Hello! Need some expertise on interpreting 1003.4(a)(25) in regard to 'whole months.'

Generally, if we have a 10 year loan, its reported as 120 months. However, a very astute employee has questioned this recently. For example, we have a contract dated 3.22.19 and maturity is 3.10.29. This is technically 119 months if we do not consider the remainder of the partial month as indicated in comment #2 under this section. But this is on monthly payments, so not sure that comment applies.

Do we need to get that specific with each loan to determine if the end maturity has days less than a full month? What are others doing? Thanks for any help.

For a fully amortizing covered loan, the number of months after which the legal obligation matures is the number of months in the amortization schedule,

This is technically 119 months

Actually it is 121.37 months. (3641 days divided by 30) or assuming your first payment is due 4/10/19 3622 days divided by 30 or 120.73 months.

Your loan is a 10 year fully amortizing loan with monthly payments. You report under Comment #1 or 120 months.

Thank you!