In light of changes in the market and to watch interest rate risk, our loan officers are going to start doing 10 year balloons on loans that amortize 15+ years. Currently, the payment example in our ARM disclosures is generally for 15 or 30 year amortizations. In looking at the commentary to 226.19(b)(2)(viii(A)-5, we don't need to change that. Am I reading this correctly? So, I'm thinking we may not really need to change our ARM disclosures at all - everything will be the same, except that the maturities will now be shorter than the amortizing period.
Thank you for your help!
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