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#2259422 - 09/09/21 01:53 PM ARM & CHARM FOR SECOND MORTGAGE AND REFINANCE
dtew Offline
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Joined: Apr 2021
Posts: 5
Is an ARM disclosure and a CHARM booklet required for an adjustable rate second lien refinance mortgage? Just need clarification.

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Lending Compliance
#2259427 - 09/09/21 02:27 PM Re: ARM & CHARM FOR SECOND MORTGAGE AND REFINANCE dtew
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,943
Galveston, TX
Lien position is irrelevant:

1026.20(b) Certain variable-rate transactions. Except as provided in paragraph (d) of this section, if the annual percentage rate may increase after consummation in a transaction secured by the consumer's principal dwelling with a term greater than one year, the following disclosures must be provided at the time an application form is provided or before the consumer pays a non-refundable fee, whichever is earlier (except that the disclosures may be delivered or placed in the mail not later than three business days following receipt of a consumer's application when the application reaches the creditor by telephone, or through an intermediary agent or broker):
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