TOPIC: ARM Loan

Errors and Omissions Letter

Chief Compliance Officer at a bank ($953MUSA)
We recently identified that due to a change in document vendors, we have some ARM loans that are missing the 45 day lookback period verbiage in the note, which will make it impossible to meet the 60 day notice requirement for rate changes.  Our compliance consultants suggested we correct the note using the errors and omissions agreement that the customer signed at closing.  Does anyone have a sample letter that they have sent to customers to notify them of a similar issue that you would be willing to share?  Or have any thoughts on how to handle this?  Any help would be greatly appreciated! 

    Replacing INDEX for ARMS-notice

    Employee at a bank ($365MUSA)
    Has anyone replaced an index for ARMs? We currently use 11th district cost of funds and it will no longer be published. We are in the process of making the switch to a new index. We are creating a notice letter to send out to all those affected. Then our system will be set up with the new specs and notices should be sent as they normally would with Initial Rate Notice and Ongoing Rate Notices...    Has anyone gone through a change like this? I want to make sure I'm not missing anything as far as timing and content or letter etc.

      Finastra Servicing Director

      VP at a bank ($456MUSA)
      Hello,  Does anyone use Finastra's Servicing Director product?  We use the Sparak System and MortgageBot from Finastra, and I am evaluating whether Servicing Director would be a good product for us as well.  We had a presentation meeting with Finastra representatives about it.  It sounds like it will be good for us.  However, I would like to get some feedback, (good or bad), from anyone that has used it.  

        ARM Construction Loan

        VP at a bank ($162MUSA)
        We are looking at doing construction loans with an adjustable rate.  The Note/Security Agreement/Financing Statements I'm looking at don't appear to work for this sort of program.  We want them to adjust with prime +1 with a floor.  Does anyone have any redacted completed forms they would be willing to share?

          ARM look back period

          SVP at a bank ($4BUSA)

          For ARM portfolio loans prior to 1/10/2015, If a note is silent in relation to index to be used, what is the default look back period and what regulation or law dictates? We are trying to find a regulatory or legal citation for guidance of what appears to be a standard 30 day look back for these loans. Thanks.

            Qualifying Loan Applicants Post Bankruptcy

            VP at a bank ($403MUSA)

            Are banks using Fannie Mae's or Freddie Mac's guidelines to qualify loan applicants with bankruptcy filings for their own portfolio loans? Generally, 2 years from discharge for Chapter 13 and 4 years for Chapters 7, 11 and dismissal of Chapter 13.

              5/1 ARM TRID Examples

              VP at a bank ($95MUSA)

              Is anyone willing to share a TRID LE and/or CD for a 5/1 ARM. Also please help with the rate change notice timing and content required. Any help will be greatly appreciated.