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#1656507 - 01/26/12 06:16 PM Separate ARM Program for Different Indices
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
If the rates on our ARM program are sometimes based on a Treasury index and sometimes based on LIBOR, do we need separate program disclosures if everything else is the same? Could we have one disclosure that says the index is either Treasury or LIBOR?
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Lending Compliance
#1656646 - 01/26/12 07:53 PM Re: Separate ARM Program for Different Indices Deena
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Each index used would constitute a separate program and you would need a disclosure for each program.
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#1656951 - 01/27/12 02:01 PM Re: Separate ARM Program for Different Indices Deena
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
Thanks, Dan. That's how we've always done it, but each year I second guess myself.
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