Reply To: Early ARM Disclosure

Mary Frances

We have gone back and read the commentary for 1026.19(b)(2) 1 & 2 and we are still confused. We have a Rate Sheet Matrix that will allow a decrease or increase of the rate. Since we do not need a separate disclosure for each rate then what rate would we use in the ARM Disclosure? Would we use the highest rate possible after adjustments per our Rate Sheet Matrix?