You are correct. The 210-240 notice is intended to give the borrower notice that the rate will be changing and to give them an estimate of what that rate will change to (if you know what that rate will be at the time you make the initial/210-240 notice you will need to put it in, but most creditors won’t know the rate this far in advance so an estimate is sufficient – see the details of 1026.20(d)). This would ideally give them time to shop around for a new loan if they can’t afford the new rate.
