We had sent a commercial customer an adverse action notice on a request to refinance the loan. The customer has indicated that new federal regulations require the bank to give consideration whenever a “notice of hardship” has been given and the customer is to be given or is to give a “notice of appeal of an adverse action.” I am not familiar with these terms in “” and was wondering is someone could give some insight as to what the customer is wanting and if there is new regulations for problem commercial loans?
There are certain hardship modification/refinance programs offered by the federal government and some offered by specific banks that include the provisions mentioned in your question. I am not aware of any specific requirement that applies to all banks engaging in hardship modifications/refinances.
New RESPA rules related to loss mitigations include an appeal option, but those rules apply to RESPA-related mortgage loans secured by a borrower’s principal dwelling.