This topic is still frustrating me. The point where the table starts would seemingly make a difference for certain scenarios. If it starts at closing, then that is going to result in a different range compared to if it starts with the first payment. For example, lets say there is a 11-month Interest Only Construction Phase with a loan that closes 2/15/2013. If you start the table based on the closing date with a normal 1st payment that would be due 4/1/2013, then your 1st stream would take you through February 2014. If permanent phase payments began 3/1/2014, then you would have a "Year 1" that encompasses just Interest Only payments, as the P & I starts after the 1 year range would end on 2/14/2014. However, if the 1 year period begins with when the 1st payment is made (4/1/2013), then you would have the 11 interest only payments and the 1st permanent phase P & I payment on 3/1/2014 both within the "Year 1" range. So, depending on which you use, the table would be different. Either "Year 1" encompasses the Interest Only payments and that's it, or it encompasses both.
Using the LE on the CFPB site as an example, they seem to utilize the date from when the 1st payment begins.
https://files.consumerfinance.gov/f...ly-adjustable-rate-loan-sample-H24C.pdf. Otherwise (if using the closing date), assuming a 4/1/2013 first payment, based on the 2/15/2013 close, you would have the P & I phase kick in on 4/1/2018. Comparing 4/1/2018 to the close date of 2/15/2013 would put the former in Year 6, as 5 years would end on 2/14/2018. In that case the table should be "Years 1-6" in the 1st column and not "Years 1-5." But, I don't feel this jives with a literal understanding of "Year 1," which would more readily be understood as from the closing date.