08-EF-1: FFIEC: Hybrid ARM Illustrations

Recently, the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (Fed), Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS) (collectively, the FFIEC Agencies) issued “Illustrations of Consumer Information for Hybrid Adjustable Rate Mortgage Products” (“Illustrations”) in order to supplement the interagency subprime mortgage guidance issued by the same five agencies last year. The illustrations, though not mandatory, may be adopted in full or in part by credit unions to educate potential borrowers on the potential pitfalls that accompany the benefits of hybrid ARM products.