Summary of the Mortgage Lending Provisions In the Dodd-Frank Wall Street Reform and Consumer Protection Act

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1 Summary of the Mortgage Lending Provisions In the Dodd-Frank Wall Street Reform and Consumer Protection Act Prepared by Robert A. Cook and Meghan Musselman Hudson Cook Revised as of July 30, 2010 A Few Key Points to Consider Qualified mortgages will escape many regulatory restrictions. Key parts of definition: Fully amortizing fixed or variable rates No interest only payments or negative amortization Complies with debt-to-income or similar ability to repay guidelines to be set by regulation Total points and fees do not exceed three points Benefits include: Exemption from risk retention requirement Safe harbor for ability to repay test Some qualified mortgages may have a prepayment penalty Excluded from the higher-risk mortgage definition Ability to repay requirements for all closed-end mortgage loans HOEPA coverage tests are completely rewritten and much more expansive Now covers purchase money loans and HELOCs Certain points and fees now excluded, may help limit impact Qualified written requests must be acknowledged within five days (penalties also increased) Loan broker compensation may not be based on loan terms other than the loan amount But borrower may choose to pay broker fees by accepting an increased interest rate Appears to exclude servicer employees from mortgage originator licensing requirements New higher-risk mortgage rules, including physical property visit required for appraisals No arbitration agreements on residential mortgage loans (i.e. closed-end, dwelling secured) or HELOCs TILA penalties increased Class action cap raised to $1,000,000 Mortgage originators subject to TILA penalties for compensation and steering violations Heaviest penalties (by far) applied to violations of the appraiser independence requirements Attorney general enforcement expanded Significant disclosure burdens added, including: Monthly statements for closed-end mortgages Payment schedule disclosure must include escrow amounts Wholesale cost-of-funds rate Settlement charges and aggregate amount of other fees or required payments Disclosures regarding mortgage originator compensation, escrows, creditor s partial payment policy, negative amortization, hybrid rate reset notice, required flood insurance and appraisals HC# Hudson Cook, LLP

2 Mandatory escrow accounts for most first lien closed-end mortgage loans New force-placed insurance rules TITLE IX INVESTOR PROTECTIONS AND IMPROVEMENTS TO THE REGULATION OF SECURITIES Subtitle D Improvements to the Asset-Backed Securitization Process 1. Regulation of Credit Risk Retention Section a. Effective Date: Regulations issued under this section will become effective: i. With respect to securitizers and originators of asset-backed securities backed by residential mortgages, one year after the date on which final rules are published in the Federal Register ii. With respect to securitizers and originators of all other classes of asset-backed securities, two years after the date on which final rules are published in the Federal Register b. Federal banking agencies and SEC are to issue regulations to require any securitizer to retain an economic interest in a portion of the credit risk for any asset sold or transferred to a third party. Regulations must be issued no later than 270 days after enactment. c. Also within 270 days after enactment, the Federal banking agencies, the SEC, HUD and FHFA are to issue regulations for the securitization of residential mortgage asset. d. The risk retention rules: i. Will apply to all types of entities, including banks ii. Will prohibit securitizers from directly or indirectly hedging or otherwise transferring credit risk that the securitizer is required to retain iii. Are to require securitizers to retain: 1. At least 5% of credit risk for any asset (1) that is not a qualified residential mortgage and that is transferred or sold through the issuance of an asset-backed security or (2) that is a qualified residential mortgage that is transferred or sold through the issuance of an assetbacked security if one or more of the assets that collateralize the assetbacked security are not qualified residential mortgages; OR 2. Less than 5% of the credit risk for an asset that is not a qualified residential mortgage that is transferred or sold through the issuance of an asset-backed security if the originator meets certain underwriting standards to be established by the federal banking agencies iv. Need not require securitizers to retain any part of the credit risk for an asset that is sold or transferred through the issuance of an asset-backed security by the securitizer if all of the assets that collateralize the asset-backed security are qualified residential mortgages v. May provide a total or partial exemption from the credit risk retention requirement for the securitization of an asset that is issued or guaranteed by the United States or an agency of the US (that would include loans guaranteed or insured by FHA and VA, but Fannie and Freddie deemed not to be US agencies), or that is issued or guaranteed by any state vi. Are to address allocation of risk retention obligations between a securitizer and an originator where a securitizer purchases assets from an originator; establish 1 Section references refer to sections of the Dodd-Frank Wall Street Reform and Consumer Protection Act. HC# Hudson Cook, LLP

