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#1094528 - 12/09/08 09:56 PM Variable Rate????
mzachau, CRCM Offline
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mzachau, CRCM
Joined: Oct 2006
Posts: 470
San Francisco
We are offering a loan product where the borrower will receive a rate for the first five years, then adjust to a higher rate (ex: 5.25 to 6.25)for the remainder of the term. The rate adjustment is fixed and is not based on an index. Would this still be considered an ARM loan requiring Adjustable rate disclosures?

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Lending Compliance
#1094534 - 12/09/08 10:00 PM Re: Variable Rate???? mzachau, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Refer to the Commentary to 226.17(c)(1) #11.
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David Dickinson
http://www.bankerscompliance.com

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