On September 5, 2014, the Department of Veterans Affairs (VA) announced in Circular 26-14-25 that it intends to clarify its interest-rate adjustment, disclosure, and notice requirements for ARM and hybrid ARM mortgage loans guaranteed by the VA in view of the CFPB's TILA mortgage servicing rule. The VA noted that the TILA mortgage servicing rule, which generally became effective in January 2014, is not effective for VA-guaranteed ARM and hybrid ARM mortgage loans until January 10, 2015.

The VA advised that it expects to publish in the near future revised regulations covering interest-rate adjustment, disclosure, and notice requirements for VA-guaranteed ARM and hybrid ARM mortgage loans to conform with the terms of the TILA mortgage servicing rule. The VA notes that in the event that its regulations are not in place by January 10, 2015, all lenders and servicers must comply with the terms of the TILA mortgage servicing rule.