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.

Well, TRID 2.0 did make a change to 1026.37(c)(1)(iii)(B) which does not require disclosing a range merely because the periodic principal and interest payment may change once during a single year (unless such change may occur during the same year as the initial periodic payment).

But I really don't know how this section would be applied to an ARM loan as you would have separate minimums and maximums that could apply during the year based on rate caps, would you not?

I think that's why I confused.
For the 5 yr ARM loan--first column in the table shows the fixed payment, the rest of the columns disclose a minimum payment and the maximum payment based on the possible rate changes. Since the payment can change twice each year-we are showing the maximum payment based on the two interest rate changes.

This vendor is claiming the maximum payment should only reflect the first interest rate change, not the second.

They are stopping too soon. 1026.37(c)(1)(iii)(B) does not apply to an adjustable rate loan.

Paragraph 37(c)(1)(iii)(C).

1. Adjustable rate mortgages. For an adjustable rate loan, the periodic principal and interest payment at each time the interest rate may change will depend on the rate that applies at the time of the adjustment, which is not known at the time the disclosure is provided. As a result, the creditor discloses the minimum and maximum periodic principal and interest payment that could apply during each period disclosed pursuant to § 1026.37(c)(1) after the first period.