Loans with no look back or a look back less than 45 days originated prior to January 10, 2015 are and will remain subject to the 25/120 day timeframe. Loans with look back periods of 45 days or more must use the 60/120 day timeframe beginning January 10, 2014. All ARMs (with the exception of frequently adjusting and ARMs adjusting soon after consummation) loans established after January 10, 2015 (regardless of look back period) are subject to the 60/120 timeframe. So you basically have a year after the effective date to make sure your ARM programs include a sufficient look back period to meet the 60/120 timeframe by January 10, 2015.
