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#1966912 - 10/03/14 04:29 PM ARM notices
taskaquestion Offline
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Joined: Dec 2010
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Are we required to produce the annual Change in Payment Disclosure on an ARM if there is not a rate change?

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Mortgage Servicing Rules
#1966919 - 10/03/14 04:37 PM Re: ARM notices taskaquestion
GTS333 Offline
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Joined: Jun 2010
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No, that annual requirement went away on 1/10/2014 when the new servicing rules went into effect.
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#1970094 - 10/17/14 03:57 AM Re: ARM notices taskaquestion
jlroberts Offline
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jlroberts
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However if the rate doesn't change but the payment does I believe you must send the notice. This could happen if the borrower makes additional principal payments which then changes the remaining amortizing payments.

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#1970261 - 10/17/14 05:23 PM Re: ARM notices jlroberts
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By: jlroberts
However if the rate doesn't change but the payment does I believe you must send the notice. This could happen if the borrower makes additional principal payments which then changes the remaining amortizing payments.


Although you might elect to provide a similar notice under those circumstances, the notice requirement in .20(c) is triggered by a rate change resulting in a payment change, not by a payment change that's not the result of a rate change.
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#1970374 - 10/17/14 08:26 PM Re: ARM notices taskaquestion
GTS333 Offline
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Posts: 257
I agree with John. Nothing in Reg. Z that says you can't send a notice under those circumstances, but it is not technically required.
_________________________
My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

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