With the first increase in the Prime Rate in almost ten years, those of you with variable-rate loan products (HELOCs, ARMs, etc.) may now have some compliance requirements that you haven’t had to worry about in a quite awhile.
It would be a good time to review the rate change notice requirements in §1026.20 to make sure your rate change notices meet the timing, content and formatting requirements for loans secured by a principal dwelling. Also, make sure that rate changes for both open and closed-end plans match your contract language and any other communications as well as that your systems accurately reflect any change.
In other words, “Do What You Say and Say What You Do”. It seems simple enough but we know that variable rate products can sometimes be anything but simple…especially when you haven’t had to worry about changes to the Prime Rate for quite some time.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!