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The InfoSight360 compliance update for the first quarter of 2025 is now available. The recording is located under Trainings in the lower right-hand corner of the My 360 View page.
In the update, you will learn about:
- An interim final rule exempting domestic reporting companies from the requirement to submit their beneficial ownership information directly to FinCEN.
- A Congressional Review Act resolution, awaiting the President’s signature, to nullify the CFPB’s overdraft rule for institutions with over $10 billion in assets.
- A court order vacating the CFPB’s rule that would have capped credit card late fees at $8 for card issuers with one million or more open and active card accounts.
- HUD’s decision to rescind its October 2024 reconsideration of value requirements and its announcement to eliminate FHA eligibility for non-permanent residents.
- The FCC’s decision to postpone the effective date of its TCPA universal consent revocation provision until April 11, 2026.
- The NCUA’s decision to reopen its share insurance simplification and succession planning final rules to allow for additional comment.
In addition, the InfoSight360 compliance calendar (found under Resources) will be discussed to cover what is on deck for the next three months of 2025.
It is also recommended that credit unions read the below InfoSight article about HUD’s updates to FHA-insured mortgages.
Updates from HUD on FHA-Insured Mortgages
In recent weeks, the United States Department of Housing and Urban Development (HUD) has issued a couple of updates related to FHA-insured mortgages that credit unions should be aware of.
The first was issued on March 19 in Mortgagee Letter 2025-08. The letter rescinds, among other things, the reconsideration of value (ROV) requirements applicable to FHA-insured mortgages as of October 31, 2024. Those requirements included:
- Development of policies and procedures that outline the steps a borrower can take to appeal a valuation report;
- Disclosure to a borrower of his/her right to request a ROV; and
- The steps a credit union must take in response to a ROV request.
HUD rescinded its ROV requirements in light of the President’s January 20 Executive Order directing federal agencies to reverse policies that have an adverse effect on key sectors of the economy, including the housing market. The interagency guidance on reconsiderations of value effective July 26, 2024, and FHFA’s ROV requirements effective October 31, 2024, both remain in effect.
HUD followed up on March 26 with Mortgagee Letter 2025-09. That letter eliminates the eligibility of certain non-permanent residents for FHA-insured mortgages. The letter provides that on a go forward basis, only the following are eligible for FHA-insured financing:
- U.S. citizens
- Permanent U.S. residents
- Citizens of Micronesia, the Republic of the Marshall Islands, or the Republic of Palau.
Lenders will be required to provide evidence of the borrower’s lawful permanent residence to HUD. Such evidence should be obtained from the U.S. Citizenship and Immigration Service (USCIS), a division of the Department of Homeland Security.