So we added a discounted start rate right before closing. The ARM disclosure is required to be given "at the time an application form is provided or before the consumer pays a non-refundable fee, whichever is earlier."Obviously, in our case, the discount feature was added after the application was provided.
So, it doesn't sounds like you can change the program after the initial ARM disclosure is provided and still comply with 1026.19(b), even if it was the borrowers request.
Would we have to consider the original application withdrawn and start a whole new application in order to make the change?
All opinions are my own, not my employer's