2.14.7 or Higher - Reg F Recent Validation Notice Information Changes

2.14.7 or Higher - Reg F Recent Validation Notice Information Changes

Regulation F Most Recent Validation Notice Information Changes in Beyond ARM


Beyond Build 2.14.7 or higher
Beyond Release Date - Oct 21, 2021
Article Published Date - Oct 21, 2021
Download PDF Version Here

Purpose 

The purpose of this document is to provide a clear understanding of how the new CFPB Model Form Validation Notice and Beyond will work together. You will learn what fields in Beyond belong on the Validation Notice and where they are supposed to be mapped to be displayed. 

Here is a helpful Model Validation Notice and Mapping Fields PDF that shows the descriptive fields needed in the Model Validation Notice. Please note that you will need to download this PDF to view the descriptive fields. 

In Beyond version 2.14.7, we made additional changes to the Validation Screen, Other Charges, Extra Other Charges, and we’ve added some calculated amounts listed below. These changes were made to accommodate some scenarios that were brought to our attention like:
  1. Having to resend the Validation Notice a second time after payments have been posted to the account. 
  2. If any interest has been accrued prior to the time of placement with the agency and if interest was accrued prior to or after the itemization date, the validation notice must reflect the correct itemization.

Manually Adjusting Account Amount Fields

**To ensure that the validation notice shows the proper amounts we strongly recommend that ALL users of the system DO NOT manually adjust balances from the Account Work Screen.**

All changes to account balances should be done by posting transactions to the account, including adjustments. These transactions can be posted in the Enter Payments menu option under Payment Clerk. 

If someone tries to manually edit an account balance from the Account Work Screen, a warning message will be displayed before the change is saved.




New Validation Screen


There are 4 new fields on this screen

  1. Interest Before Itemization date - This field stores any interest that was accumulated BEFORE the itemization date. This value is stored in VALIDATION@.INTERESTBEFORE.
  2. Interest After Itemization date - This field stores any interest that was accumulated AFTER the itemization date up to the date of referral. This value is stored in VALIDATION@.INTERESTAFTER.
  3. Fees Before Itemization date - This field stores any fees that were added BEFORE the itemization date. This value is stored in VALIDATION@.FEESBEFORE.
  4. Fees After Itemization date - This field stores any fees that were added AFTER the itemization date up to the date of referral. This value is stored in VALIDATION@.FEESAFTER.
* As an agency, if you are using the new interest fields before and after the itemization date, you will need to make sure that the interest accrual date is set correctly. If the agency is using the Date of Service for interest to accrue and the creditor is also assigning interest, you could be doubling the interest charged. 

There is a new list of validation information that will show the following information added to the validation screen: 
  1. Letter code
  2. Date the notice was requested
  3. End of the validation date
  4. Total payments/credits
  5. Total fees
  6. Total interest that was printed on that letter 
This should be used only for reference for collectors to be able to discuss with the consumer what was printed on the letter that they received. If there have been multiple validation notices sent, they will all be present here as well.


Other Charges and Extra Other Charges

For Regulation F we have modified how Other Charges and Extra Other Charges will affect the balances on the Validation Notice. We have given you the ability to mark these fields as being either interest, fees, or other. 

For clients/creditors not set up to use Extra Other

There is a new Validation Ltr Flag to determine how Other Charges will be used in relation to the Validation Notice.

     


For clients/creditors set up to use Extra Other

We updated this screen altogether to make it easier to read and to know what settings go with what Extra Other Field. 

Each Extra Other Charge is marked as a new Validation Notice Field which will determine how it will be used in relation to the Validation Notice.




How the Validation Screen Maps to the Validation Notice






New Calculated Totals for Validation Notice

We have added three new calculated amounts to the 1st Alert LTRDOWN file. For those who do not use 1st Alert for letters, we have created functions that can be used in Report Designer and Advanced Inquiry to get the amounts needed. The following three are the amounts, the functions, and how they are calculated. Learn more about Generate Test Letter File and Convert Letter File to CSV. 

1. Total Interest  

This calculates the total amount of interest that has been accrued, accumulated, and paid after the itemization date. The function for Advanced Inquiry is GET_ITEMIZATION_INT. 

