Skip to content
GeoDataVision
Thread Options
#2234048 - 04/01/20 03:17 PM ARM Question
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
We have a customer with a 5/1 ARM who put in a request to refinance right when the rates dropped. We want to keep her in the same product, no new money, just lower the interest rate. As I said, she had/has a 5/1 ARM that adjusted once prior to this request. Are we still able to modify this loan and keep at 5/1 status and fix her payments for another 5 years? Does the fact the loan adjusted once even play into the scenario?

Return to Top
Lending Compliance
#2234051 - 04/01/20 03:29 PM Re: ARM Question mdog76
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
Lowering the rate alone would not trigger 1026.20(a). Resetting the payment adjustment periods however might be considered adding a new variable rate feature.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2234053 - 04/01/20 03:37 PM Re: ARM Question mdog76
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
And if it does that means new TRID documents correct?

Return to Top
#2234057 - 04/01/20 04:13 PM Re: ARM Question mdog76
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
Yes - a refinance under 1026.20(a) would trigger a new early ARM and TRID disclosures.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z