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#2157027 - 12/12/17 09:03 PM AP Table, subsequent changes for construction-perm
burke116 Offline
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Joined: Jun 2014
Posts: 562
Petersburg, VA
The Model form H-24(C) (Mortgage Loan Transaction Loan Estimate—Interest Only Adjustable Rate Loan Sample) shows a 5 year interest-only, 5/3 ARM example. They show that the "subsequent changes" line should read "every 3 years" as if it were reflective of the interest rate changes as well.

The AP table is used to describe changes to the payment based on a loan term other than a change to the interest rate:

37(i) Adjustable payment table.
1. When table is not permitted to be disclosed. The disclosure described in § 1026.37(i) is required only if the periodic principal and interest payment may change after consummation based on a loan term other than a change to the interest rate, or the transaction contains a seasonal payment product feature as described in § 1026.37(a)(10)(ii)(E). If the transaction does not contain such loan terms, this table shall not appear on the Loan Estimate.

Shouldn't that subsequent changes line read "no subsequent changes" since the table is used to describe changes to the payment based on a loan term other than interest rate? The AIR table already describes the interest rate changes. Or, should an interest rate change be included on this table as well, just as the CFPB has done in their example?

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#2157032 - 12/12/17 09:23 PM Re: AP Table, subsequent changes for construction-perm burke116
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
They are correct. What you quoted is how you determine whether or not the table appears. Once it appears you complete based on the entire legal obligation.
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#2157065 - 12/13/17 12:42 PM Re: AP Table, subsequent changes for construction-perm burke116
burke116 Offline
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Joined: Jun 2014
Posts: 562
Petersburg, VA
Thanks Randy.

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