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In determining our max 5 year rate for QM for a 3/1 arm with a margin of 2.39%, annual cap of 1%, initial rate of 2.94% based on the current 1 year t bill of .59. Would I base my next change on the fully indexed rate plus the 1%? Or do I base it off of my initial interest rate since it will never go to the rate of 3.98%. I can’t find it in the regulation on how to calculate the max 5 year rate. I see in the ATR that it states to use the fully indexed rate.
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