Compliance News Alert: Nebraska Net Tangible Benefits Disclosure
Nov 20, 2019
FNMA has announced pending plans to modify their ARM products in the first half of 2020. These changes are being done under the guidance of the FHFA and in coordination with FHLMC.
Some of the planned changes include incorporating the Alternative Reference Rate Committee’s (ARRC’s) “fallback language” into the uniform notes and other legal documents for ARMs. New ARM products based on the Secured Overnight Financing Rate (SOFR) index are also planned, with the index being based on a 30-day average of the overnight SOFR.
While no changes are finalized at this time, we will continue to monitor this transition and post Compliance News alerts when changes are finalized and announced.
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.