We are a thrift institution that uses Harland and Wolters Kluwer. We use the simple interest calculation (365 accrual method) for mortgage loans. Our examiners are stating that if we use this method, it needs to be stated on the note. We have referred them to Reg. Z, 226.8 which does not state that the payment method needs to be on the note. They are saying that is for a bank not a thrift. Does anyone have any experience with this?
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Thanks