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#2042245 - 10/02/15 06:31 PM Product Type
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
For a 12 mo interest only loan, is 'Year 1 Interest Only, Fixed Rate' appropriate for the description? OR do we have to put it as "12 month Interest Only, Fixed Rate'?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2042259 - 10/02/15 07:00 PM Re: Product Type ahou
zozo Offline
Junior Member
Joined: Aug 2015
Posts: 27
we put " 1 Year Interest Only, Fixed Rate" .

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#2042262 - 10/02/15 07:07 PM Re: Product Type ahou
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Thanks zozo. I'm about to go crazy!
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#2042264 - 10/02/15 07:09 PM Re: Product Type ahou
Jerod Moyer Offline
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Jerod Moyer
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
1 year should be good to go based on the Commentary to §1026.37(a)(10) #3(ii) Here's my summary of that:

Any time period less than 24 months that does not equate to a number of whole years must be disclosed in whole months followed by “mo.”
Last edited by Jerod Moyer; 10/02/15 07:11 PM.
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#2042265 - 10/02/15 07:10 PM Re: Product Type ahou
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Welcome to Bankers' Threads, zozo. You've got it right. "1 Year Interest Only, Fixed Rate"
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2042286 - 10/02/15 07:44 PM Re: Product Type John Burnett
zozo Offline
Junior Member
Joined: Aug 2015
Posts: 27
Thank you, John! This is very encouraging smile Banker's thread is one of my best compliance friends smile

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#2048054 - 11/04/15 06:54 PM Re: Product Type ahou
wanted Offline
Member
wanted
Joined: Oct 2001
Posts: 99
United States
For a 12 month interest only loan---- What about the product description: "11 mo. interest only fixed rate"? This is the description that was seen recently in a webinar on TRID and construction loans.

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