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#2023647 - 06/29/15 12:03 PM Which rate change notice applies?
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Under 1026.20(d), an initial interest rate adjustment notice is required only for the first time the interest rate adjusts, and must be provided between 210 days and 240 days before the first payment at the new rate is due. Afterwards, under 20(c) a notice must be provided 60 to 120 days prior to the first payment due after the rate adjusts if the payment will change. My questions is: should the 20(d) notice be delivered for the first adjustment after the regulation’s effective date in 2014, for instance if the the loan originated years ago and the rate adjustment after the effective date is not the loans first adjustment, or should it be the 20(c) notice? Your advice would be very appreciated.

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#2023666 - 06/29/15 01:39 PM Re: Which rate change notice applies? Compliance Poster
rlcarey Online
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rlcarey
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Galveston, TX
If your loans have adjusted once under the old rules, 1026.20(d) will not apply.
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#2023775 - 06/29/15 05:32 PM Re: Which rate change notice applies? rlcarey
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Thank you Randy. That's what made sense to me, but sometimes of course regulations need not make sense.

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