Loan Servicing Requirements: Don’t Forget About Your Existing Loans!

As most of the requirements going into effect in January 2014 apply to new applications it might be very easy Diane11for banks to overlook those requirements that affect their existing loans.  If you haven’t done so already, you will want to determine whether the following requirements apply to you very soon.

If you originate adjustable rate mortgages subject to Regulation Z or are considered a large servicer subject to the periodic statement requirements, you need to make sure your systems and vendors are ready to roll with the requirements as they apply to your entire loan portfolio.  You will want to review not only the content of any required statements and/or notices, but also test the system to ensure the statements and/or notices are being generated in a timely manner in line with the new requirements.  Also, if you are going to use coupon books to meet the periodic statement requirements, do you need to order new ones?

These requirements take effect January 10, 2014, and if you act now you will hopefully have time to address any issues by January!

Diane Dean

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