We have a cd secured loan where we took the customer's home as an abundance of caution. Our cd loan of course are variable rate loans,
If this is a consumer purpose loan do you realize you have an ARM loan subject to 1026.19(a)&(b), 1026.18(s), 1026.20(c), 1026.23 if the primary residence, IOWs Reg. Z in general, RESPA, Flood, HMDA and its rate spread, etc?
The opinions expressed are mine and they are not to be taken as legal advice.