RR Joker - By any chance did you resolve your question? I have the same issue--thinking we would not use the first column as we don't have "introductory" or teaser rates. If the first column is not used, then would you show the fixed rate-there would be nothing for MAXIMUM EVER--and just put NA for principal payment and show the interest only payment and a Final Balloon?

Also, the term Maximum Ever was an error that has now been changed to First Increase (I think). However, either form will be granted safe harbor.

Afraid you were going to say that!! For a fixed rate what would you put in interest rate for MAXIMUM EVER? Nothing, NA, blacked out, marked out - pick one Would you just show the max rate under the contract (i.e. 18%) We were talking fixed-rate, weren't we? ? If we don't have a 3/1 ARM as an example, there wouldn't be a First Increase or Adjustment. Also how would you show a single pay? We could show the rate but there wouldn't be payments so the full amount just goes in Final Balloon Payment? yes, unless you require interest payments This is just for fixed; still fuzzy about variable rate loans.

For fixed-rate balloon loans that we offer, there is no intro rate and no max ever (or first increase). The column headings doesn't fit the product.

Why wouldn't you be using model H-4(E), with only one column for "Rate & Monthly Payment"?

In regard to the December 22, 2010 Interim Rule published by the Fed - I went to the Federal Register site, and I can't see where it has been published in the FR yet. I went to the ABA site, they also do not have it in there "Regulatory Proposals" calendar. I went to the FRB website - looked under proposals for Regulation Z - it isn't there either. I guess I am looking for validation that this is in fact what we should try to follow for 5/1 ARMs and interest-only loans. I understand the 12/22 rule isn't mandatory until 10/01/2011, but in some ways it would be easier to do now.

Hi, We did a seminar on this topic last week and the presenter stated that, under the escrow payments section, the mortgage insurance premium disclosed in each column should reflect: "..The estimated amounts of mortgage insurance premiums should be based on the declining principal balance that will occur as a result of changes to the interest rate that are assumed for purposes of disclosing those rates under 226.18(s)(2) and accompanying commentary..." We have always used constant balance mortgage insurance premium, so this would be a big change for us. Is everyone else reading the Reg. the same way and using declining balance mortgage insuranc?

True, I mis-stated that above and couldn't go back and edit it later. My mind really wasn't on plain ole fixed rate amort loans, but that's what I said! Sorry. I was thinking and working on interest only balloon loans and construction loans, but with no rate increases...I apologize for that incorrect statement above!

I'm talking about mortgage insurance premiums. There is a set factor for calculating the monthly premium amount, and it can be based on the original loan balance (constant) or the current monthly loan balance (declining). Is that what you were thinking?

If we have a consumer purpose loan that is secured by bare land--theorectically this wouldn't need a rate cap since there isn't a dwelling right? If so, how would you disclose the maximum in 5 years and maximum ever if no rate cap? Not sure if we do this--just trying to think through all scenarios. Thanks!