Profile: nancy sanders
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August 14, 2012 8:50 am
Welcome to Regulation Room, nancy sanders, and thank you for your comment. CFPB’s proposed rule would require that this notice be given 60 days before the new payment is due, not 60 days before the rate changes. CFPB recognizes that some servicers may have to change their practices to meet this new requirement. With all that in mind, do you think that this time frame could work?
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It would be impossible to give a 60 day notice on a rate change, when the index you use is supposed to be 45 days prior to the change date, as written in the original note signed by the borrower.