3 asset classes and underwriting standards that specify characteristics of loans within each asset class that indicate low credit risk e. Exemptions from the entire section, including allocation of risk retention obligations: i. Farm Credit system institutions and other federal programs ii. Asset-backed securities collateralized solely by qualified residential mortgages 1. This term is to be defined for purposes of this exemption by the banking agencies, SEC, HUD and FHFA, but the term must be no broader than the definition of qualified mortgage defined in TILA 129C(c)(2), 2 which is one that: i. The regular periodic payments do not: 1. Result in an increase of the principal balance, or 2. Allow the consumer to defer repayment of principal. ii. Does not result in a balloon payment, which is defined as a payment where a scheduled payment is more than twice as large as the average of earlier scheduled payments iii. Income and financial resources to support the application for the loan are verified and documented iv. For fixed rate loans, underwriting is based on fully amortizing payment schedule and takes into account taxes, insurance and assessments v. For adjustable rate loans, underwriting is based on maximum rate permitted during the first five years and a payment schedule that fully amortizes the loan amount over the loan term and takes into account taxes, insurance and assessments. vi. Complies with any Board 3 guidelines on DTI or similar measures of ability to repay vii. Total points and fees (defined in the same way as for high-cost loans under the Act) do not exceed 3% of total loan amount [NOTE: This provision uses the term total loan amount which under HOEPA was defined to mean an amount that could be lower than the amount financed. The Act changes the definition of a high-cost loan under HOEPA and compares the total points and fees to the total transaction amount. The total transaction amount is not defined, but there is no indication that it should not be given its everyday meaning. What the term total loan amount means in this section of the Act is unclear.], and viii. The term does not exceed 30 years ix. When the term qualified mortgages is used outside of the context of the ability to repay, the Board is directed to set the standards for reverse mortgage loans that would be considered qualified mortgages. 2. An asset-backed security that is collateralized by tranches of other asset-backed securities will not be exempt under the qualified mortgage exemption 2 3 This reference should be to Section 129C(b)(2) of TILA as added by Section 1412 of the Dodd-Frank Act. The term Board currently refers to the Federal Reserve Board, but upon the designated transfer date, the powers attributed in this outline to the Board will be transferred to the Bureau of Consumer Financial Protection. The term FRB refers to duties the Federal Reserve Board will retain even after the CFPB is established. HC# Hudson Cook, LLP

4 3. An issuer will be required to certify each issuance of an asset-backed security collateralized exclusively by qualified residential mortgages 2. Disclosures and Reporting for Asset-Backed Securities: The SEC is to adopt regulations to require issuers of asset-backed securities to disclose certain information for each tranche or class of security 3. Reps and Warranties: The SEC is to issue regulations on the use of representations and warranties in the market for asset-backed securities 4. Exempted Transactions: Eliminates the exemption from the Securities Act of 1933 for transactions involving the offer or sale of first lien mortgages 5. Due Diligence Analysis and Disclosure: The SEC must issue rules within 180 days of enactment relating to the registration statement that is required of an issuer of an asset-backed security. The rules will require an issuer to perform a due diligence review on the assets underlying the asset-backed security and to disclose the nature of the review. 6. Financial Services Oversight Council is instructed to study the macroeconomic effects of the risk retention requirements Subtitle C Specific Bureau Activities TITLE X BUREAU OF CONSUMER FINANCIAL PROTECTION 1. Combined Mortgage Disclosures Section 1032(f) a. The CFPB is directed, within one year of the designated transfer date, to propose model disclosures that combine the disclosures required under the Truth in Lending Act and Sections 4 (the HUD-1 settlement statement) and 5 (the closing costs information booklet and the good faith estimate) of the Real Estate Settlement Procedures Act into a single, integrated disclosure b. [NOTE: This directive is repeated in Sections 1098 and 1100A, which contain conforming amendments to the Real Estate Settlements Procedures Act and the Truth in Lending Act, respectively.] Subtitle H Conforming Amendments 1. Alternative Mortgage Transaction Parity Act Section 1083 a. The scope of the Parity Act will be significantly limited b. Effective on the designated transfer date c. Alternative mortgages are restricted to variable rate or renegotiable rate transactions [NOTE: Loans with balloon payments, interest-only payments, negative amortization or other alternative mortgage features will not be considered alternative mortgage transactions any longer unless they also have a variable rate or renegotiable rate feature as well.] d. Effect of preemption is limited to those state laws that prohibit a type of variable rate or renegotiable rate transactions HC# Hudson Cook, LLP

