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ARM Program Disclosure

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  • March 22, 2017 at 3:23 pm EDT #10786
    mdunker
    Member

    we are in the process of implementing a construction to perm loan product. My question is as far as the ARM Program Disclosure, under the section how your interest rate can change what would the fixed period be. we have a construction period for 6 months and the loan would adjust every 12 months. Would it need to state 18 months or 12 months?

    March 29, 2017 at 10:01 am EDT #10805
    rcooper
    Member

    We recommend that you disclose the first rate adjustment at 18 months and disclose subsequent rate adjustments at the regular 12 month frequency.

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