[Kristin]

We know that we are required to show the historical rate for 15 years, and include the index values, margin and annual percentage rates for that whole period.
The Commentary for 1026.40 states “If the length of the plan is less than 15 years, payments in the historical example need only be shown for the number of years in the term.”

We offer 10 year term products and less so based on above we know our example table will have rows without payment estimates.

Do we start the payment example at the top of the table which is based on the oldest rate – or do we count back from the most recent rate for the period of the loan term?
• The model disclosures don’t seem to capture our scenario, but for a loan with a 10 year draw, and subsequent 5 year repayment it starts at the top.
• Consumer protection mentality seems to push me to want to start at the bottom as it’s going to be based on the most recent rate example, but our vendor is telling us the opposite.

[rcooper]

I agree with your thought process that the more recent payment would be more helpful to the consumer, but based on the examples in the Regulation I agree with your vendor and think you should start from the top.

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