Here's what I think needs to happen, but I'm too far in it to think clearly

1026.20(d)(2) tells me that if our initial notice of new rate/payment is an estimate we use the index date 15 days prior to the date we send the notice.

1026.20(d)(2) and (c)(2) tell me to send a second notice of actual rate/payment using the index date 45 days prior to the first payment date at the new rate.

Is this right?

Bump

1026.20(c)(2) will use the rate based on what is in your legal obligation for the lookback period. In order to meet the notice timing requirements however, that look back has to be at least 45 days, if the loan was originated on or after January 10, 2015.