I have never seen this before. Looking at a subsequent arm notice and the rate change date is August 27, 2019 and the payment change date is September 15,2019. When this loan originated back in 2004 the payment change date stated October 15, 2009 and the rate change date stated August 27, 2009. Is this okay? Normally, I see the rate change date 30 days before the payment change date. Reg Z has a sample subsequent notice which shows the rate change date 30 days before the payment change date. 1026.20(c)

Without reading the note, it is hard to say, but:

The disclosures shall be provided to consumers at least 25, but no more than 120, days before the first payment at the adjusted level is due for ARMs with uniformly scheduled interest rate adjustments occurring every 60 days or more frequently and for ARMs originated prior to January 10, 2015 in which the loan contract requires the adjusted interest rate and payment to be calculated based on the index figure available as of a date that is less than 45 days prior to the adjustment date.