We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?
Is there any standard format to send notice of a change in terms for credit cards?
What are loan portfolio metrics?
What is involved with customer and account document management?
If an applicant chooses not to provide the borrower demographic data do we still collect it based on visual observation and surname?