Document Updates: CHARM Booklet

The CFPB has published a revised version of the “CHARM Booklet” required by 12 C.F.R. § 1026.19(b)(1) (available at: https://www.consumerfinance.gov/learnmore/, subheading “Mortgages”). According to the CFPB:

“. . . New features include a comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products; an explanation of how an adjustable rate mortgage works; a tutorial on how to review an ARM Loan Estimate and a lender’s ARM program disclosure; a comparison table for the various adjustable and fixed-rate loan offers that reader [sic] has received or will receive; and a description of the risks that come with different types of adjustable rate mortgages. This version of the CHARM booklet eliminates references to LIBOR due to the forecasted cessation of LIBOR.” (85 FR 35292 [2020])

Our Fulfillment operations are now ordering the newest versions of the Booklet, which will be included in Fulfillment packages once our existing stock of the Booklet is depleted, as permitted by the CFPB:

“. . . The Bureau understands, however, that some may wish to use their existing stock of the CHARM booklet. Therefore, those who provide this publication may use earlier versions of the CHARM booklet until existing supplies are exhausted. When reprinting the CHARM booklet, the most recent version should be used.” (Ibid. 35293 [2020])

We also provide an electronic version of the Booklet in ConformX and Solex. We have updated both areas and they are currently available on our Stage environments for testing. Updates will be available on production on June 26, 2020.

Questions or concerns about these changes should be directed to Client Support at 1.800.497.3584.

TW 301683

Update: We have discovered that the CFPB posted a revised version of the Booklet on their website, which differs from the one which was originally posted in their initial announcement (e.g., the last page of the original had the caption “Last updated XXXXX”, rather than “Last updated 06/20” as on the current version). We have updated our electronic version of the Booklet to match the latest version posted.