LIBOR CFPB FAQ ARMs 14 – Were the interest rate adjustment model and sample forms in Appendix H of Regulation Z updated to reflect the LIBOR transition?

Compliance > Regulation Z - TILA > LIBOR Transition
Q:  Were the interest rate adjustment model and sample forms in Appendix H of Regulation Z updated to reflect the LIBOR transition?
 
A:   Yes, the forms that referenced LIBOR were updated. The LIBOR Transition Rule revised the sample interest rate adjustment notices in Regulation Z to 1) remove reference to LIBOR, 2) illustrate one compliant way to disclose the “30-day Average SOFR rate” as the index, and 3) correct an error on Appendix H-4(D)(4) to add the date of the disclosure as required by the regulation, a change that is unrelated to the LIBOR transition.

A copy of the updated sample forms is available here.

Creditors (or assignees or servicers) can rely on the new sample forms beginning April 1, 2022, to be deemed in compliance with the notice content and format requirements. The prior legacy versions will also be available in the regulation and can be relied upon until September 30, 2023. On October 1, 2023, only the new sample forms will be available and will be the only version of the sample forms that can be relied upon for compliance with the notice content and format requirements.
 
 
This Q&A was created based on information from the Consumer Financial Protection Bureau’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://files.consumerfinance.gov/f/documents/cfpb_libor-transition_faqs.pdf
 

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