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#2186837 - 07/25/18 08:37 PM ARM loan - Irregular Transaction?
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,062
In the mountains
Would a ARM loan with a fixed initial premium or discounted rate that will change to a variable rate based on a margin and index be considered an irregular transaction?
Always learning something new...

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Lending Compliance
#2186847 - 07/25/18 09:35 PM Re: ARM loan - Irregular Transaction? Likes to Comply
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,088
Toano, VA
Late in 2012, I wrote a white paper on Reg Z's "irregular transactions" rules. BOL placed it in Tools or some other resource collection, but now I can't find it. If it's still on the site, maybe someone can post the link here for future reference. For now, I've posted a copy at

The short answer is: it depends on what the loan's payment schedule looks like (when you apply the rules from Section 1026.17(c)(1), OI #10) on a cash flow diagram.
...gone fishing.

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