[TheBank]

Question 1. Our TRID ARM loans are priced at prime rate plus a margin. If we do not lock an interest rate, and we have provided the loan estimate, is it permissible for the rate to be updated and changed to reflect a prime rate change at origination provided we disclose the updated rate on the CD 3 days prior to origination if outside APR tolerance or at origination if within APR tolerance?

Question 2. If yes, then if intent to proceed is received prior to the loan estimate expiration, is it permissible to update the rate between the time of the LE and 3 days prior to origination if outside APR tolerance or at origination if within APR tolerance?

[jholzknecht]

Question 1 Yes. The LE explains that before closing your interest rate, points and lender credits can change unless you lock the rate.

Question 2. Yes again, for the same reason.

[Author]

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