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.