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The interpretive rule explains that because an heir has already acquired the title to the home, adding the heir as a borrower on the mortgage does not trigger the Ability-to-Repay requirements. The rule does not require the creditor to determine the heir’s ability to repay the mortgage before formally recognizing the heir as the borrower. As the named borrower, the heir may more easily be able to obtain account information, pay off the loan, or seek a loan modification.
The interpretive rule can also apply to other transfers, including transfers to living trusts, transfers during life from parents to children, transfers resulting from divorce or legal separation, and other family-related transfers.
IMPROVE YOUR COMPLIANCE IN 2016
updated 11/24/15 07:46 AM
Informative ComplySight Webinars
Kick off the New Year with ComplySight and make sure your regulatory compliance is at its finest in 2016 and beyond.
NEW FFIEC MGMT. BOOKLET
updated 11/16/15 12:06 PM
NCUA Portal Open to CUs
The Federal Financial Institutions Examination Council (FFIEC) issued a revised Management booklet, as part of the FFIEC Information Technology Examination Handbook (IT Handbook). Click here for the booklet.