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.