Variable Rate Compliance Issues

On Demand Course

Instructor: Rebekah Leonard

Duration: 2 HRS

What You'll Learn

We are deep into 2025, and interest rates are still high and houses are still expensive! The low fixed rates of yesteryear lulled many bankers into variable rate complacency. We didn’t have to think too much about them, because we were too busy making loans in the hot market. Now that rates have climbed, variable rates have become quite relevant again. The compliance issues surrounding variable rates are voluminous. Moreover, existing loans are coming due and there is pressure to renew / refinance / modify them at competitive rates. Get a refresher on the multiple compliance items to watch far, as well as get a handle on the creative methods the industry is employing to keep loan volume going!

Topics covered in this session

ATR / QM considerations for variable rate loans
Buydowns
Discount Points
Assumptions
Renewals
Modifications (the rules are different for open-end vs closed-end!)
Refinances (including the special variable rate trigger)
ARM Disclosure requirements:

From Application disclosure to CHARM to TRID
Premium and discount rates

ARM Notice compliance
Advertising
RESPA Section 8 as lenders grow partnerships with realtors

Who Should Attend:

Compliance staff
Real estate staff
Risk managers
Loan officers
Loan operations
Marketing staff
Audit staff

About the Author:

Rebekah Leonard

Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.

On-Demand Course