Hello,
I am working on a file where the loan was approved as a variable rate adjusting every 3 years, however the loan was documented with a fixed rate instead. Our doc team prepared a Change in Terms Agreement to modify and correct the interest rate from fixed to variable (effective two months later). For HMDA reporting, would I need to report the introductory rate period as "NA" since that is how it was prepared on the Note as of the closing date, or should I report "36 months" to match the approved rate that it was modified to?