The regulation says that the .20(c) notice "shall be provided to consumers as soon as practicable, but not less than 25 days before the first payment at the adjusted level is due, for the first adjustment to an ARM if it occurs within 60 days of consummation and the new interest rate disclosed at consummation pursuant to § 1026.20(d) was an estimate."
There's nothing in there about 210 days.
On the other hand, there is something in the timing requirement for the initial rate change notice under 1026.20(d) that mentions 210 days: "If the first payment at the adjusted level is due within the first 210 days after consummation, the disclosures shall be provided at consummation." And THAT notice can be based on an estimate. In paragraph .20(d)(2), we read: "If the new interest rate (or the new payment calculated from the new interest rate) is not known as of the date of the disclosure, an estimate shall be disclosed and labeled as such. This estimate shall be based on the calculation of the index reported in the source of information described in paragraph (d)(2)(iv)(A) of this section within fifteen business days prior to the date of the disclosure."
And for whatever it's worth, your small servicer status buys you nothing with regard to these disclosures.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8