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#1534401 - 04/12/11 04:39 PM ARM Loans
SouthernComfort Offline
Platinum Poster
Joined: Aug 2001
Posts: 705
Southern Illinois, USA
We have recently acquired 2 new branches of another bank. We do not do ARM loans but have inherited a few from the other bank. Can someone tell me how these work and what the requirements are or where I can find information on them. I have looked in Reg Z and also at the model disclosure. We are not planning on adding this product but we will have to maintain the loans that we have inherited. Any information will be helpful.

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Lending Compliance
#1534408 - 04/12/11 04:48 PM Re: ARM Loans SouthernComfort
Cowboys Fan Offline
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Joined: Dec 2002
Posts: 4,617
SC
See 226.19(b) for the disclosures required up front and 226.20(c) for subsequent requirements. Make sure that the each loan is booked on your system exactly like the contract states (index, rate change frequency, rounding method, etc.) and review your rate change notice to make sure it includes the requirements in 226.20.
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#1534502 - 04/12/11 06:32 PM Re: ARM Loans Cowboys Fan
SouthernComfort Offline
Platinum Poster
Joined: Aug 2001
Posts: 705
Southern Illinois, USA
Thanks for the information. I appreciate it.

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#1534705 - 04/12/11 09:54 PM Re: ARM Loans SouthernComfort
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,182
Toano, VA
If you don't do the product, that increases the chances of costly errors & regulatory violations (which can also be costly.) I'd consider selling these loans to someone who's set up to handle ARMs.
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