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I am trying to figure out how we should handle our rate lock dates, I have been reviewing section 1026.37(a)(13), but am still confused. We do a lot of ARM loans in which we don’t really have have a rate lock, we honor the rate that was disclosed at the time of application. From what I have read I think we should set our rate lock date to be 90 days out in this instance, and then the all other estimated costs will be 10 days.
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