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Loss Mitigation Notices

Answered by: 
Randy Carey
John Burnett

Question: 
We have determined that it is appropriate to inform our borrowers of HELOCs nearing maturity about the availability of loss mitigation options. These borrowers are typically not past due, but we follow 1024.39 - Early intervention requirements for 180-day and 120-day timing for live contact and Written Notice. Is the Written Notice required to include all 5 items (1024.39(b)(2)) even though the borrower is not past due?
Answer: 

by Randy Carey:

Since 1024.39 does not apply to HELOCs and the borrowers are not even past due, I am not sure of the question and why you would be instituting loss mitigation procedures on a non-past due loan just because they have a HELOC that is maturing.

Answer: 

by John Burnett:

There is this: https://www.occ.gov/news-issuances/bulletins/2014/bulletin-2014-29.html, which conveys interagency guidance on Risk Management of Home Equity Lines of Credit Approaching the End-of-Draw Periods

First published on 10/29/2023

Filed under: 
Lending
Filed under lending as: 
Reg. Z

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