There may be a technical argument for having to send a final charge off statement, but practically I'd probably not do that and have my argument prepared for an examiner in case it comes up. I think the fact that the loans were already charged off well in advance of the rule change is a pretty strong argument. Keep in mind this also only applies to closed-end consumer credit (1-4 family) secured by a dwelling. If that's not your loan types, you may not have to worry a out this.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.