I believe that Reg Z 226.20(c) says that the notice cannot be mailed more than 120 calendar days before the pmt change. What if you have a customer that is paid beyond that? When the rate change occurs, it schedules the pmt change date for the date of the next payment which means the notice is printing more than 120 days ahead of time.

Whether they have "paid ahead" or not, the amount of the new payment that is due on a monthly basis changes on the anniversary date. The payment change date mailed to the customer should not be impacted by the current status of the loan.

For example, if the customer was paid ahead $600 and his payment changed from $200 to $300 a month - he is only now "paid ahead" 2 months instead of 3.