[elebra]

I just read Jack’s blog article about the ARMS with no look back period. Our rates currently adjust on the anniversary date of the note. If we adjust our rate based on an index prior to the anniversary date, our rate will still not adjust until the anniversary date. Do our notes need to be modified?

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[rcooper]

It sounds like you have a look back period. You’ll just need to make sure notes originated on or after January 10, 2015 include a look back period that allows you time to send the 60 day notice. Loan prior to January 10, 2015 you can continue to send the 25 day notice if your look back period is not sufficient to send the 60 day notice.

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