Ongoing Disclosures Flashcards
TILA - Section 36
Initial Interest Rate Adjustment Disclosure
Provides information about the servicer, alternatives to avoid paying the new rate, the effective date of the new rate, new payment, amount, and any changes to loan terms. Servicer must send out 210 to 240 days prior to rate adjustment and is kept for two years.
TILA - Section 36
Subsequent interest rate adjustment disclosure
Ongoing interest rate adjustment disclosure
Provides information about the service or, alternatives to avoid paying the new rate, the effective date of the new rate, new payment, amount, and any changes to loan terms. Servicer must send out 60 to 120 days prior to rate adjustment and is kept for two years.
RESPA - Section 6
NTS
Notice of Transfer Statement
Informs the borrower their loan is being transferred to a new servicer. 15–15–60 day rule. Old servicer must send out 15 days prior to transfer, new servicer must send out within 15 days after transfer, and no late fees can be charged for 60 days.
RESPA - Section 10
Annual Escrow Statement
Detects, overages, and shortages. If there is an overage of $50 or more than the entire overage is returned to the borrower. If there’s a shortage, it let’s them know how to rectify that. This is due annually within 30 days of annual escrow account analysis.
GLBA - Regulation P
Annual Privacy Notice
It explains what information the institution gathers, where this information is shared, how the institution safeguards that information, and how to opt out of certain aspects. This is due annually.