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DILEMMA FOR ARMs WITH NO LOOK BACK PERIOD

Effective on January 10, 2014 Section 1026.20 of Regulation Z requires, when a rate change accompanied by a payment change occurs on an ARM, a notice to be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due. However a different timing rule (at least 25, but no more than 120, days before the first payment at the adjusted level is due) applies […]

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EFFECTIVE DATE FOR NEW ARM NOTICES

Effective on January 10, 2014 § 1026.20 of Regulation Z requires that when a rate change accompanied by a payment change occurs on an ARM a notice must be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due (§ 1026.20(c)). An additional notice is required in connection with the initial interest rate adjustment provided to consumers. That notice must be provided at least […]

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PROPOSED FLOOD REGULATIONS

Recently the Office of the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Farm Credit Administration, the National Credit Union Administration (jointly referred to as the Agencies) issued 166 pages of proposed rules for loans in areas having special flood hazards. The revisions to existing rules are based on changes from the Biggert-Waters Flood Insurance Reform Act of 2012. Comments are being accepted until December 10, 2013. The Agencies […]

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