We are going to offer a 15 year product that will be billed interest only for 60 months. The interest will be billed monthly. There will be no minimum payment required. After the 60 months, the line would go back to the normal terms and the payment would be calculated and billed.
The question I have is: do we have to make any special disclosures because this is an interest only loan for the first 60 months? I can't find anything in Reg. Z that would lead me to think that I would need to do this.
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My opinion is mine only- not my employer's!