We probbaly need more information here to properly answer your question. I am assuming that by ARM disclosures you are referring to early ARM disclosures given at application? The answer would be yes. Remember, the 210 day period is associated with the Initial ARM notice (1026.20(c)), that still needs to be given the first time the ARM adjusts, even if that's after a year.
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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.