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?
You're never too old to learn something stupid.