There are three circumstance in which the 36 month disclsore is not required. They are listed in 1026.7(b)(12)(i)(F)(2). It appears that the second exemption may apply in this case:
( ii ) The estimated monthly payment for repayment in 36 months, as described in Appendix M1 to this part, after rounding as set forth in paragraph (b)(12)(i)(F)( 1 )( i ) of this section that is calculated for a particular billing cycle is less than the minimum payment required for the plan for that billing cycle;
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