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Since December 29, 1987 banks have been required to develop Adjustable Rate Mortgage (ARM) program disclosures for each different ARM program offered. The disclosures must be updated at least annually. Notices must be sent in response to rate changes. Many financial institutions have automated the ARM disclosure process, but violations still occur.
While many financial institutions have offered ARM products for decades, others only recently migrated from balloon mortgages to ARM products. Whether new to the ARM game or an old veteran a comprehensive review of the rules can help prevent violations.
The Federal Reserve Board has indicated that rates may trend upward over the next several years. Many bankers have never managed an ARM portfolio or originated ARM loans in a rising rate environment. The program provides guidance on operating in such an environment.
This two-hour program explains how to develop, maintain and audit ARM disclosures The program explains the rules, reviews typical problems that occur, and provides steps to assure ongoing compliance.
Participants receive a detailed manual that serves as a handbook long after the program is completed.
Upon completion of this program participants understand:
• What qualifies as an ARM loan;
• What disclosures are required;
• The timing rules for the disclosures;
• The required contents of the disclosures;
• Rules for periodically updating the disclosures; and
• Rate adjustment disclosures.
The program is designed for all mortgage lenders, compliance officers, auditors and others with responsibilities for assuring compliance with applicable laws and regulations in the mortgage loan department.