CFPB Addresses Adjustable Rate Notification Catch-22
Beginning Jan. 10, 2014, a lender is required to provide notification to consumer at least 60 days prior to the first payment of an adjusted rate, but what if that first payment is due, say, Feb. 10, 2014, in other words, after the effective date requiring the notification but less than the 60-day minimum notification requirement? CFPB addresses this Catch-22. [7/19]