Thank you Randy. Here's more info on the questions.
This is the first notice that would be going out. According to the Reg. the timing of the notice should be between 210 to 240 days before the first payment at the new rate is due. "Before the first payment at the new rate is due" is vague? Does this mean up to the day before the first payment or the month before the next payment at the new rate? I'm trying to get a better understanding of this requirement. Or I'm I looking at this way too deep.
Here is an hypothetical example:
ARMS adjustable - 5/5
Note date September 20, 2017
Disbursement date: September 21, 2017
First payment due: November 15, 2017
First Rate changed date: October 15, 2022
Next P&I Payment/Term Change date: November 15, 2022
Date of notice sent to the customer: March 09, 2022
Question:
When calculating whether the notice was sent within the 210-240 days, does one count the days up to November 14, 2020 starting with March 09.? If the March 09, was used the it would show that the notice exceeded the 240 days?
How does one determine when the notice should be sent in advance? Is this something that can be setup in the CORE, where the notice can be printed out?
is there a guide that shows one how to calculated when the first monthly payment is due?
Thank you for your help