I am focusing on the regulation, regardless of what some article might say. I agree that the notice under 1026.20(c) does not have to be given if there is no change in the interest rate that results in no corresponding change in the payment amount. However, 1026.20(d) is written totally differently. The early notice is only an estimate of what might happen in the future. I see no exception in 1026.20(d) like there is in 1026.20(c).
(c) Rate adjustments with a corresponding change in payment. The creditor, assignee, or servicer of an adjustable-rate mortgage shall provide consumers with disclosures, as described in this paragraph (c), in connection with the adjustment of interest rates pursuant to the loan contract that results in a corresponding adjustment to the payment.
(d) Initial rate adjustment. The creditor, assignee, or servicer of an adjustable-rate mortgage shall provide consumers with disclosures, as described in this paragraph (d), in connection with the initial interest rate adjustment pursuant to the loan contract.
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