CFPB Issues Updated CHARM Booklet

Ballard Spahr LLP

Ballard Spahr LLP

The CFPB recently announced the availability of an updated Consumer Handbook on Adjustable Rate Mortgages, often referred to as the “CHARM booklet.” The Federal Register notice regarding the public availability of the updated booklet is available here.

The biggest difference in the updated booklet is its size. The prior version issued in 2014 is 41 pages, while the updated version is a slender 13 pages. The CFPB explains that the booklet was updated “so that it aligns with the Bureau’s educational efforts, to be more concise, and to improve readability and usability.” The format of the updated booklet is designed to have the same look and feel as the Your Home Loan Toolkit guide, which the CFPB updated in connection with the TILA/RESPA Integrated Disclosure (TRID) rule.

The updated booklet reflects the Loan Estimate under the TRID rule, with a focus on interest rate and payment adjustment disclosures for an adjustable rate mortgage loan. References to LIBOR were removed from the booklet, and there are no references to the Secured Overnight Financing Rate, the likely replacement index for LIBOR for many lenders.

Creditors may elect to continue to provide the prior version of the CHARM booklet until their supply is exhausted, and then should use the updated version. Alternatively, creditors may opt to begin to use the updated version immediately.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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