As previously announced, OH HB 199 (2017) was recently enacted to reform Ohio’s statutes concerning mortgage lending (see http://blog.docutechcorp.com/compliance-news-ohio-reforms-mortgage-lending-laws). A preliminary review of this bill against our document library reveals that the following documents may be retired as generic documents:
- “OH Mortgage Loan Origination Disclosure” (Cx3472) – Provided pursuant to Ohio Rev. Code Ann. § 1322.062(A) and Ohio Admin. Code § 1301:8-7-15(A), the former of which will be repealed.
- “OH Non-Brokered Escrow Account Disclosure” (Cx11197) – Provided pursuant to Ohio Rev. Code Ann. § 1321.592(A), which will be repealed.
- “OH Mortgage Loan Origination Disclosure Statement Addendum” (Cx11204) – Provided pursuant to Ohio Rev. Code Ann. § 1322.062(D) and Ohio Admin. Code § 1301:8-7-15(D), the former of which will be repealed.
- “OH Escrow Account Disclosure” (Cx11205) – Provided pursuant to Ohio Rev. Code Ann. § 1322.063, which will be repealed.
- “OH Notice of Change in Mortgage Terms” (Cx12463) – Provided pursuant to Ohio Rev. Code Ann. §§ 1321.594, 1322.062(B), & 1322.064 and Ohio Admin. Code § 1301:8-7-15(E), the former three of which will be repealed.
While the statutory requirements for these disclosures are being repealed, the Ohio Department of Commerce has not, as yet, proposed amendments to the administrative laws which also require these documents ( (see http://www.registerofohio.state.oh.us/jsps/publicdisplayrules/processPublicDisplayRules.jsp?agencyNumberString=1301&actionType=all&doWhat=GETBYFILINGAGENCY&Submit=Search). We will, therefore, be postponing any decisions to retire these documents until the Department provides formal guidance and/or final administrative rules on these disclosures.
We are also reviewing other potential impacts to our system, such as (but not limited to) changes to our prepayment penalty defaults (due to the repeal of the prepayment penalty requirements under Ohio Rev. Code Ann. § 1321.57[G]) and potential retirements for disclosures required under Ibid. ch. 1321 (such as our “OH Insurance Notice to Applicant” [Cx13606]), since such Chapter has been substantially modified to apply to non-mortgage loans (except for loans secured by vacant lots, upon which no dwelling will be placed within two years of acquisition).