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#1916789 - 04/23/14 03:39 PM Subsequent ARM Notices Under 1026.20
Wonderofitall Offline
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Wonderofitall
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Posts: 226
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I understand 1026.20 to require two separate notices, a 1026.20(c) payment adjustment notice and a 1026.20(d) initial rate adjustment notice.

1026.20(c) permits a look-back period of less than 45 days through January, 2015, and a payment adjustment notice may be sent no later than 25 day prior to the payment adjustment date.

1026.20(d) permits the use of an estimated rate but requires a second notice with the actual rate to be sent no later than 60 days prior to the adjustment date.

It appears that (c) lets a bank use a 45-day or less look-back period but (d) disallows the use of a 45-day or less look-back period. What am I missing?
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Lending Compliance
#1917164 - 04/24/14 02:50 PM Re: Subsequent ARM Notices Under 1026.20 Wonderofitall
Wonderofitall Offline
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Wonderofitall
Joined: Sep 2010
Posts: 226
Out West
Bump
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#1917910 - 04/25/14 09:43 PM Re: Subsequent ARM Notices Under 1026.20 Wonderofitall
Wonderofitall Offline
100 Club
Wonderofitall
Joined: Sep 2010
Posts: 226
Out West
And, one more time.
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