There was a new law passed in the state of Ohio that will affect notice requirements for junior lienholders of residential real property that is required beginning March 20, 2019. It states that Ohio Banks and Credit Unions must send notices to their borrowers before collecting a debt in default if the borrower's residential real property secured that debt through a junior lien. This seems to be a new notice in addition to already existing delinquency notices.
A couple things that I can't decipher:
1) Does this cover loans where the collateral property is in the state of Ohio? Or just the bank location where the loan was made in the state of Ohio regardless of collateral location?
2) The timing requirement is "prior to collecting or attempting to collect any debt" - but I don't see anywhere where that is defined. Is this before the first delinquency notice is sent from the bank (prior to 15 days delinquent)? Or prior to any live contact attempts or filings?
Anyone other Ohio bankers working through this that want to chime in on their thoughts?