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Originally posted in Compliance Masters Group Forum by GVICK:
Example: We have an ARM that closed 6/6/11 annual adjustable rate at NYP. The initial first rate change date passed on 6/6/12 with no change in rate. Since the rate hasn’t changed yet does this loan customer still need to receive the first 240 day rate change notice under the new rules since the actual rate hasn’t changed because the index hasn’t changed or do we ignore the 6/6/12 date since the index hasn’t changed?
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