You will see this in the query wizard in both COLLACCT@ and VALIDATION@ tables. They will show up as the following fields:

  • COLLACCT@

    • [ACCTITEMIZATIONINTEREST]

  • VALIDATION@

    • [ITEMIZATIONINTEREST]


These are calculated using any field that is considered an interest amount. The standard interest fields will be looked at along with any other charges/extra other charges field that has been marked as Interest. 

For example, if you are using Extra Other and you flag Extra Other 2 as being preassigned interest or something similar, the system will add that field into the interest calculations.

Here is how we are calculating the Total Interest:

Accumulated Interest (AI) + Accrued Interest (Int) + Sum of all transactions posted to interest + All Other Charges/Extra Other Charge set with Interest Flag + Total adjustments to interest - VALIDATION@.BEFOREINTEREST

2. Total Fees 

This calculates the total amount of fees that has been added and paid after the itemization date. The function for Advanced Inquiry is GET_ITEMIZATION_FEES. You will see this in the query wizard in both COLLACCT@ and VALIDATION@ tables. They will show up as the following fields:

  • COLLACCT@

    • [ACCTITEMIZATIONFEES]

  • VALIDATION@

    • [ITEMIZATIONFEES]


These are calculated using any field that has been flagged as being a fee amount. For example, if you are using Extra Other and you flag Extra Other 2 as being set to collection fee, the system will add that field into the fees calculations.


Here is how we are calculating the Total Fees:


Other Charges/Extra Other charges (OC) with the Fee Flag + Attorney’s Fees (AF)+ Court Costs (CC)+ Sum of all transactions posted to OC with fee flag, AF, CC + total adjustments to fees - VALIDATION@.BEFOREFEES


3. Total Payments/Credits 

This calculates the total amount of payments that have been applied after the itemization date. The function for Advanced Inquiry is GET_ITEMIZATION_PMTS. You will see this in the query wizard in both COLLACCT@ and VALIDATION@ tables and will show up as the following fields:


  • COLLACCT@

    • [ACCTITEMIZATIONPAYMENTS]

  • VALIDATION@

    • [ITEMIZATIONPAYMENTS]


This is calculated by adding all payments that have been applied to the account. Here is how we are calculating the Total Payments:

Sum of all transactions posted to account + VALIDATION@.PAYMENTSCREDITS



New Business Mapping Use Case Scenarios for Validation Information

Scenario 1

When a creditor uses the Transaction Date as the itemization date and their placement includes the following amounts:



** This $600 includes the Principal Balance (PB), Interest prior to placement, and a collection fee. It is important to note that if your client provides your file in this manner that you know what “Balance Owed” includes. 

Here is how you would map this data from the client into Beyond. We have provided the creditor field names, Beyond fields, and the amounts set for those fields in Beyond.



Scenario 2

When the creditor is using any date that is NOT the Transaction Date for the Itemization Date and they place the following file:




* In this scenario, it is extremely important to know if this interest prior to placement is Interest added before and/or after the Itemization Date.
** In this scenario, it is extremely important to know if these fees prior to placement are Fees that were added before and/or after the Itemization Date.

Depending on the interest and fees above, there are three options to map this data into Beyond.

Option 1

If interest and fees are all added after the Itemization Date, your mapping will be the same as Scenario 1 above.



Option 2

If the interest and fees are before the Itemization Date your mapping will be like this.



Option 3

Interest and fees have been added both before and after the Itemization Date, but prior to placement with the agency.



We’ve walked you through the changes made for the Validation Information when it comes to Interest and Fees pre- and post-Itemization dates. Now you can use these additional fields to provide accurate data points on the Validation Notice.

Contact Info

Please take a few minutes to look over the latest Release Notes. To schedule an update, reach out to Julie Newson by phone at 801.394.5791 x 269 or email julie@dakcs.com. 

For questions about the REG F: Focus Group, please contact Justin Devine at justin@dakcs.com or call 801.394.5791 x297. 

For questions about Regulation F, you can reach out to our DAKCS Support team by calling or submitting a ticket today.