Thread Options
#2032510 - 08/07/15 08:29 PM Adjustable Payment (AP) Table - LaserPro
Miss Comply Offline
Member
Joined: Mar 2012
Posts: 81
According to the Guide to the Loan Estimate and Closing Disclosure Forms published by the CFPB, the Adjustable Payment table is to be disclosed on the Loan Estimate if the loan contains any specific features (interest only, optional payment, etc.).

I am testing an interim (bridge) loan that has interest only payments and that box is not populating on the bottom left page 2 within LaserPro.

Has anyone else noted this issue, are we missing something or did I misinterpret the guide?

Thanks!
_________________________
The opinions I express are soley mine.

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2032588 - 08/10/15 02:15 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
The table is to appear in the Loan Estimate if the periodic principal and interest payment may change after consummation (but not based on an adjustment to the interest rate), or if the transaction is a seasonal payment product as described in paragraph 1026.37(a)(10)(ii)(E). Then, if the table appears, you indicate whether specific features (interest only, optional payment, step payments, or seasonal payments) apply.

From page 47 of the Guide to the Forms, page 47:
Quote:
The Adjustable Payment (AP) Table is disclosed when the periodic principal and interest payment may change after consummation, but not because of a change to the interest rate, or the loan is considered to be a Seasonal Payment product. (ยง 1026.37(i)) If the loan does not contain these features, the AP Table is not disclosed. (Comment 37(i)-1) [emphasis added]


Based on your description of the loan, the table shouldn't even appear in the disclosure.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2032643 - 08/10/15 04:50 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
Miss Comply Offline
Member
Joined: Mar 2012
Posts: 81
Thanks for your reply John. I interpreted the Guide to indicate that it was required because the interest only payment changed based on the number of days of the month (rate is fixed), so I am glad that I am mis-interpreting this and it's not a LaserPro issue.

I appreciate the help!
_________________________
The opinions I express are soley mine.

Return to Top
#2032684 - 08/10/15 06:19 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
Is Laser Pro omitting the table altogether? I didn't read that in your OP, but you could have meant that when you said "the box is not populating."
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2032997 - 08/11/15 07:24 PM Re: Adjustable Payment (AP) Table - LaserPro John Burnett
ccman Offline
Platinum Poster
Joined: Sep 2007
Posts: 918
Would the AP Table be used for fixed rate loans such that due to USDA RD has irregular payments or mortgage loan that has PMI and irregular payments (not due to interest rate change)?

Trying to understand when to you this table. thanks.

Return to Top
#2033001 - 08/11/15 07:32 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
It only looks at the P&I payment. Changes in PMI premiums aren't covered by this table. If the P&I payment can change without a change in interest rate, this table will be used. That includes seasonal payments, step payments, optional payments (is anyone still making those insane loans?), interest only changing to P&I, etc.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2033068 - 08/11/15 09:04 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
Lakeminded Offline
Member
Joined: Mar 2014
Posts: 76
Washington
John,

What about a construction only loan - non revolving, I/O, that is originated undisbursed with monthly draws, should we be seeing the AP table in these situations?
_________________________
I'm not sure about I'm sure...

Return to Top
#2033113 - 08/12/15 12:38 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
This is a gut response, since I haven't seen any sample disclosures for such a loan and the Bureau's attention to construction loans was, according to many commenters, incomplete in the TRID rule.

Basically, the loan is an interest only balloon payment loan. I don't think the AP table will be used.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2034105 - 08/17/15 08:44 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
Miss Comply Offline
Member
Joined: Mar 2012
Posts: 81
Thank you so much for taking the time to reply, in answering your question from the 10th, the table was omitted altogether. In looking at it more, I agree with your gut. I am not going to worry about this any more!

Thanks again!
_________________________
The opinions I express are soley mine.

Return to Top
#2038650 - 09/15/15 09:00 PM Re: Adjustable Payment (AP) Table - LaserPro John Burnett
Moeciu Offline
New Poster
Joined: Aug 2015
Posts: 13
Hi - on a construction loan, 30 y fixed, disclosed as a single transaction, should we have an AP table. I think yes, based on 1026.37(i), but I will appreciate confirmation. Thanks.

Return to Top
#2038653 - 09/15/15 09:03 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,948
Galveston, TX
If it is an interest only loan with a balloon, there is no adjustable payment unless you have added a stepped rate feature or something like that.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038813 - 09/16/15 03:35 PM Re: Adjustable Payment (AP) Table - LaserPro Miss Comply
SaaL Offline
Gold Star
Joined: Mar 2008
Posts: 294
The Texas Hill Country
Moeciu - If you're asking about a one time close construction loan (which I gather from your statement regarding 30 yr and disclosed as a single transaction) and the transaction includes a construction portion with interest only payments and permanent portion that includes p&i payments and you're disclosing as a single transaction then based on my reading I would say you should have an AP table.
_________________________

Return to Top