Document Updates: OR Forbearance Accommodation Disclosure (Cx24147)

Last month, we created Cx24147 as a means for clients to comply with OR HB 4204, § 1(9) (2020), which requires the following:

“Within 60 days following the effective date of this 2020 special session Act, each lender authorized to do business in this state must provide written notice by mail to all of the lender’s borrowers of a borrower’s rights for accommodation under this section.” 

The language of this section is a bit odd. While it only requires the notice to be provided between June 30^th and August 29^th, the forbearance relief provisions in the rest of the bill (which are outlined in the notice) still apply during the “emergency period” which is tentatively slated to end September 30^th (unless extended by Oregon’s Governor) and the bill itself ceases to have any effect 90 days after the end of the emergency period (tentatively set for December 29, 2020). Thus, there is a period of (at least) a month where new borrowers will not be informed of Oregon’s forbearance provisions.

There is no indication that the Oregon Legislature made a mistake in prematurely ending the disclosure timeframe before the end of the emergency period. Therefore, we will be discontinuing support for Cx24147 – though it will be available “upon request” for clients who wish to continue providing it during the other effective timeframes of OR HB 4204.

This change will take effect on September 1, 2020. Questions or concerns about this change may be directed to Client Support at 1.800.497.3584.

DR 326506