Circular 26-14-25 clarifies that should the VA’s revised regulations regarding VA-guaranteed ARMs/hybrid ARMs not be in place by January 10, 2015, the effective date of the CFPB’s Mortgage Servicing Rules (“Rules”) under TILA, all lenders and servicers must comply with the CFPB’s Rules regarding interest-rate adjustment, disclosure, and notice requirements for ARMs and hybrid ARMs guaranteed by the Department of Veterans Affairs.
