Sorry - brain already on vacation. I am making a 7/1 ARM loan. Loan date is 2/28/11 and first pyt date is 4/1/11. Future interest rate changes will be in March and future payment change dates will be in April. The Interest rate can first change on 3/1/18 with corresponding pyt change on 4/1/18. Should the "Maximum during First Five years" interest rate date disclosed on the TIL be the loan date of 2/28/11, 3/1/12 (the first potential interest rate adjustment date if not constricted by the fixed interest rate and pyt for first 7 years, or 3/1/2016?

Thank you in advance.

Our doc prep system is indicating the Maximum During the First Five Years as the closing date. Since it is a 7-1 ARM obviously this is the same rate during the first five. The last column then indicates the Maximum Ever.

226.18(s)(3)(ii)(B) indicates creditors should disclose the earliest date that the interest rate becomes effective.

Just my opinion. Hope it helps.
Regards,