In July 2013 the CFPB issued the final interpretations for changes to Regulation Z precipitated by the Dodd Frank Act, which requires financial institutions to provide a monthly statement to members who have closed-end mortgages. (The specific addition can be found in Section 1026.41, excerpts from which are quoted in the body of the announcement.)
According to the regulation, financial institutions that are subject to the rule must send a monthly statement for each billing cycle after the payment due date or at the end of the courtesy pay period provided for the previous billing cycle. There is an exemption to this rule if the financial institution provides the member with coupons, but this exemption does not apply to Adjustable Rate Mortgages (ARMs).
It is important for your credit union to thoroughly understand the regulation, and some credit unions may even need to make adjustments to their mortgage servicing rules. This document is intended to explain CU*Answers’ intentions with regard to producing the required statements for members.
On August 26th CU*Answers published an announcement to all clients detailing the plan to address the new regulation as well as details revolving around the specifics of the requirements. In the body of the announcement we suggested that clients comment on the specific plan and encourage these comments be posted on the AuditLink site. To post a comment please follow the link below.