With respect to the effective dates only:
The Reg X mortgage servicing rule amendments apply beginning January 10, 2014, to all mortgage loans that are being serviced. There is one minor exception: A servicer is not required to comply with ยง 1024.38(c)(2) -- the servicing file standards -- with respect to information created prior to January 10, 2014. [See Comment 38(c)(2)-1]
The Reg Z mortgage servicing rule amendments also apply beginning January 10, 2014, to all mortgage loans that are being serviced. There is a grandfathering exception for ARM loans with index look-back periods of less than 45 days that are originated before January 10, 2015.
Last edited by John Burnett; 04/11/13 02:31 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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