During our post closing review, it was noted that the closing attorney prepared an ARM Rider with a 45 day lookback to determine the current index; however, the note we provided the attorney had a 60 day lookback.

TIL requires that the Paymnent Change Notice for ARM loans be provided at least 60 days, but no more than 120 days before the first payment at the adjusted level is due. Is the lookback period of 45 days still correct for a 5/1 ARM loan that is originated in June 2015? Or should the lookback period also be 60 days?

We use a 45 day lookback period and are able to produce the notices within the required timeframes. I think you would have issues if the lookback period was anything less than 45 days.