Legal Blog

CHARM Booklet Revised

The Bureau has revised the CHARM Booklet, for immediate use, to provide updates based on consumer testing and removes references to LIBOR based rate examples.  The updated booklet aligns itself with the Bureau’s efforts to improve readability and usability.  The booklet has a similar look as the Your Home Loan Toolkit which is given alongside the CHARM booklet when a borrower is considering an adjustable rate mortgage.

New features:

  1. a comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products;
  2. an explanation of how an adjustable rate mortgage works;
  3. a tutorial on how to review an ARM Loan Estimate and a lender’s ARM program disclosure;
  4. a comparison table for the various adjustable and fixed-rate loan offers that reader has received or will receive; and
  5. a description of the risks that come with different types of adjustable rate mortgages.

Distribution and Use of the Updated CHARM booklet

  1. Creditors may, at their option, immediately begin using the revised CHARM booklet, or a suitable substitute, to comply with TILA requirements.
  2. The Bureau understands, however, that some creditors may wish to use their existing stock of the booklet. Therefore, those who provide the booklet may use earlier versions until existing supplies are used. When reprinting the CHARM booklet, the most recent version should be used.

What does this mean for you?

  1. Reach out to your document provider and inquiry when they will be releasing the updated CHARM booklet.
  2. Inform your mortgage loan originator about the updated booklet.  Are they ready to address questions from their borrower?
  3. Got paper?  Inform your office staff to remove the older versions and replace with the updated version if you decide not to use your current supply.

 

You can access the CHARM booklet here and the Federal Register notice here.

ABOUT DANIELLA CASSERES

Daniella Casseres’ legal practice focuses on laws and regulations governing mortgage lenders, mortgage brokers, financial institutions and consumer finance companies. She regularly advises clients on state and federal compliance laws and regulations including fair lending, advertising, licensing, privacy, TILA, RESPA, FHA, FCRA, and BSA requirements.

 

 

 

 

 

 

 

ABOUT OFFIT KURMAN

Offit Kurman is one of the fastest-growing full-service law firms in the United States. With 14 offices in seven states, and the District of Columbia, and growing by 50% in two years through expansions in New York City and Charlotte, North Carolina, Offit Kurman is well-positioned to meet the legal needs of dynamic businesses and the individuals who own and operate them. For over 30 years, we’ve represented privately held companies and families of wealth throughout their business life cycles.

Whatever and wherever your industry, Offit Kurman is the better way to protect your business, preserve your family’s wealth, and resolve your most challenging legal conflicts. At Offit Kurman, we distinguish ourselves by the quality and breadth of our legal services—as well as our unique operational structure, which encourages a culture of collaboration and entrepreneurialism. The same approach that makes our firm attractive to legal practitioners also gives clients access to experienced counsel in every area of the law.

Find out why Offit Kurman is The Better Way to protect your business, your assets and your family by connecting via our Blog, Facebook, Twitter, Instagram, YouTube, and LinkedIn pages. You can also sign up to receive LawMatters, Offit Kurman’s monthly newsletter covering a diverse selection of legal and corporate thought leadership content.

DELAWARE | MARYLAND | NEW JERSEY | NEW YORK | NORTH CAROLINA | PENNSYLVANIA | VIRGINIA | WASHINGTON, DC