LIBOR CFPB FAQ HELOCs 11 – What if the HELOC creditor chooses to replace LIBOR prior to April 1, 2022?

Compliance > Regulation Z - TILA > LIBOR Transition
Q:  What if the HELOC creditor chooses to replace LIBOR prior to April 1, 2022?
 
A:   The LIBOR Transition Rule is not effective until April 1, 2022. If a creditor chooses to replace a LIBOR index before April 1, 2022, the creditor must comply with the version of Regulation Z in effect prior to April 1, 2022. For example, the creditor would not be afforded the LIBOR-Specific Provisions discussed above.  
 
 
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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