We have just made a change to our loan rate sheet and went from 30 ARM disclosure possibilities (when done at 10, 15, 20, 25 and 30 year amortizations) to a possibility of around 130 with the new combination of rates and margins.

I want to make sure I am reading this right and not missing anything. Regulation Z says that the disclosures do not have to be based on the term or maturity of the loan. Instead the disclosures for ARMs may be based on maturity or amortizations of 5, 15, and 30 years. A 1 to 10 year amortization would be given a 5 year disclosure, 11 to 20 year amortization would be given a 15 year disclosure and amortizations over 20 years would be given a 30 year disclosure.

In this case there would be three disclosures (5, 15 and 30 years) for each combination of rate and margin. Is that correct?

Thanks

That's correct, but the variance in a margin does not constitute a separate ARM program

Got it.

Thanks Dan.