I'm sorry but I have looked in the threads and cannot find the answer to my questions. We originate consumer construction to perm loans with the note containing the construction period (say 12 mos) followed by the perm phase, often times ARMs. We provide 2 sets of LEs, one for the construction phase and another for the perm phase. Let's say we have a 10/1 ARM on a 30 year amort with a construction period of 12 months, all in one note.
Do we report the "loan term" as 372 months?
What do we report for the "introductory rate period"?
For calculating the rate spread, do we use 10 years for "years to first adjustment"?
Last, would we report it as having a "balloon payment" due to the construction period?

Fiddlesticks, did you ever receive an answer for this? I am curious as well.

Me too.

I also want to know if Fiddlesticks can play fiddlesticks.

We offer similar loan types and would like to know the answer to Fiddlesticks questions.

Has this been answered?

I don't think so - has anyone sent the question to the CFPB yet?

I sent in a similar question to the CFPB about a few weeks ago but it only pertained to the first 2 questions Fiddlesticks asked. It took 3 emails and 2 phone calls from them to answer my question. Here's a summary of what I asked and their reply that I wrote to my Team:

If a loan closes today (5/15) and the first payment is 7/1 and is a 30 year loan, the loan term is 360. Ignore any period of time before the first payment starts. What was throwing us off was the commentary to .4(a)(25) #3 & #4 which state:
3. PURCHASED LOANS.
For a covered loan that was purchased, a financial institution reports the number of months after which the legal obligation matures as measured from the covered loan's origination.

4. OPEN-END LINE OF CREDIT.
For an open-end line of credit with a definite term, a financial institution reports the number of months from origination until the account termination date, including both the draw and repayment period.

He (the CFPB attorney) said you only count from origination date when it is a purchased loan or a LOC. IOW, Comment #3 & 4 don’t change the answer for originated, closed-end loans.

The interest rate change [(a)(26)] is more clear that it is always from account opening / loan closing.

Hi David, I am not sure I understand your answer regarding the number of months.
1.)Regarding a loan with a 12 month construction period that closes on 5/15/18 first interest payment due 07/01/18 then a 360 month repayment period beginning 1 year later on 07/01/2019 with P & I payments, would the term be 372 months or 360 months,
disregarding the temporary period of construction and interest only payments.
2.) if we disregard the 12 month construction period do we use interest only payments or no interest only payments in the section regarding the loan.
thanks for all your help over the years!!!

Any guidance on this scenario would be appreciated.

1) 372. Start counting with the first payment (7/1/18) and stop with the final payment 31 years later.
2) NA.

Sorry David, I was confused by your 2) NA...Just to be clear, if we have a const-perm loan that is a 5/5 ARM with 12 months interest only and 30 years perm financing we report the loan term as 372 and the introductory rate period as 72 months (since the first rate change will actually be after the first 5 years of permanent financing)?

The reason I wrote "NA" for #2 was because #1 was right and because you wrote "if we disregard . . ." You don't disregard the 12 month construction period.

You report the loan term as 372. The Intro Rate period would be 72 (12 months of construction financing and 60 months of perm before the rate changes).