5 e. The CFPB is instructed to review the current Parity Act regulations issued by the Comptroller of the Currency and the National Credit Union Administration to determine if they are fair and not deceptive and then issue its own regulations f. Transactions that occur before the designated transfer date will not be affected by this provision 2. Home Mortgage Disclosure Act Section 1094 a. Extensive new data must be captured for each application and transaction b. Effective date: The new data (other than age of applicants) may not be required to be reported earlier than the first January 1 that occurs nine months after the CFPB issues regulations in final form c. Will require reporting of the following additional information regarding mortgage loan applications: i. Age of applicants, ii. Total points and fees, iii. Difference between the APR and a benchmark rate (apparently to be determined by the CFPB), iv. Length of any prepayment period, v. Value of the real property securing the loan, vi. Length of any introductory rate period, vii. Presence of interest-only or negative amortization periods, viii. Term of the transaction, ix. The channel through which the application was received, such as retail, broker or other, x. And, as the CFPB may determine to be appropriate: 1. The SAFE Act unique identifier for the loan originator 2. A universal loan identifier 3. The parcel number of the property to be pledged 4. The credit score of the applicants, and 5. Any other information the Bureau may require. d. The CFPB may also require the reporting of this information with respect to loans sold by each institution and may require the reporting of the class of purchaser of the loans e. The CFPB may specify the format for information reported under HMDA, as opposed to continuing to permit institutions to report the information in the form in which it is maintained 3. Omnibus Appropriations Act, 2009 Section 1097 a. Effective on the designated transfer date b. Transfers from the FTC to the CFPB rulemaking authority related to unfair and deception practices in mortgage lending, including mortgage modification and rescue scams. c. Clarifies that state attorneys general may bring civil actions to enforce rules promulgated by the CFPB under this authority 4. Secure and Fair Enforcement for Mortgage Licensing Act Section 1100 a. Delays the effective date for the registration of loan originators employed by depository institutions or their subsidiaries with the Nationwide Mortgage Licensing System and Registry until one year of enactment of the Act b. Gives the CFPB the authority to issue rules to implement the registration requirements under the SAFE Act HC# Hudson Cook, LLP

6 5. Adjustments for inflation related to the coverage of the Truth in Lending Act Section 1100A a. Expands the coverage of TILA for non-real estate, non-dwelling secured loans b. Effective on the designated transfer date c. The coverage of loans (or leases) that are not secured by real estate or personal property that is the principal dwelling of the borrower under the Truth in Lending Act is expanded to include amounts financed (or the total contractual amounts for leases) up to $50,000 d. The CFPB is instructed to adjust this amount annually based on increases in the Consumer Price Index for Urban Wage Earners and Clerical Workers Effective Date Section 1400 TITLE XIV MORTGAGE REFORM AND ANTI-PREDATORY LENDING ACT 1. Regulations implementing this Title must be issued in final form within 18 months of the designated transfer date. The designated transfer date is the date on which the CFPB accepts functions from the other federal regulatory agencies. The designated transfer date is to be established within 12 months after the passage of the Act; although the date can be delayed for up to another six months. 2. Regulations must take effect within 12 months after date of issuance. 3. The provisions of this Title take effect when the regulations become effective; however, if a regulation to implement a provision of the Title has not been issued (presumably in proposed form) within 18 months after enactment, then the relevant provision becomes effective 18 months after enactment, even though there are no regulations interpreting the provision. 4. [NOTE: Although the CFPB is ultimately given rulemaking authority for most of the regulations that implement Title XIV, the current federal regulator generally either the FRB or HUD could issue regulations implementing these provisions prior to the designated transfer date.] 5. Exception: Interim final regulations implanting the appraisal independence requirements, which will replace the Home Valuation Code of Conduct, will become effective 90 days after enactment. Subtitle A Residential Mortgage Loan Standards 1. Defines a New Term: Residential Mortgage Loan Section 1401 [Adding TILA 103(cc)(5)] a. Most of the new mortgage reform provisions, including those applicable to mortgage originators, apply to residential mortgage loans. b. Includes all consumer loans secured by a dwelling other than HELOCs or (for most provisions) timeshare plans. Includes closed-end reverse mortgage loans. c. The term residential mortgage loan should not be confused with the current TILA term: residential mortgage transaction, which still refers only to a purchase money transaction. 2. Creates New Definition of Mortgage Originator Section 1401 [Adding TILA 103(cc)(2)] HC# Hudson Cook, LLP

