Look-Back Period for FHA and VA Adjustable Rate Mortgages
Dear Licensed Partner,
In response to CFPB's 2013 TILA Servicing Rule, Federal Housing Administration (FHA) and the Department of Veterans Affairs (VA) announced the implementation of a 45-day look-back period for all Adjustable Rate Mortgages (ARMs).
The updated guidelines require that an interest rate adjustment resulting in a change to the borrower’s monthly payment on their FHA or VA ARM be based on the most recent index value available 45 days (instead of 30 days) before the date of the interest rate adjustment.
To comply with the updated guidelines on look-back period, Sun West requires the following on all FHA and VA ARM loans:
• FHA and VA ARM loans with note date on or after January 10, 2015, must reflect look-back period as 45 days on Note and Riders.
• Closed FHA and VA ARM loans submitted for purchase through Correspondent channel with note date before January 10, 2015, may continue to show look-back period of 30 days provided that the loan is purchased by Sun West on or before February 28, 2015.
• Closed FHA and VA ARM loans submitted for purchase through Correspondent channel with note date on or after January 10, 2015 and purchased by Sun West before June 6, 2015, must carry the following interest rate change dates:
o For FHA and VA 3/1 ARMs, first interest rate change date of July 1st, 2018 on Note and Riders.
o For FHA and VA 5/1 ARMs, first interest rate change date of July 1st, 2020 on Note and Riders.
Note: Department of Housing and Urban Development (HUD) and VA announced their regulation revisions in HUD’s Final Rule 79 FR 50838 dated August 26, 2014 and VA Circular 26-14-25 dated September 5, 2014.
If you have any questions, please contact your Client Relations Manager at (855) OK-SUNWEST or (855) 657-8693.
|Sun West Mortgage Company, Inc.
18000 Studebaker Road, Suite 200
Cerritos, CA 90703
Phone: (800) 453-7884