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#1711479 - 06/18/12 09:11 PM loan rate way under 6%, so....
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
We have a new borrower that advised he will be active duty.

The loan rate is under 6%. We've flagged the account appropriately.

As we will not be making any changes to rates/pmts, do we need to send any kind of acknowledgment to the borrower....nothing is really changing on the account.

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1711500 - 06/18/12 09:46 PM Re: loan rate way under 6%, so.... Trees
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
No. But, does he understand his rate won't go any lower? I would give him the courtesy to know that in case he doesn't.
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#1711562 - 06/19/12 01:08 PM Re: loan rate way under 6%, so.... Trees
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
You also need to keep in mind that the 6% limitation does not apply only to the interest rate. It applies to all charges that would be considered interest under the regulation.

(1) INTEREST.—The term ‘interest’ includes service charges, renewal charges, fees, or any other charges (except bona fide insurance) with respect to an obligation or liability.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1711810 - 06/19/12 05:35 PM Re: loan rate way under 6%, so.... Trees
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Thank you both.

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