7 a. Does not amend the SAFE Act definition of loan originator, but defines persons that must be licensed or registered under SAFE for purposes of TILA b. Definition differs from SAFE as follows: i. Includes a person that takes an application, assists a consumer in obtaining or applying for a residential mortgage loan offers or negotiates terms of a residential mortgage loan ii. Assists is new criteria iii. Replaces and in the SAFE Act with or. [NOTE: HUD and the states had generally read the and in the SAFE Act to mean or, but the federal banking agencies had not.] iv. Includes an exemption for persons engaged in merely clerical or administrative functions, but does not include the requirement, which is in the SAFE Act, that such persons be supervised by a licensed or registered person v. Excludes servicers or their employees agents or contractors that work on loan modifications or refinances vi. [NOTE: It will be interesting to see how this new definition changes the proposed rules issued by HUD that, if they become final, would require servicer employees to be licensed or registered if they take applications for loan modifications or offer or negotiate the terms of a modification. Whether or not the final rules to be issued by HUD (or perhaps the CFPB if HUD decides not to act) reflect the new definition of mortgage originator in TILA, the final rules will not affect any state law that has been enacted that specifically requires the licensing of such employees. Although, a favorable ruling from HUD or the CFPB might influence states to revise their statutes.] 3. Establishes a Duty of Care for Mortgage Originators Section 1402 [Adding TILA 129B(a) and (b)] a. This duty of care for a mortgage originator is limited to two requirements: i. Be licensed or registered as a mortgage originator pursuant to the SAFE Act ii. Include on all loan documents the unique identifier provided by the Nationwide Mortgage Licensing System and Registry 4. Prohibition on Steering Incentives Section 1403 [Adding TILA 129B(c)] a. Prohibits compensation paid to a mortgage originator to be based on the terms of the loan, other than the amount of principal. [NOTE: Apparently compensation may not be based on factors such as: i. The type of loan, i.e. fixed vs. adjustable ii. The lien position iii. Whether the loan is for a purchase money transaction or a refinancing iv. Whether the loan is conforming or non-conforming] b. No person other than the consumer can pay a mortgage originator any fee other than a bona fide third party charge unless: i. The mortgage originator receives no compensation directly from the consumer ii. The consumer does not pay any discount points or origination points or fees upfront, other than bona fide third party charges not retained by either the mortgage originator, creditor or an affiliate of either iii. The Board may either waive the prohibition in (ii) above or provide exemptions if it finds that the waiver or exemption is in the interest of consumers and the public. HC# Hudson Cook, LLP

