We use the end of January as the time we update our early ARM disclosures and the rate as of January 31st was discounted. One week we may decide to discount the rate and the next week we may not discount it. We also prepare 'mortgage kits' that include the early ARM disclosures, CHARM booklet, etc. My question: should we place two disclosures in the kit - one for a fully indexed rate and then one for the discounted rate? 226.19(b)(2)5 Revisions - A creditor must revise the disclosures once a year and revisions to the disclosures also are required when the loan program changes The branch managers love the 'kit' because they don't have to 'think' about what to give to the customer when they come in for an application for a mortgage loan.

Similar question .

Darn - I did do a search, but didn't come across that - but I still have my question - in our mortgage kits can I place two disclosures - one discounted and one fully indexed? If we can't do it that way the loan officers will have to go back to putting the mortgage kit together each time a person comes in to get a mortgage application - 'disclosures must be provided at time the application form is provided' ......and it may turn out that we give a discounted disclosure and the customer comes back a month later and the rate is no longer discounted..... Baffled

Yes. We have 3 different ARM disclosures in our mortgage packets.

Thanks - that's what I wanted to hear - we'll have 2.

I couldn't put my finger on this earlier, but here's a regulatory cite allowing multiple disclosures:

OSC 226.19

If a consumer who has received program disclosures subsequently expresses an interest in other available variable-rate programs subject to 226.19(b)(2), or the creditor and consumer decide on a program for which the consumer has not received disclosures, the creditor must provide appropriate disclosures as soon as reasonably possible . The creditor, of course, is permitted to give the consumer information about additional programs subject to §226.19(b) initially .