LIBOR FRB FAQ 1 – After December 31, 2021, would supervisors view a modification to a LIBOR-referenced adjustable-rate mortgage as a new contract?

Compliance > Regulation Z - TILA > LIBOR Transition
Q:  After December 31, 2021, would supervisors view a modification to a LIBOR-referenced adjustable-rate mortgage as a new contract?
 
A:   Supervisors would not view a modification to a LIBOR-referenced adjustable-rate mortgage as a new contract unless it (i) creates additional LIBOR exposure for a supervised institution or (ii) extends the term of the mortgage.
 

 
This Q&A was created based on information from the Federal Reserve’s website (which may be updated from time to time) that provides Answers to Frequently Asked Questions on the Transition Away from LIBOR.  This information may be found here:  https://www.federalreserve.gov/supervisionreg/srletters/SR2112a2.pdf
 

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