Mass. Gen. Laws ch. 184, § 17B 1/2 requires that:
“At or before closing [a subprime loan at a variable or adjustable rate of interest], the mortgagee shall obtain evidence that the mortgagor has completed an approved counseling program.”
Our MA Counseling Disclosure (Cx13391) currently prints in Initials and Closings to satisfy this requirement. However, since the timing requirement for the disclosure is to be given “at or before closing,” and since it is very unlikely that borrowers will have completed an approved loan counseling program by the time the Initial disclosures are generated, we have decided to generically remove the document from printing in the Initial Disclosure package. Also, we are changing the language of the signature acknowledgment from: “I/We acknowledge this document for the sole purpose of certifying receipt of it prior to closing” to: “I/We acknowledge this document for the sole purpose of certifying receipt of it at or before closing” to better reflect the language in the statute.
These changes will be in effect on November 19, 2020. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.