We are having some internal differences of opinion on how the AP table should be completed on the LE and CD for a particular product and wondered if anyone else had encountered this or had any CFPB or other guidance on how to complete.

Product is a 15/1 ARM Construction/Perm loan with 12 months Interest Only during the construction period accomplished with one closing. The 15 year period includes 12 months IO and 14 years of P&I payments.

System is completing the AP Table with:

Interest Only Payments? - Yes, For your first 12 months
Optional, step, and seasonal payments are completed with NO
Under Monthly Principal and Interest Payments:
First Change/Amount - xxxx at 13th payment
Subsequent Changes - every year
Maximum payment - xxxx starting at 205th payment

One faction is saying that since the AP table is only required when there is a payment change that is not based on the interest rate, that the entire section under Monthly Principal and Interest Payments should be blank because there is only one change that is not based on an interest rate.

The other group believes that the system disclosure is accurate as it appears to follow 1026.37(i)(5). The regulation does not say that only payments that are not based on interest rate change are to be disclosed.

Any opinions?

Isn't this a very similar situation to the CFPB example LE for an interest only adjustable rate loan? http://files.consumerfinance.gov/f/20140...sample-H24C.pdf

I believe you want to fill in the Monthly Principal and Interest Payments sections, just like the provided example. I also don't see any mention in the rule that states this monthly section is optional. My understanding is that if the AP table is provided, the monthly section must be filled in.

Steve