8 iv. [NOTE: Unless the Board provides a waiver or exemption, this provision will prohibit creditor paid compensation to loan brokers or incentive compensation to in-house loan officers unless the borrower is offered a no-point loan. It also further discourages the use of affiliated service providers. c. However, the rules of construction discussed below permit a consumer to pay a mortgage originator s fees by having the fees added to principal or the rate (i.e. a YSPtype payment), provided that the fees don t vary based on the means of payment. d. Regulations: Directs the Board to prescribe regulations to prohibit certain mortgage originator practices, including: i. Steering consumers to mortgages they cannot repay or that have predatory characteristics or effects (e.g. equity stripping, excessive fees, or abusive terms) ii. Steering consumers from a qualified mortgage (defined in 129C(b)(2)) to a nonqualified mortgage iii. Abusive or unfair lending practices that promote disparities among consumers of equal credit worthiness but of different race, ethnicity, gender or age iv. Mischaracterizing a consumer s credit history, the residential mortgage loans available to a consumer, or the appraised value of the property v. Discouraging a consumer from seeking a mortgage from another originator if the mortgage originator is unable to recommend a loan that is not more expensive than a loan for which the consumer qualifies. [NOTE: This provision appears to require mortgage originators to know whether a borrower could qualify for a better mortgage product from any other originator, a standard that would be difficult to meet. In practice, however, mortgage originators can avoid this conundrum by not discouraging applicants from seeking mortgages from other originators.] e. Rules of Construction: This subsection does not: i. Permit any YSP or similar compensation that would allow total direct or indirect mortgage originator compensation to vary based on loan terms, other than the amount of principal ii. However, the subsection also does not restrict a consumer s ability to finance origination fees or costs through principal or rate or a mortgage originator s right to receive such fees provided the fees do not vary based either on loan term, other than amount of principal, or the consumer s decision about whether to finance such fees or costs. Thus, mortgage originators may be paid through the rate as long as their total compensation does not vary based on the payment method. [NOTE: The intended effect of this and the other antisteering rules may be to drive broker compensation away from creditor-paid compensation to direct agreements between the applicant and the broker regarding the broker s compensation. If a consumer agrees to pay compensation to a broker, then the compensation can either be financed as part of the principal, or can be paid through the interest rate on the loan, i.e. a YSP-type payment. Also, having the applicant agree to pay the broker, either directly or through the principal of the loan or the interest rate, eliminates the prohibition on upfront points and fees, including bona fide fees paid to an affiliate of the creditor or mortgage originator.] iii. Limit or affect amount of creditor compensation upon sale of a consummated loan to a subsequent purchaser iv. Prohibit incentive payments to a mortgage originator based on the number of mortgage loans originated within a specified period of time. HC# Hudson Cook, LLP

9 5. Penalties for Mortgage Originators Section 1404 [Adding TILA 129B(d)] a. A mortgage originator that fails to abide by these requirements may be subject to the same penalties as provided for creditors under Section 130 of TILA b. However, the maximum liability for a mortgage originator under Section 130 is limited to the greater of actual damages or three times the total amount of direct and indirect compensation involved in the violation, plus costs and attorneys fees 6. Defense to Foreclosure/Assignee Liability [NOTE: This appears to be just a right of set-off or recoupment, not a complete defense] Section 1413 in Subtitle B of the Act [Adding TILA 130(k)]) a. In a foreclosure or collection action, a consumer may assert a violation of the mortgage originator compensation provisions as a defense by recoupment or setoff in the amount of damages to which a consumer would be entitled for the violation b. Such a claim may be raised against the creditor, assignee or other holder c. Such a claim may be raised at any time, even if the time limit on a private action for damages, which is now three years for these provisions, has expired. d. When a set-off or recoupment claim is brought after the three-year statute of limitations has expired, the amount of set-off or recoupment may not exceed the amount that would have been computed up to the day preceding the expiration of the statute of limitations. 7. Discretionary Regulatory Authority Section 1405 [Adding TILA 129B(e)] a. Gives Board the authority to prohibit acts or practices related to residential mortgage loans that are abusive, unfair, deceptive, or predatory b. Gives Board the authority to exempt or modify disclosure requirements for any class of residential mortgage loans 8. Study of Shared Appreciation Mortgages Section 1406 a. HUD to conduct comprehensive study to determine appropriate regulatory requirements for shared appreciation mortgages Subtitle B Minimum Standards for Mortgages 1. Coverage: Most of the new minimum mortgage standards apply to residential mortgage loans, which are closed-end consumer mortgage loans other than timeshare plans. See definition in Section Some rules, as noted below, exempt reverse mortgage loans and bridge loans. 2. Ability to Repay Section 1411 [Adding TILA 129C(a)] a. [NOTE: These rules are similar to the FRB rules adopted in June 2008 for higher-priced mortgage loans. However, these rules apply to a significantly larger number of loans and do not have a presumption of compliance based on processes used by the lender. Reverse mortgage loans and bridge loans with a term of 12 months or less are excluded. The only safe harbor is for a qualified mortgage.] b. In connection with a residential mortgage loan, creditors must make a reasonable and good faith determination based on verified and documented information that, at the time of consummation, the consumer has a reasonable ability to repay the loan, including taxes, insurance and assessments. HC# Hudson Cook, LLP

