After looking at the rule more closely, I reazlie that the 25-120 unique timeframe for loans with shorter than 45 day look-back periods is a permanent exception for all loans originated prior to 1/10/15. So, no need to address these loans, only to be sure to originate loans with 45 day or longer look back periods as of 1/10/15. My mistake.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.