I understand if the variable rate changes that constitutes a new waiting period (ex 5/1 to 3/1 ARM). Do we still have to wait if the change is in the customer’s favor for example changing the loan program from a 3/1 to a 5/1.
If I’m reading your question correctly, you would still be making a change to the loan product (the information you disclosed under 37(a)(10)), which is a change that would require a new waiting period. I don’t see anywhere in the regulation that there is an exception to the rule if the product change is in the customer’s favor.