Servicing

14 articles in this category

ARM Adjustment Notices Under Reg Z 1026.20(c) and (d): The 210-Day Initial Notice, the 60-Day Subsequent Notice, and the AI Servicing Agent Explaining the Index Math a Borrower Never Learned

The adjustable-rate mortgage adjustment is the servicing event where the borrower's monthly payment changes because a reference index moved, and the borrower's understanding of why is usually thin. Regulation Z 1026.20(c) governs the notice at least 60 days before a subsequent rate adjustment, and 1026.20(d) governs the first-adjustment notice at least 210 days before the initial change, and both notices have specific content the servicer's system has to produce accurately or the servicer's UDAAP posture is at risk. The architecture we run so the notice is right, the borrower's follow-up call is answered with the index math, and the ARM's reset lands without becoming a complaint.

Jul 17, 202613 min read

HELOC Draw-to-Repayment Reset Servicing With AI Agents: Reg Z 1026.40, the Interest-Only-to-Amortizing Shock, and the Conversation the Bank Postpones Until It Cannot

Home equity lines of credit have the least-understood transition in consumer lending: the end of the interest-only draw period and the start of the fully amortizing repayment period, which for a borrower on a 20-year post-draw schedule commonly doubles the monthly payment. Reg Z 1026.40 disclosures and 1026.9(c)(1) change-in-terms rules run alongside servicing operations that have to explain the reset to a borrower who did not read the original disclosure. The playbook we run so the reset conversation lands well and the servicer's file survives review.

Jul 10, 202612 min read

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