We are encountering our first initial rate adjustment and have a question about the new rate and payment. 1026.20(d)(2)(vi) says the actual rate/payment must be provided at least 2 months prior to the initial payment adjustment. We use SOFR as our index and have no idea what it will be 2 months from now. Is our guess sufficient to determine the actual rate and payment for the borrower or are we to use the rate as of the date of the notice?

You have to have a lookback period in your note of at least 45 days in order to produce this notice. There is no "guessing" involved.

Sorry, but I'm not getting it. We give a notice 60 days before the change using a rate 45 days prior to the change?

Yes, if your note has a 45 day look back - here is an example - all months have 30 days in this example.

Interest rate change is due January 1st and first payment at the new payment level is due February 1st.

So you have to have your notice sent by December 1st, 60 days prior to the February 1st payment at the new level.

Using your 45 day lookback in your note, you then set the new interest rate for the adjustment period on the SOFR index on November 16th, which is 45 days before January 1st, and that then gives you 14 days to get them the notice by December 1st..