10 c. Multiple loans if the creditor knows or has reason to know that the consumer will obtain multiple loans on the same dwelling, the creditor must base the ability to repay determination on the combined payments of all loans on the same dwelling. d. Ability to repay determination must include consideration of: i. Credit history, ii. Current income, iii. Expected income that the consumer is reasonably assured of receiving, iv. Current obligations, v. DTI or residual income, vi. Employment status and vii. Other financial resources other than equity in the dwelling or real property securing the loan. e. Creditor must verify income and assets using W-2, tax forms, payroll receipts, financial institution records or other third party documents that provide reasonably reliable evidence of income or assets. i. Income history must be verified using IRS tax records or another means approved by the Board. ii. Verification of income and assets may be waived by the relevant government agency for government guaranteed or insured loans used for refinancing provided: 1. The consumer is not more than 30-days past due, 2. The principal balance is not increased, except by fees and charges allowed by the government agency, 3. Total points and fees (as defined for high-cost mortgage loans) for the refinancing do not exceed 3% of the new total loan amount 4, 4. The new interest rate is lower, unless the borrower is refinancing from an adjustable rate to a fixed rate pursuant to guidelines established by the government agency, 5. The new loan is fully amortizing in accordance with regulations published by the government agency, 6. The new loan does not have a balloon payment, and 7. Both the old loan and the new loan satisfy all requirements of the government agency. f. For nonstandard loans: i. For variable rate loans that defer repayment of principal or interest, creditors must use a fully amortizing repayment schedule ii. For a loan that permits or requires interest-only payments, creditors must use a payment amount that fully amortizes the loan by its maturity date iii. Any balance increase that may occur due to negative amortization must be taken into consideration iv. Creditors may assume: 1. Loan proceeds are fully disbursed at consummation, 2. The loan is repaid in substantially equal payments, unless the contract requires more rapid repayment (such as a balloon payment), in which case the calculation shall be made in accordance with regulations issued by the Board for any loan with an annual percentage rate that does not exceed the average prime offer rate for a comparable transaction as of the date the interest rate is set, by 1.5 points for a first lien or by See page 3 for a discussion of the meaning of total loan amount. HC# Hudson Cook, LLP

11 points for a subordinate lien; or, for other loans, using the contract repayment schedule, and 3. The interest rate for the entire term is a fixed rate equal to the fully indexed rate at the time of the loan closing, without considering any introductory rate. v. When a creditor refinances a non-delinquent hybrid loan (which term is undefined 5 ) it holds into a standard loan (also an undefined term) in which there would be a reduction in the monthly payment, the creditor may: 1. Consider the mortgagor s good payment history on the existing mortgage, 2. Consider if the new loan would prevent a likely default and give such concern a higher priority as an acceptable underwriting practice, and 3. Offer rate discounts and other favorable terms that would be available to new customers with high credit ratings based on such underwriting practice. 4. [NOTE: The Act does not explain whether these considerations may completely replace the otherwise required ability to repay determination or whether they are simply additional factors to be taken into consideration in making a determination of the applicant s ability to repay.] vi. Fully-indexed rate means the index rate at the time the loan is made plus the margin that will apply after any introductory interest rate expires. vii. If documented income, including income for a small business, is a repayment source for a loan, a creditor may consider the seasonality and irregularity of such income. 3. Safe Harbor and Rebuttable Presumption for the Ability to Repay Section 1412 [Adding TILA 129C(b)] a. [NOTE: Although the title of this section in the Act is Safe Harbor and Rebuttable Presumption the language of this section permits creditors and assignees to make a presumption, but does not explain whether this presumption is a safe harbor or whether this presumption is rebuttable, and provides no indication whether the permitted presumption can be relied upon or how it can be challenged.] b. A creditor or assignee may presume that a consumer has the ability to repay if the loan is a qualified mortgage. c. Definition of qualified mortgage i. The regular periodic payments do not: 1. Result in an increase of the principal balance, or 2. Allow the consumer to defer repayment of principal. ii. Does not result in a balloon payment, which is defined as a payment where a scheduled payment is more than twice as large as the average of earlier scheduled payments iii. Income and financial resources are verified and documented iv. For a fixed rate loan, underwriting is based on the fully amortizing payment schedule and takes into account taxes, insurance and assessments 5 However, hybrid adjustable mortgage loan is defined in Section 1413 of the Act as a loan secured by the consumer s principal dwelling with a fixed interest rate for an introductory period that adjusts or resets to a variable interest rate thereafter. HC# Hudson Cook, LLP

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