On our adjustable rate mortgages, the interest rate and payment can change every 6 months after the initial fixed period. The maximum payment disclosed on the projected payment table reflects two changes each year. For example on a 5 year ARM, the payment changes on payment #61 and #67. So on the LE and CD the maximum payment shown for year 6 is the amount for payments #67 - 72. Year 7 maximum payment would payments #79-84.
A vendor is claiming that due to TRID 2.0, mid-year payment changes no longer need to be disclosed unless it happens in the first year of the loan. I've asked for a reference to the actual regulation, but in the meantime thought I would ask if anyone else has heard of this. I've searched but haven't found anything that states mid-year payment changes don't have to be disclosed.
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Don't cry because it's over. Smile because it happened ~ Dr. Seuss
CRCM