, much more.”

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“These forbearance filings that were based on nonexistent requests from customers “in Chapter 13 bankruptcy cases can put borrowers’ homes at risk of foreclosure and represent a fraud against the bankruptcy court,” in addition to harming their credit.6 Moreover, because of the way loan servicers are compensated for forbearance, it is possible that Wells Fargo was able to profit on each forbearance filing.”



“Given our ongoing concerns about the bank’s ability to comply with the law and treat its customers fairly, we ask that you provide the following information no later than August 12, 2020.

1. Please provide a description and written copies of Wells Fargo’s policies with respect to:

a. The use of court documents to determine whether to file for forbearance on behalf of a customer during COVID-19;

b. Any other circumstances under which Wells Fargo would enter a consumer who is not delinquent on their loan into forbearance without a customer’s explicit request;

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c. The steps Wells Fargo takes to notify consumers that their loan has been placed into forbearance, including the text of any letter that goes out with the notification of forbearance as well as the time that elapses between a consumer being placed into forbearance and the consumer receiving that letter;

d. The communications with bankruptcy trustees after Wells Fargo places a loan in forbearance;

e. What information Wells Fargo furnishes to credit bureaus for consumers who have been placed into forbearance, including all special comment codes;

f. How Wells Fargo manages requests from customers who initially indicated they wanted to participate in forbearance programs, but after receiving information about the program, no longer want it.



2. For how many mortgage borrowers has Wells Fargo provided forbearance since March 18, 2020? Of that number, how many of those borrowers were current on their loan and did not explicitly request and provide appropriate consent for their loans to be placed in forbearance? Of that number, how many of those loans were government-backed? a. What actions has the bank taken to identify these cases and

remunerate borrowers for any damage caused by Wells Fargo’s actions?

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3. Has Wells Fargo identified circumstances under which the bank has filed official court documents that indicate a borrower has requested forbearance when they have not explicitly requested it and provided appropriate consent? a. If so, how many instances has this occurred and what remediation

efforts are underway?



4. Has Wells Fargo been compensated for forbearance filings not requested by the borrower? If so, how much has Wells Fargo been compensated?

5. How does Wells Fargo handle funds received from borrowers who continue making full or partial payments while their loan is in forbearance, including any loan that was current but has been placed in forbearance without a request from the borrower?

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6. For current borrowers whose loans Wells Fargo has placed into forbearance without the borrower’s request, what special comment codes has Wells Fargo furnished to credit reporting agencies, such as a disaster code, or any other special comment code, even if the loan is reported as current? If so, has the bank taken any steps to correct the information with the credit reporting agencies?”


Eyer v Wells Fargo:

In consultation with the other Judges of this Court, it is concluded that the Notice of Payment Change filed by Wells Fargo should be stricken. The Court reaches this conclusion because the payment change notice has nothing to do with the Debtor’s current obligations under its note and/or mortgage with Wells Fargo. Rather, the Notice of Payment Change submitted by Wells Fargo is merely an offer (or a request) that the Debtor enter into a loan modification agreement.

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Eyer v Wells Fargo:

However, to insure that such items are not merely entered into by default—and without meaningful opportunity for debtors to seek guidance and counsel from their attorneys—it seems more appropriate that mortgage modification approval be obtained by way of a formal motion joined by the debtors (through their counsel if they have an attorney). This process is appropriate to insure that any loan modification entered into by the debtors is knowingly made, is voluntary, and is in their best interests. In addition, such transactions appear to be outside the “ordinary course” and a motion would be the appropriate vehicle by operation of 11 U.S.C. § 363 and/or Fed. R. Bankr. P. 9019.


In re Allen and In re Roman:

Based upon the Findings of Fact, the Court agrees with Debtors Counsel and the Standing Trustee that Wells Fargo’s Notice goes beyond the pale of due process. Rule 4001 of the Federal Rules of Bankruptcy Procedure and Rule 4002 of this Court’s Local Rules require Court authorization for a debtor to obtain credit secured by real property, which includes mortgage modifications. Only after a debtor obtains a Court Order approving the trial modification would a Notice of Mortgage Payment Change based on the trial modification be timely and appropriate. The Court recommends that creditors such as Wells Fargo only file such Notices when it can attach an Order of this Court approving the proposed trial modification. Therefore, the Debtors’ Objection to Notice of Mortgage Payment Change is SUSTAINED and the trial modification is REJECTED.

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http://www.westlaw.com/Link/Document/FullText?findType=L&pubNum=1000546&cite=11USCAS363&originatingDoc=I494b31c0af7411e5963e943a6ea61b35&refType=LQ&originationContext=document&vr=3.0&rs=cblt1.0&transitionType=DocumentItem&contextData=(sc.Default)

http://www.westlaw.com/Link/Document/FullText?findType=L&pubNum=1000611&cite=USFRBPR9019&originatingDoc=I494b31c0af7411e5963e943a6ea61b35&refType=LQ&originationContext=document&vr=3.0&rs=cblt1.0&transitionType=DocumentItem&contextData=(sc.Default)

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Thank you to all of our Speakers!!!

PO Box 1000Shelby, North Carolina 28151

704.473.7022 (Max Direct)

www.consumerdefenseacademy.comwww.maxgardner.com

[email protected]

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http://www.consumerdefenseacademy.com/

http://www.maxgardner.com/

mailto:[email protected]

Brought to You By - considerchapter13.org · 2 The CARES Act and Mortgage Forbearance On March 27,...

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