Lending Compliance for Adjustable Rate Mortgages – ON-DEMAND WEBINARS

Date Recorded: December 22, 2021

Presenter: Anetria Cohen, Vice President and Senior Consultant, FORVIS

A two-hour webinar covering lending compliance rules and issues that are specific to ARM loans.

In a period of low interest rates, interest rate risk is a very real concern – as interest rates inevitably rise, institutions are worried that, at some point, the return on fixed rate loans will not be enough to cover interest rates paid on deposit accounts. Accordingly, institutions typically turn to either Adjustable Rate Mortgages (ARMs) or balloon loans to control that risk. Because the Dodd-Frank Act effectively limited a number of institutions’ ability to use balloon loans, institutions increasingly are looking at establishing or emphasizing ARM loan programs instead.

This two-hour webinar will focus on closed-end Truth-in-Lending/Regulation Z requirements as they relate to ARM loans, as the regulation provides a number of requirements that are specific to ARMs and variable rate transactions. In addition to ARM disclosure requirements, it is important to understand how a variable rate transaction is shown and treated under other Regulation Z compliance provisions like the Loan Estimate/Closing Disclosure and the Ability-to-Repay rules.

HERE IS WHAT YOU WILL LEARN:

• Definition of ARMs
• Closed-End Truth-in-Lending Requirements:
  • ARM disclosures: the CHARM Booklet, Program Disclosure, and Adjustment Rate Notices
  • TILA Statement and the Integrated Disclosures (the Loan Estimate and Closing Disclosure);
  • Ability-to-Repay requirements;
  • High-Cost Loans (HOEPA); and
  • Timing rules.