With the new rate spread calculator, I am wondering if the APOR spreadsheet will it no longer be updated with each Monday? Also, I am getting conflicting answers within the forum: as a small servicer, is there an exception to the threshold of 3.5% on first liens or does the rule apply across the board whether you are a small creditor or not: 1.5% for first lien and 3.5% for subordinate liens to determine the HPML status?
Our bank made a loan to an active duty military on 4-16-15. He was active duty on 8-2-13 and ended active duty on 7-2-16. Can our bank repossess per the reg?
Can we continue to use the old four-page uniform application with the demographic information addendum or must we convert to the new eight-page form.?
Is there any reason why we are not allowed to have First Reserve/LOC statements and HELOC’s to be estatement?
The previous Commentary to Reg Z at 1026.5b contained the following statement regarding a matured HELOC: "...A new plan results; however, if the plan is renewed (with or without changes to the terms) after the scheduled expiration. The new plan is subject to all open-end credit rules, including sections 226.5b, 226.6 and 226.15." I have not found any comparable interpretations by the CFPB since the CFPB took over responsibility for Regulation Z. I'm looking for any information that will support the need, or lack thereof, to require a Notice of Right to Cancel when a new HELOC note is executed after the existing HELOC has matured.